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The Sociedad Cooperativa de Producción Pesquera Puerto Chale S.C.L. and the Center for International Environmental Law (CIEL) submitted an amicus curiae application to the ICSID Tribunal in the case of Odyssey Marine Exploration, Inc. v. United Mexican States. The amici argue that the Mexican State was justified in denying an environmental permit for the Don Diego seabed mining project in the Gulf of Ulloa, as the project would violate international environmental and human rights laws, specifically the precautionary principle and the rights to work, health, and a healthy environment.

This document contains the Appellants' Heads of Argument filed by the Centre for Environmental Rights on behalf of the Endangered Wildlife Trust and the Federation for a Sustainable Environment. The appeal, brought under section 149 of the National Water Act (NWA), challenges a Water Tribunal decision that dismissed an appeal against the granting of a water use licence (WUL) to Atha-Africa Ventures (Pty) Ltd for the proposed Yzermyn Underground Coal Mine. The appellants argue that the Water Tribunal erred on several questions of law, including the failure to consider the strategic importance of the mine area, the absence of landowner consent, the misapplication of the precautionary principle, the lack of post-closure water treatment provisions, and the misapprehension of the burden of proof regarding socio-economic impacts.