3.4 Teachings of most qualified publicists
Article 38(1)(d) of the Statute of the ICJ states that the ICJ will also apply 'the judicial decisions and the teachings of the most highly qualified publicists of the various nations, as subsidiary means for the determination of rules of law'. This provision and the preceding Article (1)(c) are of less importance than the first two sources of law in Article 38. However, eminent scholars and distinguished authorities in international law continue to have some influence conceptually. Arbitration tribunals and other bodies engaged in resolving disputes may cite authors in the deliberations. Distinguished writings thereby contribute as a source of international law.