## Facts

- The Åland Islands are a Swedish-speaking archipelago between Sweden and Finland.
- After Finland’s independence from Russia (1917), many Ålanders sought separation from Finland and union with Sweden to protect language and culture.
- Finland asserted sovereignty over the Islands while indicating willingness to provide autonomy and cultural safeguards.
- Sweden brought the dispute to the Council of the League of Nations, seeking authorization for a plebiscite on whether the Islands should remain under Finnish sovereignty or join Sweden.
- The Council, with Finland’s and Sweden’s assent, asked a three-member International Committee of Jurists for an advisory opinion on (1) whether the dispute was entirely within Finland’s domestic jurisdiction under Article 15(8) of the League Covenant and (2) the state of international obligations demilitarizing the Islands.
- The Committee received submissions from Finland and Sweden and heard representatives of both states and of the Islands’ inhabitants.
- A central background element was an established treaty-based regime demilitarizing the Islands, originating in the post–Crimean War settlement.

## Issues

1. Whether the dispute over the Åland Islands was, under international law and Article 15(8) of the League Covenant, entirely within Finland’s domestic jurisdiction, limiting the Council’s competence.
2. What international legal obligations existed concerning the demilitarization of the Åland Islands and whether those obligations bound Finland as the territorial sovereign after Russia.

## Decision

- The Committee concluded the dispute was not entirely within Finland’s domestic jurisdiction; the Council was not barred from addressing it under Article 15(8).
- The Committee concluded that international obligations requiring demilitarization of the Åland Islands remained in force and bound Finland as successor with respect to the territory.
- The opinion was advisory and provided the legal basis for the Council to proceed with further consideration of the dispute.

## Legal Principles

- The scope of “domestic jurisdiction” is determined by international law; a matter is not exclusively internal where international obligations, other states’ rights, or international peace and security interests are engaged.
- Under Article 15(8), the Council must refrain only when a dispute is wholly and exclusively domestic; the presence of international elements can prevent that classification.
- Self-determination, as invoked in the post–World War I context, did not operate as a general rule of positive international law granting minorities a unilateral legal right to secede.
- Minority protection concerns may contribute to internationalizing a dispute, even where sovereignty over the territory is not legally in doubt.
- Localized treaty obligations linked to a specific territory—such as demilitarization arrangements serving broader security interests—may continue despite a change in sovereignty and bind the successor state.

## Conclusion

The advisory opinion determined that the Åland Islands dispute was not wholly within Finland’s domestic jurisdiction and confirmed that demilitarization obligations attached to the territory continued to bind Finland as successor, permitting the League Council to take further action on the dispute.


Report of the Int’l Comm. of Jurists on the Aaland Islands Question, League of Nations O.J. Spec. Supp. No. 3 (1920)