In the Eritrea/Yemen Arbitration (Second Phase), the Arbitral Tribunal took navigational interests into account in several parts of the delimitation line dividing the territorial seas.
In addition to this, the Arbitral Tribunal, in the Guyana/Suriname case, explicitly regarded navigation as a special circumstance in the delimitation of the territorial seas under Article 15 of the LOSC. The Croatia/Slovenia case provides a unique precedent in that the Arbitral Tribunal created a junction area to secure Slovenia’s interest of navigation.
Apart from these cases, the influence of navigational factors usually remains modest. State practice seems to demonstrate more concern about protection of navigation in agreements delimiting territorial seas than in agreements concerning the continental shelf or single maritime boundaries.