The
Abaclat v. Argentina matter has brought to light a new type of arbitral
dispute: in the event of a sovereign debt crisis, creditors who wish to resist
the adopted restructuration measures act directly against the debtor State on
the basis of the Bilateral Investment Treaty which it has concluded with their
own State of origin. What are the characteristics of this new relationship
between investment arbitration and financial crises? What is the potential
thereof in terms of the possible findings of liability against defaulting
States? And what are the implications of this type of litigation? At a time
when Greece is in turn facing proceedings before the ICSID by reason of the
restructuring of its sovereign debt adopted in March 2012, these questions
require careful examination with a view to the potential supervision of the proceedings.