This article discusses the June 1992 Arbitral Award of the Canada-Fran
ce Court of Arbitration established to determine the location of the m
aritime boundary of the French archipelago of St Pierre-Miquelon. The
Decision and the two dissenting opinions are described. The reasoning
of the Decision is then analysed and the conclusions drawn that not on
ly has the Court departed from the use of equitable principles but the
solution reached cannot clearly be said to be equitable.