Until 2003, the umbrella clause received little attention in academic discussion or arbitral practice, although it was often reflected in treaties. Those few authors who drew attention to the clause essentially shared the German, view of the purpose of the clause as a means to elevate violations of investment contracts to level of international law. However, this phase of unanimity came to an end with the arbitral decision in SGS v Pakistan in 2003 which departed fundamentally from the conventional understanding of the clause. Ever since this ruling the purpose, meaning and scope of the clause have caused controversy and given rise to disturbingly divergent lines of jurisprudence.