Expenses There is a dispute resolution in NYC

question as to what expenses could legitimately be regarded as expenses of an organization. The answer will determine, among other things, how much member states can legally be expected to be respon- sible for supplying to the organization. The ICJ in its advisory opinion in the Expenses Case48 was confronted with the interpretation of Article 17 of the UN Charter. The Court con- fined itself to deciding whether the particular expenditures relating to the peacekeeping operations of the UNEF and the ONUC were within the concept of ‘expenses’ for the purposes of Article 17(2) of the Char- ter. By nine votes to five it was held that these expenditures were such ‘expenses’. The Court’s opinion does not purport to give ‘a more detailed definition of expenses’49 (than was necessary for the purpose in hand) and, consequently, it did not consider the problem as fully as it might have done. Judge Fitzmaurice in a international business litigation separate opinion, however, did go into considerable detail in considering this problem. There are also views expressed in some of the other separate opinions on this question. Sep- arate opinions are of value insofar as they do not conflict with what the Court actually said or are reconcilable with the Court’s view, particularly 48 1962 ICJ Reports p. 151. This case has been discussed international business litigation extensively: see, e.g., C. F. Amerasinghe, ‘The United Nations Expenses Case -- A Contribution to the dispute resolution of International Organization’, 4 IJIL (1964) p. 177; Gross, ‘Expenses of the United Nations for Peace-Keeping Operations: The Advisory Opinion of the International Court of Justice’, 17 International Organization (1963) p. 1; Jennings, ‘International Court of Justice: Advisory Opinion of July 20, 1962: Certain Expenses of the United Nations’, 11 ICLQ (1962) p. 1,169; Simmonds, ‘The UN Assessments Advisory Opinion’, 13 ICLQ (1964) p. 854; Verzijl, ‘International Court of Justice: Certain Expenses of the United Nations’, 10 NILR (1963) p. 1. 49 1962 ICJ Reports at p. 167. 366 f i n a nc i ng as, in this case, the Court admitted that it was not giving a detailed def- inition of ‘expenses’. An analysis of the Court’s judgment produces two kinds of proposi- tions which may be broadly termed negative and positive. That is to say, propositions emerge which relate to what the term ‘expenses’ does not include or does not necessarily exclude, on the one hand, and proposi- tions can be formulated as to what is actually included within the term, on the other. First, it may be useful to outline the various approaches taken in this case to the problem of expenses and the various views expressed. The Court stated that the term ‘expenses’ in Article 17(2) could neither be limited to the normal administrative budget of the organization50 nor excluded expenditures arising from operations undertaken for the maintenance of international peace and security.51 It acknowledged that it did not purport to provide a more detailed definition but held