This article analyses the recent application by the Russian Federation under Article 84 of the Chicago Convention on International Civil Aviation against thirty-seven states for their imposition of airspace restrictions and aviation sanctions on Moscow due to its 2022 invasion of Ukraine. The Kremlin is likely using its application to achieve concessions on the sanctions, however, Russia’s application may test the Council’s ability to approve a decision under Article 84. The dispute highlights the effect of the International Civil Aviation Organization (ICAO) Council’s voting rules which exclude Council members that are a party to a dispute. Examining the history and structure of its voting rules, one that requires a statutory majority for Council decisions, this article proposes several options to alter the ICAO Council’s voting procedures. While the voting procedure can be changed internally through the Council or by amendment to the Chicago Convention, the article concludes with the recommendation that the ICAO Council maintain the current status quo for voting on Article 84 disputes.