1. However, he could not agree that terror attacks from occupied territories could be characterized as ?international;I.C.J. at,2004
2. and that recent UN Security Council Resolutions supported that view. He concluded that attacks coming from the West Bank triggered Art. 51, and he faulted the Court for failing to analyze whether the Wall was a necessary and proportionate response to that threat. [Advisory Opinion, 2004 I.C.J. at 241-243 (Separate Opinion of Judge Buergenthal)]. For academic viewpoints challenging the Wall Opinion along similar lines, see Sean D. Murphy, -Self-Defense and the Israeli Wall Advisory Opinion: An Ipse Dixit from the ICJ?;Justice Buergenthal, as well, found that Art. 51 is not limited to state-sponsored ?armed attack,2005
3. The ICJ’s Advisory Jurisdiction and the Crumbling Wall Between the Political and the Judicial