¹ As Mr. Oliver J. Lissitzyn pointed out in 1936: “The foregoing examination of the meanings attached to the term ‘denial of justice’ by writers and of its use in diplomatic practice and in international adjudications clearly shows that no agreement, or even predominance of opinion, exists on this question. This conclusion may be surprising at first sight, in view of the widespread use of the term. It is believed, however, that this condition is due to the fact that the determination of particular controversies has almost never depended upon the meaning attached to this term. In almost all cases, the real question has always been whether or not a State was responsible internationally for a particular act or omission, and not whether such an act or omission can be called denial of justice. Hence the incidental use of the term in most cases. It is interesting to note that the American and Panamanian General Claims Commission has found it possible to avoid the use of the term in its decisions.” (“The Meaning of the Term Denial of Justice in International Law,” this Journal, Vol. 30 (1936), pp. 632, 646.)