On 22 February 2023, the International Court of Justice issued an order for provisional measures in Application of the International Convention on the Elimination of All Forms of Racial Discrimination (Armenia v. Azerbaijan), Case No. 180. The Court ordered Azerbaijan to, in the Court’s words, “take all measures at its disposal to ensure unimpeded movement of persons, vehicles and cargo along the Lachin Corridor in both directions” (Order of 22 February 2023; ICJ press release 2023/10).
The Lachin Corridor was, at the time of the order, the sole road connecting Nagorno-Karabakh to Armenia. The order was issued in proceedings brought under the International Convention on the Elimination of All Forms of Racial Discrimination (CERD). Provisional measures indicated by the ICJ are legally binding on the parties under Article 41 of the Court’s Statute, as the Court confirmed in LaGrand (Germany v. United States) (2001).
The record since the order
The case did not end with the February 2023 order. The public docket shows a continuing sequence (full case docket):
6 July 2023. Armenia requested modification of the February order after the installation of a checkpoint on the corridor. The Court’s Order of 6 July 2023 addressed the request; the February provisional measure remained in effect.
17 November 2023. Following the September 2023 military operation and the departure of virtually the entire Armenian population of Nagorno-Karabakh, the Court indicated further provisional measures (Order of 17 November 2023; press release 2023/69).
12 November 2024. The Court rejected Azerbaijan’s preliminary objections and ruled that it has jurisdiction under Article 22 of CERD to hear Armenia’s application (Judgment of 12 November 2024; press release 2024/73). The case proceeds to the merits.
17 December 2025. The Court fixed time limits for Armenia’s Reply and Azerbaijan’s Rejoinder (Order of 17 December 2025). As of mid-2026, the case is in active written proceedings on the merits.
Why this matters
Three things follow from the documentary record.
First, the obligations are not rhetorical. An ICJ provisional measures order creates binding international legal obligations. The question of whether Azerbaijan complied with the 22 February 2023 order – during the months in 2023 when the corridor was, per extensive international reporting, effectively closed – is now part of a live case before the Court with jurisdiction confirmed.
Second, the jurisdiction ruling changes the stakes. Until November 2024, Azerbaijan’s position was that the Court could not hear the case at all. That argument failed. Every documented episode – the corridor closure, the September 2023 operation, the displacement of over 100,000 people – can now be examined on the merits.
Third, the record is public and checkable. Every order, judgment, and press release cited here is a primary document published by the Court itself. This pattern suggests the most durable form of accountability available: a permanent, citable, institutional record that does not depend on any one government’s narrative.
Sources
- Case docket: icj-cij.org/case/180
- Order of 22 February 2023 (provisional measures)
- Press release 2023/10 (22 February 2023)
- Order of 6 July 2023 (modification request)
- Order of 17 November 2023 (further provisional measures)
- Judgment of 12 November 2024 (jurisdiction)
- Order of 17 December 2025 (time limits)


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