Two publications by Associate Professor Danae Azaria have been cited in the Separate Opinion of Judge Nolte and in the Separate Opinion of Judge Tladi in the International Court of Justice’s landmark Advisory Opinion on the Right to Strike under ILO Convention No. 87, delivered on 21 May 2026.

The Advisory Opinion represents a significant development in international law and international labour law, with the Court concluding that the right to strike is protected under the Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87).

The separate opinions of Judges Nolte and Tladi engage with important questions of treaty interpretation, sources of international law, and the reasoning underpinning the Court’s conclusions.

Danae Azaria’s recent book, State Silence Across International Law: Meaning, Context and Developments (OUP 2025), was cited by Judge Nolte in relation to his analysis concerning the interpretation of State silence and inaction (Separate Opinion, Judge Nolte, p. 7, para. 26, footnote 12). Danae Azaria’s article on ‘The Legal Significance of Expert Treaty Bodies Pronouncements for the Purpose of the Interpretation of Treaties’, published in the International Community Law Review (2020), was cited and relied on (as involving a “thorough discussion”) by Judge Tladi in his analysis regarding the legal effect of the pronouncements of expert treaty bodies (Separate Opinion of Judge Tladi, p. 8, para. 22, footnote 32). 

The citation of Dr Azaria’s publications in these judicial opinions by two elected members of the International Court of Justice – from both the Western European and Others Group (WEOG) and the African Group – underscores the influence of her scholarship on contemporary debates before the world’s principal judicial body. 

Such references highlight the enduring role of academic research in shaping the interpretation and development of international law, while also reflecting recognition of Dr Azaria’s work across diverse legal traditions and its relevance to issues considered at the highest level of international adjudication.

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