The Implications of Expanding International Dispute Settlement Systems: The 1982 Convention on the Law of the Sea

internal, then further arguments and decisions as to the consequences. On the other hand, it is possible that the appeals chamber is suggesting that it may be preferable to treat many of the conflicts in the former Yugoslavia as noninternational, thus dispensing with the need to determine their nature in future cases. In any event, the decision stands as an important judicial affirmation that serious violations of international humanitarian law committed in noninternational armed conflicts are international crimes. Such affirmation would, of course, have been lost if the appeals chamber had followed the advice of the commission and found all of the armed conflict in the former Yugoslavia to be an international armed conflict.