The End of a Low Threshold for Granting Provisional Measures with the ‘Zheng He’ Case?

Abstract On 27 July 2024, the International Tribunal for the Law of the Sea declined Luxembourg’s request for provisional measures in the ‘Zheng He’ case. Following two orders of the International Court of Justice, this marked the third consecutive decision in which provisional measures were denied. The question asked in this Note is whether this signals the end of a low threshold for granting provisional measures. Two points of view are possible: either the undertakings given by the respondents are being taken more seriously, or international courts have grown at least somewhat frustrated with the frequent requests for provisional measures.