BUDHA ISMAIL JAM, et al., Petitioners, v. INTERNATIONAL FINANCE CORPORATION, Respondent

The brief supports petitioners in Jam v. International Finance Corporation, contending that applying a restrictive theory of immunity under the IOIA would enhance the accountability of international organizations and complement existing non-judicial accountability mechanisms without causing a flood of litigation.

• The amici argue that the IOIA is a 'general reference' statute that incorporates subsequent changes in foreign sovereign immunity law, including the Foreign Sovereign Immunities Act (FSIA), which employs a restrictive rather than absolute theory of immunity.
• Existing independent accountability mechanisms (IAMs), such as the IFC's Compliance Advisor Ombudsman (CAO), are often insufficient because they lack the power to enforce judgments or guarantee remedial measures, making judicial access a necessary complement for effective remedy.
• The brief asserts that absolute immunity creates a public perception that international organizations are 'above the law,' which can breed mistrust and hinder their missions; conversely, a restrictive theory would improve their reputation and public image.
• There is no empirical evidence to support the claim that a restrictive theory of immunity would lead to a 'floodgate of lawsuits,' noting that the CAO has registered only 178 complaints since its inception and that the IFC itself has described suits against international organizations as 'uncommon.'

APA

Center for International Environmental Law (2018). BUDHA ISMAIL JAM, et al., Petitioners, v. INTERNATIONAL FINANCE CORPORATION, Respondent. https://www.ciel.org/wp-content/uploads/2018/08/2018-07-31-Amicus-Brief-CIEL-et-al-Jam-v-IFC.pdf

Chicago

Center for International Environmental Law. BUDHA ISMAIL JAM, et al., Petitioners, v. INTERNATIONAL FINANCE CORPORATION, Respondent. 2018. https://www.ciel.org/wp-content/uploads/2018/08/2018-07-31-Amicus-Brief-CIEL-et-al-Jam-v-IFC.pdf.

Wikipedia

{{cite report |author=Center for International Environmental Law |title=BUDHA ISMAIL JAM, et al., Petitioners, v. INTERNATIONAL FINANCE CORPORATION, Respondent |date=31 July 2018 |url=https://www.ciel.org/wp-content/uploads/2018/08/2018-07-31-Amicus-Brief-CIEL-et-al-Jam-v-IFC.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centerforinternationalenvironmentallaw2018budha, author = {{Center for International Environmental Law}}, title = {{BUDHA ISMAIL JAM, et al., Petitioners, v. INTERNATIONAL FINANCE CORPORATION, Respondent}}, institution = {Center for International Environmental Law}, year = {2018}, month = jul, url = {https://www.ciel.org/wp-content/uploads/2018/08/2018-07-31-Amicus-Brief-CIEL-et-al-Jam-v-IFC.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }