By Procedural Order No 3 the Tribunals organised inter alia the proceedings concerning the Claimant’s request for the Compensation Declaration. The Parties filed their memorials accordingly. The last of these memorials were Niko’s Reply Concerning the Compensation Declaration (the Reply), filed on 29 May 2014, and BAPEX’s Rejoinder concerning the Compensation Declaration (the Rejoinder), filed on 25 September 2014. 

With respect to the Compensation Declaration, the Claimant seeks a declaration of non-liability. At the Preliminary Procedural Consultation the relief requested in this respect by the Claimant was defined in the following terms: