Among the criteria ( effective occupation, cession, prescription, conquest, and accretion ), the Philippines said that the country " exercised both effective occupation and effective jurisdiction over Bajo de Masinloc since its independence . " Thus, it claims to have erected flags in some islands and a lighthouse which it reported to the International Maritime Organization.
42.
In 1889, although Britain recognised the rights of the International Association of the Congo to large sections of the Congo basin, which formed the Congo Free State under the personal rule of King Leopold II of Belgium, it did not accept its effective occupation of Katanga, which was known to have copper and was thought might also have gold.
43.
The state government of Sabah ceded Labuan to the Malaysian federal government, and Labuan became a territorial dispute between Indonesia and Malaysia since 1969 over two islands of Ligitan and Sipadan in the Celebes Sea, the International Court of Justice ( ICJ ) made a final decision to award both islands to Malaysia in 2002 based on their " effective occupation ".
44.
Portugal's efforts to establish a corridor of influence between Angola and Mozambique without gaining full political control were hampered by one of the articles in the General Act of the Berlin Conference requiring effective occupation of areas claimed rather than relying on historical claims based on early discovery or more recent claims based largely on exploration, as Portugal wished to use.
45.
The matter was brought for adjudication before the International Court of Justice and, at the end of 2002, the Court awarded the island along with the island of Sipadan to Malaysia, on the basis of the " effective occupation " displayed by the latter's predecessor ( Malaysia's former colonial power, Great Britain ) and the absence of any other superior title.
46.
The disinclination to rule what the Europeans had " conquered " is apparent throughout the protocols of the Berlin Conference, but especially in " The Principle of Effective Occupation . " In line with Germany and Britain's opposing views, the powers finally agreed that this could be established by a European power establishing some kind of base on the coast, from which it was free to expand into the interior.
47.
When he returned on 3 September the Wellington newspapers published a full report of his notes on the nine whaling stations he had visited, but confined reports on his remarks about the Port Cooper country to the statement : We hear he brings highly favourable information of that locality . Yet it was the impression he gained of the Port Cooper district during this cruise, in which he had seen a great deal of the South Island, that confirmed Deans in the decision to settle there a decision that led to the first effective occupation of the Canterbury Plains.
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