ABSTRACT
The International Law Commission (ILC) was created by the United Nation to fulfil the General Assembly's mandate of "encouraging the progressive development of international law and its codification". Additionally, intention was one of their justifications for undertaking the codification of unilateral acts. The ILC's Working Group on this topic noted that states often acted unilaterally and that the importance of these acts was increasing. The debate among Members of the ILC over Rodriguez Cedeño's proposed definition illustrated an ongoing problem with intention-based obligations such as unilateral acts. Once the ILC decided that legalization of this area should proceed by adopting the criteria in the Nuclear Tests Cases, it had to determine how a state could manifest its intention. The ILC's inability to identify intention carried into the next year's ILC meetings. Autonomy, as the Nuclear Tests Cases required, meant that unilateral acts did not need any "quid pro quo" on the part of another state.
