"International Investment Law is characterised by the lack of a unified set of rules. The absence of the principle of stare decisis means that arbitral tribunals are not bound by earlier decisions and as such, not obliged to interpret treaty provisions in the same manner as their counterparts, which gives rise to uncertainty both, from the point of view of an investor in respect of making investments, as well as from the regulatory perspective of States."

This article attempts to examine the benefits of the EU's proposal of a Multilateral Investment Court for the resolution of Investment disputes in the backdrop of the endemic ad hoc model of the current Investor State Dispute Settlement mechanism.

https://www.sevenseasllp.com/post/the-consistent-inconsistency-problem-of-isds-an-eu-perspective-for-reform