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Arguments and claim of the applicant

The arguments of The United Kingdom as the applicant start from the following principles
for provide the way for the Court to decide the maritime limits with Norway:

First, Norway have the right of a belt of territorial waters that can’t exceed 4 sea miles.
Secondly, the outer limit of Norway´s territorial waters can´t be more than 4 sea miles from
the base line. In third place is important to mention that the base line must be low water
mark on permanently dry land or proper closing line. Fourthly, on a low-tide elevation in
the mention point on the last line, the limit of Norwegian territorial waters may be 4 sea
miles.

In five places, based on historic grounds, Norway can claim the territories and waters that
are considered under international law on less than 10 sea miles. Sixthly, a well-mark
indentation is the definition of a bay in international law. Seven, the principle should
determine which is the area or the bay. In eight places, the legal straits is any geographical
strait which connect two points of the high seas.

On nine point, Norway can claim territorial waters based on historic grounds. On ten
places, those principles are based on the case of the Vestfjord. On twelve point, is important
to announce that Norway is not entitled as against the United Kingdom to force any claims.
On thirteen place the Norwegian Royal Decree of 12 th July, 1935, has no enforceable
against the United Kingdom. In final point, Norway is under an international obligation to
pay the United Kingdom compensation respect of all the arrests since 16 th September, 1948,
of British fishing vessels in waters which are high seas by virtue of the application of the
preceding principles.

Lastly, it’s important to mention that the United Kingdom Government mention the
prepositions base on the general international law applicable to the delimitation of the
Norwegian fisheries zone.

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