In investment arbitration, the jurisdictional clause limits the authority of the tribunal. Depending upon the wording in question, it can restrain the tribunal’s authority to adjudicate disputes arising from the violation of a particular substantial provision (normally an expropriation clause) or more generally “concerning” an international investment, even if the arbitral practice has not demonstrated a tendency to read such provisions broadly. A well-known example of this is offered by the Biloune case, in which investment arbitrators declared that they lacked jurisdiction to analyze human rights violations “as an independent cause of action”. The tribunal explained that notwithstanding the importance of human rights in contemporary international law, it “does not follow that this Tribunal is competent to pass upon every type of departure from the minimum standard to which foreign nationals are entitled, or that this Tribunal is authorized to deal with allegations of violations of fundamental human rights”. [13]