The International Court of Justice, in its two successive guises, has on several occasions already had to deal with cases in which its own jurisdiction in the dispute brought before it was at issue. In nearly every instance when its jurisdiction to take cognizance of the merits of a case was challenged, the proceedings were divided, according to a provision in the Court's Rules of Procedure now embodied in Article 62, into a preliminary and a final phase, although such a division is not obligatory in the sense that the defendant party retains its freedom to raise its objections to the Court's jurisdiction not as a preliminary but simultaneously with its defence on the merits.