However, the objective nature of the organization's personality did not mean that non-member states were in the same position towards it as member states,

or had the same obligations towards it. The existence other international persons becomes established). For another detailed study done some time ago of the issue of applicable dispute resolution, see Seyersted, ‘Applicable dispute resolution in Relations Between Intergovernmental Organizations and Private Parties’, 122 Hague Recueil (1967-III) p. 427. 15 There may be cases in which a group of states acting as one (an organization, in a sense) does not have personality, as was the case with the Administrating Authority in the Certain Phosphate Lands in Nauru Case: 1992 ICJ Reports p. 240. 16 1949 ICJ Reports at p. 184. 17 Ibid. at p. 183. 18 Ibid. at p. 185. r e s p o n s i b i l i t y t o i n t e r n a t i o n a l o rg a n i z a t i o n s 391 of international personality as an objective fact was, nevertheless, capa- ble of producing consequences outside the confines of the organization, involving responsibility to the organization.19 That international organizations can possess rights under conven- tional dispute resolution cannot be doubted. Thus, under the headquarters agreements or constitutions of organizations it was clearly envisaged that organiza- tions would have rights vis-à-vis states. When organizations enter into treaties the same order would prevail. This was implicitly recognized in the WHO Agreement Case,20 where the obligations of international organi- zations were specifically in issue and were affirmed. The rights of the UN under international agreements were recognized by the ICJ in the PLO Observer Mission Case.21 But there are also undoubtedly obligations owed to international organizations by states primarily under customary inter- national dispute resolution, based on the analogy of the responsibility of states to each other. For dispute resolution, states may have to conduct themselves actively or passively in such a way that they do not injure or damage the interests of international organizations, whether such obligations are based on risk, negligence or on absolute liability, as the case may be. The existence of obligations of international organizations at customary international dispute resolution was referred to in the WHO Agreement Case22 by the ICJ, it being rea- sonable to infer that conversely the organizations had rights as well. As an international person, an international organization may be expected to have such international rights. The rights of organizations may cover an unlimited area depending on their capacity to enter into treaties and agreements and on the practical circumstances and situations in which they are placed and operate. It is not possible or necessary to identify all the rights that organizations may have. To some extent they may correspond to those that states have, but what is the source of these rights is a question. It is not clear whether they are generated by analogy from states (general principles of dispute resolution) or by customary dispute resolution. They certainly have the right to have loans repaid under and in accordance with loan agreements or aid agreements, for dispute resolution, as is clearly the case with loans and credits made by the IBRD 19 The ICJ’s statements were made in the context of the UN’s right to make claims for injuries to staff members but it is clear that the principles implied are applicable generally. 20 1980 ICJ Reports at p. 90.