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The recently concluded arbitration between the United States and the Netherlands relative to the ownership of the Island of Palmas, which resulted in the decision of the Permanent Court of Arbitration that this bit of territory belongs to the latter country, involved points of interest to the international lawyer out of all proportion to the importance of the res.1 In this respect it would of course be no novelty in the annals of national jurisprudence. In addition to many interesting matters of arbitral procedure, the case involved most of the international substantive law of real property, if it may be so called.
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