On April 29, 2016, an Arbitral Tribunal at the Permanent Court of Arbitration issued [3] its order on provisional measures in Italian Republic v. Republic of India, the arbitration concerning the “Enrica Lexie” incident. According to the press release [4], in 2015, Italy sought international arbitration under the UN Convention on the Law of the Sea (UNCLOS) in regard to an incident where two Italian marines stationed on the Enrica Lexie killed two Indian fishermen approximately 20.5 nautical miles off the coast of India and India exercised jurisdiction over the marines. Italy requested that the Tribunal prescribe provisional measures concerning the ability of the marines to remain in Italy for the duration of the arbitration, which is expected to conclude in 2018. The Tribunal unanimously prescribed that “Italy and India shall cooperate, including in proceedings before the Supreme Court of India, to achieve a relaxation of bail conditions” of the Italian marine who remained in India “so as to give effect to the concept of considerations of humanity.” The effect of the order is that the Italian marine remaining under the authority of the Supreme Court of India may return to Italy during the present arbitration. The Arbitral Tribunal further confirmed Italy’s obligation to return the marine to India in case it finds that India has jurisdiction over him.