INDIA AND THE INTERNATIONAL LAWS OF THE SEA PART 5/5: Maritime Claims and Boundary Delimitations

Abstract: The foregoing four parts of this paper (Parts 1/5 to 4/5) published in the preceding editions of INDES analysed the convergences and divergences between India’s national law and policy vis-à-vis the provisions of international law and State practice relating to maritime law-enforcement and peacetime military issues. This final part of the paper examines and analyses the same in the context of India’s maritime claims and boundary delimitation with its neighbours. Like its preceding parts, this final part of the paper is equally relevant for commanders of India’s seagoing services, as it is for national policymaking. Furthermore, drawing from the entire series of articles, it avers that as a major power in the emerging multi-polar world and for good reasons, India needs to continue upon its present trajectory to align its national legal positions with international law.

Introduction

The four preceding parts of this paper (Parts 1/5 to 4/5) examined the international laws of the sea¹ pertaining to criminal jurisdiction at sea, maritime law enforcement and the military issues relating to navigational freedoms during peacetime vis-à-vis the Indian legal positions on these issues. Such comparison was aimed at informing India’s national policy formulation at various levels, and particularly to contribute to professional military education for commanders of the Indian maritime forces, since these issues are directly linked to operational law to be practiced by them.

This part addresses aspects relating to India’s maritime claims and delimitation of its maritime boundaries with its neighbouring coastal States. These aspects are also of operational relevance for Indian maritime forces—and especially for the operational planners—even if some of their applications may be indirect. This correlation may be exemplified by the May 1982 Cold War naval stand-off between the United States (US) and the Soviet Union (USSR) in the Peter the Great Bay located in north-west Pacific Ocean. (See Fig 1 below)

Fig 1: Peter the Great Bay (Source: MDPI)

The incident involved an American frigate, USS Lockwood deployed off Peter the Great Bay, claimed by the Soviets as a historic bay. Although the Lockwood was operating beyond 12 NM territorial sea limit off the USSR coast, Soviet naval units ordered the frigate to leave their “sovereign waters”. This ambiguity was caused because the US Pacific Command, which assigned the operating area to Lockwood, was unaware of the Soviet claim of ‘historic bay’. As a result, the “approved operating area” for the Lockwood lay within the mouth of the Bay claimed by the Soviets, and therefore, within the Soviet Union’s historic waters, wherein even innocent passage regime would not apply.² It caused a serious diplomatic row between the two superpowers, which could have been avoided if the US operational planners were aware of the Soviet maritime claim, notwithstanding its legal validity. In the diplomatic space, the US rejected the Soviet protest since it did not recognise its historic bay claim, and even its claim to a legal (juridical) bay based on the 1958 Convention reflecting customary law.³ (In later years, the US even justified the USS Lockwood case as an operational assertion against Soviet Union’s “excessive maritime claim.”).⁴ Internally, however, the US government realised that it needed to fill the void in its legal practice through awareness of maritime claims of all coastal States. This led to issuance of a US Department of Defense (DOD) directive in June 1983 to publish the US Maritime Claims Reference Manual.⁵

Since the Indian maritime-military forces are operating increasingly in and above international waters, their commanders also need to be guided by such a doctrinal document. The process must be initiated by understanding India’s own maritime claims and agreements that delimit its maritime boundaries. This (final) part of paper is an effort in that direction. The most appropriate approach to do this is to begin with India’s ‘maritime baselines’ claim.

Maritime Baselines

A ‘maritime baseline’ is an imaginary line drawn along the coast based on a set of geographic points. It forms the basis for delineating all maritime zones of a coastal State, including territorial sea, contiguous zone, and the Exclusive Economic Zone (EEZ). Baselines not only demarcate the geographic scope of a state’s sovereignty and sovereign rights in its maritime periphery but also regulate its lawful maritime interface with all other States. Therefore, the preservation of a coastal State’s maritime interests—and thus its maritime security—is premised on a clear understanding of baselines, both of that State itself, and those of other coastal States in the areas of maritime interest.

The UNCLOS says that coastal states should usually adopt the points along the low-water line along the coast (as marked on the State’s official large-scale charts) as a “normal baseline”.⁶ The coastal State exercises complete sovereignty over all sea area landward of such a baseline. However, the UNCLOS also provides for “straight baselines” in unusual circumstances, such as a “deeply indented coastline”, the presence of “a fringe of islands along the coast in its immediate vicinity”, or a “highly unstable coast”, such as one that is formed by riverine delta. In such cases, dispersed baseline points may be joined by straight lines, provided that the baseline so formed does not depart from the general lay of the coast.⁷ The sea area landward of “straight baseline” is considered as the State’s internal waters. A good example is the application of straight baseline to the heavily indented coast of Norway. However, unlike in case of waters enclosed by a ‘normal baseline’, the navigational regime of innocent passage applies in these waters (akin to the territorial sea). The only exception wherein such regime does not apply is in case of historic bays.

The United Nations Convention on the Law of the Sea, 1982 (UNCLOS) obliges all coastal States to promulgate their baselines and inform United Nations (UN) Secretary General.⁸ Accordingly, India established its baselines in accordance with Section 10 of its Territorial Waters, Continental Shelf, EEZ and other Maritime Zones (MZI) Act 1976.⁹ It was first promulgated vide the extraordinary Gazette Notification No. 736 dated 11 May 2009 (with its Corrigendum issued later in November 2009),¹⁰ and submitted to the UN Secretary General through a note verbale,¹¹ who acknowledged their receipt in February 2010,¹² and published it in the UN Law of the Sea Bulletin of 2010.¹³ At that time, however, India did not promulgate the baselines along the eastern coast of its Andaman and Nicobar (A&N) islands. The ostensible reason was the straight-baseline regime, used by some countries including China, for island territories was objected to by the major powers (This aspect will be examined in detail in the following paragraph). Drawing a straight baseline to enclose the isolated Narcondam Island (located 65 NM East of the A&N archipelago) would have led to a very vast expanse of the intervening sea area becoming India’s ‘Internal Waters’, which may have been construed by Thailand as India’s attempt to expand its EEZ by shifting the existing India-Thailand maritime boundary negotiated in 1978 eastwards (examined later).

Notably, however, in its second promulgation in April 2025, India promulgated its complete baseline system, including the eastern coast of A&N islands. Ostensibly, the potential anxieties of Thailand were assuaged by assuring Bangkok that India would continue to abide by the erstwhile 1978 treaty that delimited their maritime zones based on the median-line principle. Whereas the earlier 2009 baselines used the Everest Spheroid datum specific to South Asia, the revised baselines were based on the World Geodetic System 1984 (WGS84) datum. Also, the new baselines were determined by using higher-resolution electronic charts. This improved compatibility with international standards and digital mapping, while also leading to the increase in the total length of India’s coastline from 7,516.6 km to 11,098.81 km. The new baseline system was promulgated vide India’s Gazette Notification No. 177 dated 03 April 2025 (with its Corrigendum issued on 23 April 2025).¹⁴ This was deposited by India to the UN Secretary General, and the same was acknowledged on 28 April 2025.¹⁵

It is clearly advantageous for a coastal State to draw “straight baseline” vis-à-vis a “normal baseline” since the former maximises the State’s maritime jurisdiction. Since every localised condition is geographically unique, the UNCLOS provision on baselines is generic rather than specific, which brings in subjectivity to interpret the provision. Hence, coastal States are inclined to draw straight baselines wherever the aforesaid circumstances could be legally justified, which is often challenged by other States. For instance, when India promulgated its baselines based on straight baselines across the gulfs of Kutch and Khambhat, and at some other areas, Pakistan objected to it. Earlier in August 1996, when Pakistan had announced its own baselines, India had objected to its straight baselines, besides that its baseline Point "K" was located on the eastern bank of Sir Creek, which India considers part of its sovereign territory.¹⁶

The straight baseline system that India has opted for its island territories (Lakshadweep and A&N) does, however, lead to much larger legal dissonance. The UNCLOS also provides for a third category of baseline, called “archipelagic (straight) baseline”, which permits an archipelagic State to draw straight baselines to join the outermost points of their outermost islands and drying reefs. The waters so enclosed are called archipelagic waters wherein the innocent passage regime applies. However, such baselines are meant only for the few (about 22) countries that are designated as ‘archipelagic’ States. These States are mid-ocean insular archipelagos (constituted entirely by islands) like Indonesia and the Philippines, rather than continental States like India that possesses Lakshadweep and A&N Island groups, or the US (Hawaii Islands), or Denmark (Faeroes Islands), or Ecuador (Galapagos Islands).¹⁷ Furthermore, the UNCLOS stipulates that for acquiring the status of ‘archipelagic State’, it must have a land-water area ratio between 1:1 to 1:9, a criterion that is not met by other States that are constituted by mid-ocean insular archipelagos.¹⁸ For instance, States like Cuba, Japan, New Zealand and the United Kingdom are large-land-area island States whose land-water area ratio is less than 1 to 1. On the other extreme are small-land-area island States like Kiribati and Tuvalu, whose ratio is greater than 9 to 1. Ostensibly, it emerged during the UNCLOS-III deliberations that the large-land-area island States did not deserve archipelagic status, and if the small-land-area island States were accorded such status, it would enable them to exercise sovereignty/ jurisdiction over inordinately large sea areas at the cost of navigational/overflight freedoms, which was unacceptable to the maritime powers. Hence the 1:1 to 1:9 ratio band was a compromise between the two extremes.

During the UNCLOS-III deliberations at Caracas in 1974, India submitted a joint working paper that advocated the status of an “Archipelagian State” for all states that possessed mid-ocean outlying archipelagos. Though several other States like Canada, Chile, Iceland, Indonesia, Mauritius, Mexico, New Zealand, Norway, Greece, Ecuador, Argentina, Spain, Peru, France and Honduras supported the proposal, it was opposed by other states like Algeria, Burma, Japan, the USSR, Thailand, Bulgaria and Turkey, who perceived that the proposal was premised on the intent to "grab" ocean areas which should normally be open to all States. As a result, the proposed claim of the “Archipelagian States” was not incorporated into the UNCLOS.

It is clear from the aforesaid that India cannot justify its straight baselines off Lakshadweep and A&N on the UNCLOS provision of “archipelagic baselines”. This reveals a notable void in UNCLOS. The rationale of “archipelagic (straight) baseline” enclosing an archipelagic State was to simplify maritime jurisdiction and avoid the complexities that would have otherwise emanated from the ‘polka-dot’ pattern, if baselines were drawn around each one of the numerous islands in near proximity to determine their individual entitlements of maritime zones. The rationale applies equally to all archipelagos, including those outlying ones of continental States like India. India’s ‘straight baselines’ around Lakshadweep and A&N are premised on this rationale, which is thus in conformity with UNCLOS in ‘spirit’, though not in ‘letter’, i.e. its strictest interpretation. Whereas not calling the straight baselines drawn for Lakshadweep and A&N groups as ‘archipelagic baselines’, India seems to have implicitly maintained the position that the UNCLOS provision of archipelagic (straight) baselines applies to all archipelagos.

Notably however, India’s position is plagued by a geopolitical complexity. China has also used the same rationale to draw straight baselines around Taiwan, Penghu, Paracel and around the Senkaku groups of islands. This could not be left uncontested by the US, which led to the US Navy’s Freedom of Navigation Operations (FONOP) against China, as alluded to in the preceding Part 4/5 of this paper.¹⁹ These operational assertions began in the year 2000, with US FONOPs against “Taiwan’s excessive straight baselines”,²⁰ and was followed by multiple assertions against “straight baselines not drawn in accordance with international law”, every year since 2013. The assertion of 2017 was specifically against China’s “excessive straight baselines” of the Paracel Islands.²¹ In contrast, the US has not conducted any operational assertion against India on the issue of straight baselines around its island territories. However, US Navy’s doctrinal and guidance documents do mention India as being among the twelve States that have drawn straight baselines around their claimed island territories (A&N and Lakshadweep) in contravention of UNCLOS.22

Maritime Boundary Delimitations

The maritime boundary of a coastal State pertains to the extent of its maritime zones based on the delimitation agreement with the opposite/ adjacent State, which leads to a boundary line that India calls International Maritime Boundary Line (IMBL). Such delimitation is necessary to avoid overlapping maritime claims.

India shares maritime boundaries with more States than those with whom it shares land borders. While India has six land neighbours (Pakistan, China, Nepal, Bhutan, Bangladesh and Myanmar), it has seven maritime neighbours (Pakistan, Maldives, Sri Lanka, Bangladesh, Myanmar, Thailand and Indonesia). India thus signed 12 IMBL agreements with five of its neighbours. These agreements are tabulated at Table 1 below.

Table 1: India's IMBL Agreements with Maritime Neighbours

India’s IMBL agreements are based on the delimitations of the territorial sea and/ or the EEZ, depending upon geographic considerations. India-Bangladesh IMBL agreement has yet to be signed after resolution of the maritime dispute through arbitration in 2014. India-Pakistan maritime dispute is yet to be resolved. The specifics of each one of these issues of delimitation of India’s maritime boundaries are examined and analysed in the following text. In the coming years, when the extended continental shelf claims of States beyond their EEZ fructify,²³ these will form the new seabed boundaries of opposite/ adjacent coastal States. This may lead to the addition of Oman as the eighth maritime neighbour.

IMBLAgreement(s) with Sri Lanka and Maldives

India’s first maritime boundary agreement was signed with Sri Lanka in June 1974 to settle the common boundary in the “historic waters” of Palk Bay stretching from Adam’s Bridge to the northern entrance to Palk Strait²⁴ (See Fig 2). The boundary is defined by a set of six geographical points (Points 1 through 6). The delimitation was based on ‘median line’ principle’, with a minor adjustment made in relation to Kachchativu, which is an uninhabited island located about 12 NM from the India (Pamban Island, Adam’s Bridge), about 10 NM from Sri Lanka (Delft Island), and 1.2 NM North of Point 4. Based on equitability, India ceded Kachchativu Island to Sri Lanka. The pact assured traditional rights to the fisherfolk and pilgrims of both sides in the “historic waters”, specifically, “access to visit Kachchativu”. It implied that Indian fisherfolk could only visit St Antony’s church and dry their nets on the Island. The agreement provided each country exclusive sovereignty/ sovereign rights over islands/ sea area on its own side of the IMBL. So, the fisherfolk of one country could not fish on the other side of the IMBL.

Fig 2: India-Sri Lanka IMBL Agreements Source: Sovereign Limits

To extend their IMBL in Historic Waters of the Palk Strait on either side, India and Sri Lanka entered into the March 1976 agreement to delimit the boundary in the Gulf of Mannar and Bay of Bengal.²⁵ This Gulf of Mannar section of IMBL was defined by 13 geographical points, whereas the IMBL in Bay of Bengal was based on eight points. Drawing from the tentative provisions of UNCLOS (being negotiated at UNCLOS III), the March 1976 agreement recognised the sovereign rights of each party in their part of EEZ and extended continental shelves, alike their exclusive rights in Historic Waters under the 1974 agreement. Reportedly, in return for India ceding Kachchativu to Sri Lanka, Colombo recognised India’s sovereign rights over the resource-rich Wadge Bank (Laccadive Sea) located south of the southern tip of peninsular India, which has been a lucrative fishing ground for Sri Lankan fishermen since the 1920s.²⁶

Over the years, however, Indian fishermen have been frequently arrested, and their boats impounded by the Sri Lanka Navy for fishing in Sri Lankan waters. The issue of the traditional rights of Indian fisherfolk in historic waters has thus become politically contentious in India. The Indian State of Tamil Nadu has been demanding that the central government should re-negotiate the treaty to reclaim Kachchativu²⁷ and accord traditional fishing rights to Indian fishing folk in the historic waters. This is something that is not only challenged by Sri Lanka,²⁸ but also that it is not feasible for New Delhi to do, not only for the sake of good neighbourly relations with Colombo, but also to fulfil its international obligation of pacta sunt servanda (Latin for “agreements must be kept”) embodied in the 1969 Vienna Convention on the Law of Treaties, as mentioned earlier in Part 4/5 of this paper.²⁹ Accordingly, the Indian Government explicitly stated its position in the Indian Parliament in August 2011, as follows:

“The Government of India considers its maritime boundary with Sri Lanka settled under the Agreements concluded with Sri Lanka in 1974 and 1976… the Exchange of Letters of 1976 stipulate that fishing vessels and fishermen of India shall not engage in fishing in the historic waters, territorial seas and EEZ of Sri Lanka. Indian fishermen, therefore, do not have the legal right to fish in the waters in Katchatheevu Island…”.³⁰

In January 1977, India issued a Gazette notification laying its claim to the ‘Historic Waters’³¹ based on Section 8 of the MZI Act 1976 (Historic Waters), which states: (1) The Central Government may, by notification in the Official Gazette, specify the limits of such waters adjacent to its land territory as the historic waters of India. (2) The sovereignty of India extends, and has always extended, to the historic waters of India and to the seabed and subsoil underlying, and the air space over, such waters.³²

Although the UNCLOS provision of ‘bays’ does not address State claims to ‘historic bays’, the India-Sri Lanka ‘historic waters’ treaty is based on historic evidence and is thus consonant with international law. However, the United States (US) has contested this ‘historic waters’ claim. In 1983, the US protested this claim.³³ It based on the conclusions of a 1962 UN Study, which averred that to establish a historic claim, a State must meet three conditions: (1) there must have been an effective exercise of sovereignty over the area by the claiming State; (2) the exercise of sovereignty by the claiming State must have continued over a considerable time so as to have developed into a usage; and (3) the attitude of foreign States to the activities of the claiming State in the area must have been such that it can be characterised as an attitude of general toleration. Furthermore, the UN Study says that ‘the burden of proof of title to historic waters is on the State claiming such title.³⁴

Regarding the third factor above, the US takes a contrary view to the historic waters claim of India and Sri Lanka. It avers that the claim is not based on “actual showing of acquiescence” by foreign States, but rather of ‘a mere absence of opposition’.³⁵ Whether the historic waters as claimed by India and Sri Lanka did receive active international acceptance through historic times is difficult to prove through empirical evidence due to inadequate record-keeping and the fact that both countries were part of the British colonial empire in the more recent centuries.

The US also contests the follow-on ‘internal waters’ claim of India and Sri Lanka in historic waters. The UNCLOS does not oblige coastal States to draw straight baselines in historic waters. Accordingly, Sri Lanka has designated the entire Sri Lankan part of Palk Strait (historic waters), and even its part of the Gulf of Mannar as internal waters, where the regime of innocent passage does not apply (See Fig. 2 above). On the other hand, India has been more cautious. In its baseline system, India declared some areas in the Palk Strait (historic waters) and Gulf of Mannar as ‘internal waters’ by enclosing these areas by straight baselines.³⁶ In these waters, India applies the regime of innocent passage in accordance with UNCLOS. Hence, theoretically, the US has a stronger case for conducting operational assertions against Sri Lanka vis-à-vis India. However, as mentioned in Part 3/5 of this paper, the US has undertaken FONOPs against India’s claim to “Historic Waters” in the Gulf of Mannar on three occasions so far in 1993³⁷, 1994³⁸ and 1999³⁹. In contrast, the US has conducted FONOP against Sri Lanka for the same reason only once in 1999.⁴⁰ In reality, the US contestation and operational assertion against India and Sri Lanka have little practical relevance since the Palk Straits and adjoining waters between India and Sri Lanka are not navigable by deep-draft vessels.

Through a supplementary agreement of November 1976,⁴¹ India-Sri Lanka boundary in Gulf of Mannar was later extended to the tri-junction point (Point T), which was the meeting point of their common boundary with that of Maldives. Before the November 1976 India-Sri Lanka agreement, however, in July 1976, the two countries had entered into a trilateral agreement with Maldives to determine Point T, which is equidistant from the coasts of the three maritime neighbours.⁴² A later India-Maldives agreement of December 1976, besides legally endorsing Point T on a bilateral basis, delimited the IMBL between the two countries by stipulating a set of 19 geographical points.⁴³

IMBLAgreements with Indonesia, Thailand and Myanmar

Shortly after its first agreement with Sri Lanka, India signed its second agreement with Indonesia in August 1974, but which entailed the delimitation of a larger swath of maritime space between India’s Great Nicobar Island and Indonesia’s Sumatra Island. However, the UNCLOS was still being negotiated at that time. Hence, this agreement delimited the continental shelf (rather than EEZ) between India and Indonesia, based on Article 6 of 1958 Geneva Convention on Continental Shelf.⁴⁴ So the basis of the agreement was “median line” (equidistance) principle, rather than the ‘equitable’ principle of EEZ.

The domestic legality of this agreement in India was enabled by the interpretation of the (default) provision of MZI Act 1976, whose Section 9(1) states that:

“The maritime boundaries between India and any State whose coast is opposite or adjacent to that of India… shall be as determined by agreement… (and) shall not extend beyond the line every point of which is equidistant from the nearest point from which the breadth of the territorial waters of India and of such State are measured.”⁴⁵

The India-Indonesia continental shelf boundary was thus initially defined by a set of four geographical points (Points 1 through 4, See Fig. 3 below).⁴⁶ In January 1977, the two countries signed another agreement to extend the four points to delimit the IMBL in the remaining part of Andaman Sea and Indian Ocean. Whereas Point 1 was connected to Points K, N and O in the Andaman Sea, point 4 was connected to Points R, S, T and U in the Indian Ocean.⁴⁷ Notably however, the southern-most Point U lies 183 Nm from the coast of Great Nicobar Island (India) and Sumatra Island (Indonesia). Hence, this delimitation falls short of the complete 200 NM EEZ by 17 Nm.

Like the 1974 agreement, this agreement was also based on delimitation of the continental shelf, which only allocated sovereign rights over seabed areas to the two countries, rather than over natural resources (such as fish) in the water columns above these areas.

Fig 3: India-Indonesia IMBL Agreements

 Source: Vivekananda International Foundation (VIF)

In June 1978, India delimited its IMBL with Thailand (based on Points 1 through 7, See Fig 4).⁴⁸ Concurrently, India entered into a trilateral agreement with Indonesia and Thailand to extend Point O of India-Indonesia IMBL and Point 1 of India-Thailand IMBL to the trijunction point (Point T).⁴⁹

India-Thailand IMBL agreement was also based on median-line division of the continental shelf, rather than the EEZ. This has not raked up any bilateral contention with Bangkok. However, this is not the case with Indonesia. From Jakarta’s perspective, the existing India-Indonesia IMBL based on equal division of continental shelf is not equitable, due to two reasons: First, Indonesia’s archipelagic status under UNCLOS bestows could expand its maritime zones. Secondly, since Sumatra Island is more densely populated than the Nicobar Islands, Indonesia rightfully deserves a larger proportion of the living marine resources, and thus a larger EEZ.

Fig 4: Extension of India-Indonesia IMBL to Thailand

Source: Office of the Geographer, US Department of State

For a fresh India-Indonesia IMBL delimitation, technical deliberations are currently underway and are being accorded high priority by both sides.⁵⁰ New Delhi has been seeking to impress upon Jakarta to adjust the existing median-line IMBL for equity (along with extending it to address the entire 200 NM beyond Point U). However, Jakarta is keen to re-negotiate a separate EEZ boundary with India.⁵¹ According to academic literature, at some stages of the Continental Shelf negotiations in the 1970s, India and Indonesia had agreed to use the existing boundary line (seabed boundary) for their EEZ boundary delimitation in the future, but this is not explicitly mentioned in any of their existing IMBL agreements.⁵²

More than eight years after its IMBL agreement with Thailand, in December 1986, India signed an agreement with Burma (now Myanmar) to delimit their EEZ in Andaman Sea, Coco Channel and Bay of Bengal.⁵³ (See Fig 5). The IMBL was delimited based on the equitable principle of UNCLOS, even though the Convention came into force much later in 1994. The IMBL so established was based on a set of 16 geographical points. Points 1 through 13 delimits their common boundary in the Coco Channel and the Andaman Sea, whereas Points 14 through 16 do so in the Bay of Bengal. Myanmar’s IMBL agreement with Thailand signed in July 1980⁵⁴ made Point 1 (of India-Myanmar agreement) coincident with the trijunction Point T of the India-Myanmar-Thailand IMBL, which was formalised through a trilateral agreement with Myanmar and Thailand signed in October 1993⁵⁵ Concurrently, another agreement was signed separately with Thailand in October 1993 to extend Point 7 of India-Thailand IMBL (See fig. 4) to Point T.

Fig 5: India-Myanmar IMBL Agreement Source: Sovereign Limits

India-Bangladesh Maritime Dispute Resolution

The long-standing maritime dispute between India and Bangladesh in the Bay of Bengal was resolved through international arbitration in July 2014 in accordance with the dispute resolution mechanism of UNCLOS. The dispute began in 1974 and mainly concerned the excessive claims of Bangladesh to address its disadvantaged geography. More specifically, whereas Bangladesh drew straight baseline across its deltaic coast as provided by UNCLOS Art 7(2), its chosen base-line points were far-flung off shore low-tide elevations (LTE), located as far away as 50 NM from the low-water line of Bangladesh coast. India objected to this as not in accordance with UNCLOS. (See Fig 6).

Fig 6: Approximate Maritime Claims of India and Bangladesh before 2014 PCA Judgement (Source: Author)

Dhaka’s EEZ claim line also extended 180 degrees South along the meridian drawn from its Western-most baseline point, whereas India insisted on a median line. Earlier, Myanmar had a l so insisted upon a median line in its dispute with Bangladesh., before it was resolved by the International Tribunal on the Law of the Sea (ITLOS) in 2012. However, since Bangladesh’s coastline is highly concave, if Dhaka accepted the median-line principle, it would get virtually land-locked with an EEZ less than the complete stretch of 200 NM. Therefore, even in its case against Yangon, Dhaka had earlier insisted on claim based on a 180-degree meridian from its Eastern-most baseline-point (See Fig 6). However, later at ITLOS, Dhaka moderated its claim to a South-westerly (215 degree) line. The dispute was resolved in March 2012 through a formal adjudication by the ITLOS under Annex VI of UNCLOS. The ITLOS based its judgment on equidistance/ relevant circumstances method, but made an adjustment to a provisional equidistance line to provide Bangladesh sufficient maritime space beyond the 200 nm EEZ limit; thereby ensuring greater equitability. The Bangladesh-Myanmar IMBL was thus established approximately midway between the competing claims of the two countries.

To resolve its dispute with India, in October 2009, Bangladesh initiated arbitration proceedings at the Permanent Court of Arbitration (PCA) at The Hague (Netherlands) under Annex VII of UNCLOS, seeking maritime delimitation based on the equitable principle. Since every case is unique , UNCLOS stipulates only broad guidelines for reaching an equitable solution, with start-point being the median-line principle. Essentially, this was now the task of the PCA. The hearings concluded in 2013, after which, the PCA delivered its judgement in July 2014. The verdict awarded Bangladesh 19,467 sq. km of the disputed 25,602 sq. km area, with the orientation of its IMBL closely aligned to the Southward meridian, as originally claimed by Dhaka (See Fig 7).⁵⁶ However, the PCA award did oblige Dhaka to modify its excessive straight baseline points to conform to the UNCLOS.

India-Pakistan IMBL Delimitation

The India-Pakistan maritime boundary dispute in the northern Arabian Sea has been an old one, and hostage to the more pressing territorial and other disputes, as well as to the complex nature of adversarial bilateral relations. It is linked to the delineation of land boundary between India and Pakistan along the 96 km- long marshy Sir Creek that separates Rann of Kutch (India) and Sindh (Pakistan). Claiming that the entire Creek lies in its territory, Pakistan claims the ‘green line’ (joining the blue and purple lines that establish the land boundary) lying on the eastern bank of the Creek represents the boundary along the Creek. These coloured lines were promulgated by  the erstwhile British Government of Bombay (that brokered the 1913 agreement between the Kutch and Sind provinces of undivided India) and depicted it on Map No. B-44 published in 1914 (See Fig 8).

Fig 8: British Map No. B-44 (1914) depicting Sir Creek and adjoining areas.

(Source: F Khan 1965)

Pakistan extended the ‘green line’ in the south-eastern direction to meet its southern-most baseline Point K. It claims that this Point (K) is the land-terminus of the India-Pak IMBL (See Fig 9).

Notably, since 1914, several natural geomorphological changes have occurred in the area in terms of the orientation of Sir Creek and the widening of its mouth. The land mass that separated Pir Sanai Creek from Sir Creek – marked on old maps – has now disappeared. As a result, the mouths of the two creeks have nearly merged, which has allowed Pakistan to extend its claim line further south-east. However, the India-Pakistan joint survey conducted in 2007 revealed that Point K cannot legally be used as a baseline point since it does not lie on land and is not even a low-tide elevation (LTE).

Furthermore, contrary to Pakistan’s “green-line” claim, India asserts that in line with the internationally accepted Thalweg Principle, the mid-channel line of Sir Creek (red-coloured line in Fig 9) should be the international boundary between the two States. Accordingly, Point 1 (India’s northern-most baseline point) should be the land terminus of the India-Pakistan IMBL. However, as per Pakistan ’ scounter claim , Thalweg Principle applies only to navigable channels, whereas the Sir Creek is not navigable. But India asserts that Sir Creek is used for transit by fishing vessels during high tide and is thus navigable . T h e results of the 2007 India-Pakistan joint survey reinforce this claim. However, Pakistan argues that the joint survey was meant only to check the orientation of the creek, rather than the navigability of the channel.

Fig 9: Divergent India-Pakistan Claims on IMBL Land Terminus

Source: ilearncana/ Author

The disparate interpretation of the land terminus has led to sizable disputed maritime area. This has led to frequent harassment and arrests of the fishermen of both countries by the maritime security forces of the other side.

Conclusion

In order to pursue its resource-related economic activities in its maritime zones, it was important for India to delineate its maritime baselines and delimit its maritime boundaries with its maritime neighbours. A clear determination of Indian maritime zones based on legally tenable principles enables India to harness sea-based living and non-living resources sans geopolitical and security impediments. The enhanced economic activities in the benign maritime environment enhance opportunities for seafaring jobs, such as on offshore oil and gas platforms, onboard Offshore Supply Vessels (OSV), and deep-sea fishing vessels/ industry. A clarity of maritime jurisdiction is also closely related to India’s maritime governance and Blue Economy endeavours and contributes to the safety of people engaged in activities at sea, including through enhanced Maritime Domain Awareness (MDA). On the other hand, lingering maritime disputes also lead to an insecure seafaring environment and impinge upon safety of Indian citizens, particularly fishermen; thereby adversely affecting the economic growth of the nation.

The geopolitical rationale is not insignificant. India needs to convey to the Indo-Pacific countries, and to the broader international community that it is a benign major power of consequence in the emerging multi-polar world. This is being done rather skilfully by India by showcasing its rich civilisational ethos through the enunciation of concepts like Vasudhaiva Kutumbakam (the world is one family),⁵⁷ the policy of SAGAR (Security And Growth for All in the Region)⁵⁸ and the revised policy of MAHASAGAR (Mutual And Holistic Advancement for Security and Growth Across Regions).⁵⁹ These inclusive Indian concepts and policies are tailored to challenge China’s exclusive and extractive geopolitical ventures, such as the Belt and Road Initiative (BRI). However, India needs to supplement these concepts and policies with demonstrated intent of adherence to a rules-based maritime order based on international law. In this context, New Delhi did well to gracefully accept the adverse verdict by the Permanent Court of Arbitration (PCA) in its maritime dispute with Bangladesh,⁶⁰ and thus opening fresh avenues for India-Bangladesh maritime cooperation in the Bay of Bengal. India’s policy approach stands in stark contrast to China’s rejection of the PCA verdict in 2016 in its legal case against the Philippines in the South China Sea dispute.⁶¹

As examined in the preceding parts of this five-part series, India is also on its way to align its national laws and policies with international law. This is amply reflected in India’s adherence to customary laws, its ratification of international conventions to counter maritime crimes like drug-trafficking and human smuggling and incorporating the treaties into national law. Of utmost significance is the enactment of India’s Maritime Anti-Piracy Act in 2022 that not only draws from UNCLOS, but also conforms strictly to the Convention, even though this new Act is not strictly aligned with India’s own Maritime Zones of India (MZI) Act, 1976 in terms of the latter’s implicit security jurisdiction in India’s EEZ. In any case, the revision of the archaic Act of 1976 is long overdue. While revising the Act, India could consider emulating the UNCLOS on the use of conformal terminology. Also, owing to the impracticality of enforcing its requirement of ‘prior notice’ for innocent passage of foreign warships through its territorial sea, especially against major naval powers, this provision in MZI Act 1976 offers no utility to India and may be removed. For the same reason, India could withdraw its 1995 declaration that it stipulates that foreign States must seek prior ‘consent’ from India to conduct ‘military exercises or manoeuvres’ in its EEZ and on its continental shelf. India’s revised interpretation of UNCLOS will also facilitate its own naval access and mobility across the global maritime common, including in the EEZ of other coastal States, if required, in accordance with international law. It will also indicate that India contributes to the Mare Liberum, and will demonstrate its emergence as a more self-assured maritime power.

Endnotes

1. Whereas the phrase ‘International Law of the Sea’ (singular noun) is used to refer to the United Nations Convention on the Law of the Sea, 1982 (UNCLOS), “International Laws of the Sea” (plural noun) is used in the paper to refer not only to UNCLOS, but also to the other treaty-based Conventions relating to maritime affairs.

2. J. Ashley Roach, “The Maritime Claims Reference Manual and the Law of Baselines,” The Law of Military Operations, International Law Studies, vol. 72 (Newport, RI: U.S. Naval War College, February 1998), 181–196. https://digital-commons.usnwc.edu/cgi/viewcontent.cgi? article=1462&context=ils Russia still claims Peter-the-Great Bay as a "historic bay" since July 20, 1957.

3. United Nations, Convention on the Territorial Sea and the Contiguous Zone, 1958, art. 7, https://www.gc. noaa.gov/ documents/8_1_1958_territorial_sea.pdf.

4. United States Department of State, Limits in the Seas No. 112: United States Responses to Excessive National Maritime Claims, March 09, 1992, 19–20, https://www.state.gov/wp-content/uploads/2019/12/LIS-112.pdf and United States Navy, Annotated Supplement to Commander’s Handbook on the Law of Naval Operations (NWP 1-14M) (Newport, November 1997), 1–12. https://www.fichl.org/fileadmin/_migrated/content_uploads/US_Navy_ Commander_s_Handbook_Annotated_Supplement_1997.pdf.

5. United States Department of Defense, DoD Instruction C-2005.1: U.S. Program for the Exercise of Navigation and Overflight Rights at Sea ( U) , June 21 , 1983 . https://www.jag.navy.mil/national-secu rity/mcrm/.

6. United Nations, United Nations Convention on the Law of the Sea, art. 16(2), December 10, 1982.

7. United Nations, United Nations Convention on the Law of the Sea, art. 7, December 10, 1982.

8. United Nations, United Nations Convention on the Law of the Sea, art. 5, December 10, 1982.

9. India, The Territorial Waters, Continental Shelf, Exclusive Economic Zone and Other Maritime Zones Act, 1976, Act No. 80 of May 28, 1976, sec. 10. https://www.indiacode.nic.in/ bitstream/123456789/14 84/2/A1976-80.pdf

10. India, Gazette of India, Notification No. 736, May 11, 2009; Notification No. 1914, November 20, 2009.

11. Government of India, Note Verbale No. NY/PM/443/1/2009, August 13, 2009.

12. United Nations, Secretary-General, Letter No. M.Z.N. 76.2010.LOS, February 17, 2010, https://www.un.org/Depts/los/LEGISLATIONANDTREATIES/PDFFILES/mzn_s/mzn76ef.pdf.

13. United Nations, Division for Ocean Affairs and the Law of the Sea, Law of the Sea Bulletin No. 71 (New York, 2010), https://www.un.org/Depts/los/doalos_publications/LOSBulletins/ bulletinpdf/bulletin71e.pdf and United Nations, Division for Ocean Affairs and the Law of the Sea, Law of the Sea Bulletin No. 72 (New York, 2010), https://www.un.org/Depts/los/ doalos_publications/LOSBulletins/bulletinpdf/bulletin72e.pdf.

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