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INTERNATIONAL CENTRE FOR THE
SETTLEMENT OF INVESTMENT DISPUTES
Lone Pine Resources Inc.
Versus
Canada (ICSID Case No. UNCT/15/2)
An application for leave to file Amicus Curiae submissions
Muhammad Muzahidul Islam, Lawyer, Supreme Court of Bangladesh
August 4, 2017
1. Upon an open invitation of the Tribunal (ICSID) dated 20.6.2017 this application for leave to file Amicus Curiae brief has been submitted. The discretion of the Tribunal to accept and consider the amicus curiae briefs from non-governmental persons is well established. There is no particular procedure for amicus curiae submissions; an application for leave to file such brief coupled with the attached brief has been submitted electronically via an email to the office of ICSID.
THE AUTHOR
2. Muhammad Muzahidul Islam is currently practising as an advocate in the Supreme Court of Bangladesh. He is a member of Bangladesh
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Supreme Court Bar Association. He studied LL.B (Hons) at University of London, LL.B (Hons), LL.M at University of Rajshahi, Bar Vocational Course at Inns of Court School of Law, City University, London, and obtained Barrister at Law from Lincoln's Inn, London. His Chamber is at the following address:
“The Liberty Law” Third Floor, Nakshi Homes, 6/1/A Segunbagicha, Dhaka- 1000, Bangladesh. Email: [email protected]
3. The Author, as an applicant, humbly seeks the leave of the Tribunal to file Amicus Curiae submissions on the following grounds:
I. The submissions made in the brief are different from that of both parties. The submissions would help the Tribunal reach a just decision on the dispute.
II. The submissions made in the brief are regarded to the Matter at Issue: whether Canada has expropriated the investment of Lone Pine Resources Inc. under Article 1110 of NAFTA. This issue is at the central point of the dispute and the submissions would assist the Tribunal in the determination of that issue. The submissions, however, do not cover the issue relating to the amount of compensation.
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III. The Author does not have any material or personal interest in this dispute. He does not have any direct or indirect affiliation with the disputing Parties. He did not take any compensation or fees from any person, government or organization in preparing the brief. One of the significant interests that the Author, as a student of law, has includes- the dispute gets a fair and just decision. As the matter is widely circulated and a further fact that the issue of public- interest is involved, a fair and just decision would be the only answer to the concerns.
IV. The analysis, interpretation and insight that the submissions (Please find in the brief) are based on would assist the Tribunal in the determination of legal and factual issues involved in the dispute.
Wherefore, it is most humbly prayed that the Tribunal may kindly grant the leave to file the Amicus Curiae submissions.
All of which is respectfully submitted,
Signature
Muhammad Muzahidul Islam
August 4, 2017