In the case concerning Maritime Delimitation in the Area between
Greenland and Jan Mayen, the ICJ expressly articulated the approach of dividing the delimitation process into two stages, namely “to begin with the median line as a provisional line and then to ask whether 'special circumstances' require any adjustment or shifting of that line” (Judgment,I.C.J. Reports 1993, p. 38, at p. 61, para. 51). This general approach has proven to be suitable for use in most of the subsequent judicial and arbitral delimitations. As developed in those cases, it has come to be known as the equidistance/relevant circumstances method