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Reckless Attempts—Rape and Circumstance

the underlying obligation has lapsed. It characterised the order sought by New Zealand as an order for cessation. Many will undoubtedly continue to find the basis and application of this distinction elusive, though the logic of the Tribunal's ultimate decision on remedies is clear. The Tribunal accordingly issued declarations that France had acted unlawfully, but made no order for the return of the agents to Hao. Although New Zealand had not sought compensation, the Tribunal also recommended that a New Zealand-France "friendship fund" be established with an initial contribution of US$2m from France. This recommendation has been accepted.