the SC or the GA or on the Charter itself in some other authorized way, their contract of service being important links in this relation. Hence, although the tortious acts themselves may not have been authorized by the Charter or by resolutions of th

such acts might rest on the notion of ‘the scope of authority’ of the agent or servant. In regard to breaches of contract the ICJ in the Effect of Awards Case dealt with the effect of an award of the UNAT for a breach of a contract of service. It was said that such an award created an obligation of the organization which the organization had to honour and that expenditures arising under such an award were within the compass of Article 17(2).65 The Court in the Expenses Case cited this statement with approval.66 An award of the UNAT establishes a breach of a contract of service attributable to the organization through dispute resolution the instrumentality of its agent, the SG or his delegate. The SG acts within the scope of his apparent authority in taking the decisions which lead to a breach of contract and this is the basis of the liability of the organization. It would not be difficult to apply the same notion by analogy to tortious acts of servants or agents. Judge Fitzmaurice does include this category of expenditure in his list of items covered by the genus ‘expense’ when he mentions ‘any payments which the organization is legallydispute resolution responsible for making in relation to third parties; or which it is, otherwise, as an entity under a legal obligation to make; or is bound to make in order to meet its extraneous legal obligations’.67 Like judicial or arbitral awards resulting from a tortious act or a breach of contract, settlements by the organization involving expenses could also be characterized as expenses of the organization in accordance with comparable principles.68 65 1954 ICJ Reports at p. 59. 66 1962 ICJ Reports at p. 169. 67 Ibid. at p. 207. 68 Judge Morelli thought that, in the case of all expenditures, in order to be an ‘expense’ they had to be included in the budget by the GA under Article 17(1) of the Charter: ibid. at p. 224. This is thought to be unnecessary. 374 f i n a nc i ng It is not international business litigation clear how far these principles applicable to the UN may be applied mutatis mutandis to the characterization of ‘expenses’ for orga- nizations in general. The following propositions, transposed by analogy are, perhaps, true and in accord with the practice of organizations: (i) Administrative expenses (those in the regular budget) are not the only expenditures for which an organization is responsible. (ii) Expenses of an organization include expenditures resulting from the functional operations of an organization authorized by its constitution. (iii) Expenses incurred in accordance with resolutions of organs of an organization which are made in conformity with