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VIII
standing of this material is, in the view of Saudi Arabia,essential to a just result.
3. Of the four categories of special considerationslisted in Article IV of the Arbitration Agreement, thehistorical rights of the King of Saudi Arabia and hisforefathers and of the other rulers concerned and theirforefathers have been dealt with at length in Chapter IV,while the diplomatic aspect of these rights has been reviewedin Chapter V. The traditional loyalties of the inhabitants,together with their tribal organization and way of life,have been discussed in Chapter III; and the facts relatingto the exercise of jurisdiction have been set out in Chapter IV.The significance of these factors in the light of generalprinciples of law has been analyzed in Chapter VI, whileadditional considerations believed to be relevant havebeen suggested in Chapter VII. It is believed that thefactual materials, the legal principles, and the equitableconsiderations brought out in these chapters fully supportthe position of Saudi Arabia concerning the territories indispute.
4. For these reasons, Saudi Arabia requests the Tribunalto decide, with respect to the questions before it, —
a) That the common frontier between Saudi Arabia and Abu
Dhabi is the line defined by Saudi Arabia on 14 October1949, commencing on the Persian Gulf at a point twokilometers east of Bandar al-Marfa; thence running duesoutheast until it meets Latitude 23° 56' N.; thence dueeast until it meets Longitude 54° E.; thence straight to thepoint of intersection of Latitude 24° 25' N. and Longitude55° 36' E.
b) That sovereignty is possessed by Saudi Arabia over the
whole of the area comprised within a circle whose center
