this principle. Article 17 of the Charter gives the GA the power to make binding dispositions both as regards the budget (expenditures and income) and assessments. In practical terms, the absence of an obli- gation to pay would impede the organizatio

discussed the matter in general in his separate opin- ion in the Expenses Case75 and qualified the general obligation to con- tribute which he conceded did exist. While beginning with the propo- sition that irrespective of Article 17(2) there was an obligation upon member states collectively to finance the organization, at least to the extent necessary to make the organization workable, he made a number of distinctions. The problems created were because of the differing legal effect of resolutions and the possible existence of a difference between essential and non-essential activities. As regards decisions of the SC, these were binding oninternational business litigation all member states, no problem arose in connection with them and all member states were bound to bear expenses incurred under them, whether they agreed with the decisions or not and whether they were members of the SC or not. Recommendations of the SC or GA, however, were not binding per se and might cause problems. It could be argued that in certain circumstances a distinction should be made between those who voted in favour of such resolutions or abstained and those who voted against them, because the latter showed disapproval of the resolutionsinternational business litigation being carried out so that there could be some doubt sometimes about their obligation to contribute.76 There were four cate- gories of recommendations: (i) those made in the area of the essential activities of the UN, such as peacekeeping activities; (ii) those which prescribed action solely in the way of making a payment or financial contribution (e.g., for some purpose of aid or relief); (iii) those made in the area of more or less permissive or non-essential activities of the 73 See particularly, Alvarez, loc. cit, note 7; Galey, loc. cit. note 1; Nelson, loc. cit. note 7. 74 See Zoller, loc. cit. note 7, who is of the view that withholding of payments is justified, when in the view of the international business litigation member it is compelled to do so to defend itself against the ‘corporate will’ or tyranny of the majority. 75 1962 ICJ Reports at pp. 210ff. 76 Ibid. at pp. 213ff. t h e o b l i g a t i o n t o pa y 377 organization, such as its social or economic activities; and (iv) those made pursuant to permissive activities which were closely connected with essential activities. In the case of (i) and (iv) there was a duty to contribute, irrespective of how votes were cast. In the case of (ii) there was no obligation to contribute if a negative vote had been cast by the member state, because the making of the payment or contribution was not merely a means to an end but the end itself and it became apparent that, if even member states who voted against the recommendation were under an obligation to contribute, the recommendation itself would acquire a wholly obligatory character; and in any case the practice of the UN was to seek voluntary