, a permanent investment court or state-state arbitration. 56 India opted to fix its investment treaty practice by means of the Model Bilateral Treaty Template 2015 (India Model BIT ). SADC ’s Annex 1 chose litigation, the European Union (EU) proposes an InvestmentCourtSystem ( ICS ), while
some form of ISDS exists, but only if there is a systemic overhaul to many of the features that are central to how ISDS currently operates. The EU’s proposal for a multilateral court of first instance and appellate review is a key example, and is virtually identical to the investmentcourtsystem
whether the provisions of the
eu -Canada Comprehensive Economic and Trade Agreement (‘
’) regarding the InvestmentCourtSystem (‘ ics ’) are compatible with eu law.
Based on this previous case-law on the principle, it is possible that the cjeu would find that the fra or wa