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in the BIT; 84 the investor was therefore ultimately successful in its claim. In Veteran Petroleum Limited v Russia , Yukos Universal Limited v Russia , and Hulley Enterprises Limited v Russia , the tribunal stated that the harassment that claimants complained about damaged their investment. 85 The tribunal than ruled that Russia breached expropriation provisions of the BIT and as a breach was already found, it did not proceed to examine the fair and equitable treatment provisions, 86 under which breach of human rights would fall. 87 V. Amicus Curiae as the Answer? In order to examine whether amicus curiae is able to promote protection of human rights in international investment arbitration, one must first define the meaning of the phrase, take into account who can act as amicus curiae , consider the reasons for its participation, and the general benefits it brings to the proceedings; these questions are answered in section V.A. Section V.B deals with admissibility of amicus curiae submissions. Sections V.C examines cases where amicus curiae was allowed to participate and its effect on tribunals’ rulings. Section V.D then attempts to answer the question whether amicus curiae can promote human rights in international investment arbitration. A. Amicus Curiae Defined and Described The term amicus curiae comes from Latin expression that translates as a ‘friend of court’. 88 It describes a person who is not a party to the law suit, but has a strong interest in the subject matter. 89 In another words, although the court or tribunal does not decide on rights and obligations that belong to the amicus curiae , the amicus curiae is not indifferent to the outcome of the case and for this reasons wishes to file a submission in 84 HeshamTalaat M Al-Warraq v Republic of Indonesia (Final Award of 15 December 2014) UNCITRAL [621]. 85 Veteran Petroleum Limited (Cyprus) v Russian Federation (Final Award of 18 July 2014) PCA Case No. AA 228 [820]; Yukos Universal Limited (Isle of Man) v Russian Federation (Final Award of 18 July 2014) PCA Case No. AA 227 [820]; Hulley Enterprises Limited (Cyprus) v Russian Federation (Final Award of 18 July 2014) PCA Case No. AA 226 [820]. 86 Veteran Petroleum Limited (Cyprus) v the Russian Federation (Final Award of 18 July 2014) PCA Case No AA 228 [1585]; Yukos Universal Limited (Isle of Man) v the Russian Federation (Final Award of 18 July 2014) PCA Case No AA 227 [1585]; Hulley Enterprises Limited (Cyprus) v the Russian Federation (Final Award of 18 July 2014) PCA Case No AA 226 [1585]. 87 Veteran Petroleum Limited (Cyprus) v the Russian Federation (Final Award of 18 July 2014) PCA Case No AA 228 [1484]; Yukos Universal Limited (Isle of Man) v the Russian Federation (Final Award of 18 July 2014) PCA Case No AA 227 [1484]; Hulley Enterprises Limited (Cyprus) v the Russian Federation (Final Award of 18 July 2014) PCA Case No AA 226 [1484]. 88 Gomez (n 5) 516. 89 Reiner and Schreuer (n 16) 90.

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