Special ITLOS chamber formed for Ghana, Togo boundary dispute
The special chamber will be composed of seven members. Judge Tomas Heidar will serve as President of the chamber. The other members are Judge Neeru Chadha, Judge Ida Caracciolo, Judge Zha Hyoung Rhee and Judge Konrad Jan Marciniak.
A special chamber of the International Tribunal for the Law of the Sea has been formed to hear the maritime boundary dispute between Ghana and Togo in the Gulf of Guinea.
The agreement was reached in Hamburg, Germany, on 3 June 2026, following consultations between representatives of the two countries and the President of the Tribunal. The dispute concerns the delimitation of the maritime boundary between Ghana and Togo.
Under the agreement, Ghana and Togo have consented to transfer the arbitral proceedings instituted by Ghana to a special chamber of ITLOS, pursuant to Article 15, paragraph 2, of the Statute of the Tribunal.
The special chamber will be composed of seven members. Judge Tomas Heidar will serve as President of the chamber. The other members are Judge Neeru Chadha, Judge Ida Caracciolo, Judge Zha Hyoung Rhee and Judge Konrad Jan Marciniak.
The parties have also nominated two judges ad hoc. Ghana has nominated Mr Dapo Akande, while Togo has nominated Mr Makane Moïse Mbengue.
According to the agreed minutes, if any objection to jurisdiction or admissibility is raised before the special chamber, it will be dealt with together with the merits of the case.
The proceedings will be governed by the Statute and Rules of the Tribunal, as well as the agreement reached by the parties. Ghana and Togo have requested that the written proceedings proceed in the following order: a Memorial by Ghana, a Counter-Memorial by Togo, a Reply by Ghana and a Rejoinder by Togo.
Ghana is represented in the proceedings by H.E. Mr Dominic Akuritinga Ayine, Attorney-General and Minister of Justice, as Agent. H.E. Ms Marietta Brew, Legal Counsel to the President, will serve as Co-Agent.
Togo is represented by H.E. Mr Pacôme Yawovi Adjourouvi, Minister of Justice, as Agent, with Mr Stanislas Bamouni Baba, Minister and Secretary General of the Government of Togo, serving as Co-Agent.
The consultations were held on 2 and 3 June 2026 at the premises of the Tribunal in Hamburg. Ghana’s delegation included Mr Fui S. Tsikata, Mr Philippe Sands KC, Mr Remi Reichhold, Mr Nana Poku and Mr Kwame Mfodwo.
Togo’s delegation included Mr Edem Kokou Tengue, Mr Cofie Séna Rodrigue Woussido, Mr Sena Agbayissah, Mr Alexander Marcopoulos and Mr Enguerrand de la Morsanglière.
The formation of the special chamber marks a major procedural step in the resolution of the maritime boundary dispute between the two West African neighbours. The eventual decision is expected to provide legal clarity on the maritime limits of Ghana and Togo in the Gulf of Guinea, a region of strategic economic and maritime importance.
