Awards 829) was a territorial dispute over the Island of Palmas (or Miangas) between the Netherlands and the United States which was heard by the Permanent Court of Arbitration.

In 1898, Spain ceded the Philippines to the United States in the Treaty of Paris (1898) and Palmas is located within the boundaries of that cession.

The visit led to the US statement that the Island of Palmas, undoubtedly included in the "archipelago known as the Philippine Islands," as delimited by Article III of the Treaty of Peace between the United States and Spain, also called "Treaty of Paris," and ceded in virtue of the said article to the United States, was considered by the Netherlands as forming part of the territory of its possessions in the East Indies.

[4] Contesting the principle of contiguity, the Netherlands considered discovery by Spain was not proved, that the same held for any other form of acquisition, and that any such Spanish title would have been lost.

The main argument was that the Netherlands, represented by the East India Company, had possessed and exercised rights of sovereignty from 1677, or possibly from 1648.

Sovereignty arose out of conventions entered into with native princes on Sangi (the main island of the Talautse Isles).

to stabilize the sovereignty of the Netherlands over the territories of the princes, including Palmas (or Miangas) and this had been validated by international treaties.

However, for a sovereign to maintain its initial title via discovery, the arbitrator said that the discoverer had to actually exercise authority even by as simple an act as planting a flag on the beach.

The United States argued that Palmas was American territory because the island was closer to the Philippines than to the Netherlands East Indies.

The arbitrator said that there was no positive international law for the American view of terra firma in which the nearest continent or island of considerable size gives title to the land in dispute.

The arbitrator held that mere proximity was not an adequate claim to land and noted that if the international community followed the proposed American approach, that would lead to arbitrary results.

The decision has also served as a basis for the definition of the inter-temporal rule in international law (tempus regit actum).