Rights; encroaching the right to life. Water is included in this right, as part of access to land. The courts required the lands to be returned, compensation provided, and basic goods and services to be implemented, while the community was in the process of having their lands returned. International Centre for Settlement of Investment Disputes The following cases from the International Centre for Settlement of Investment Disputes (ICSID) concern the contracts established between governments and corporations for the maintenance of waterways. Although the cases regard questions of investment, commentators have noted that the indirect impact of the right to water upon the verdicts is significant. World Bank data shows that water privatization spiked starting in the 1990s and significant growth in privatization continued into the 2000s. Azurix Corp v. Argentina The first notable case regarding the right to water in the ICSID is that of Azurix Corp v. Argentina. The dispute was between the Argentine Republic and Azurix Corporation regarding discrepancies arising from a 30-year contract between the parties to operate the water supply of various provinces. A consideration in regard to the right to water is implicitly made during the arbitration for compensation, where it was held that Azurix was entitled to a fair return on the market value of the investment. This was rather than the requested US$438.6 million, citing that a reasonable business person could not expect such a return, given the limits of water price increases and improvements that would be required to ensure a well-functioning, clean water system. Biwater Gauff Ltd v. Tanzania Secondly, a similar case encountered by the ICSID is that of Biwater Gauff Ltd v. Tanzania. This was again a case of a private water company in a contractual dispute with a government, this time the United Republic of Tanzania. This contract was for the operation and management of the Dar es Salaam water system. In May 2005, the Tanzania government ended the contract with Biwater Gauff for its alleged failure to meet performance guarantees. In July 2008, the Tribunal issued its decision on the case, declaring that the Tanzania government had violated the agreement with Biwater Gauff. It did not however award monetary damages to Biwater, acknowledging that public interest concerns were paramount in the dispute. Right to water in domestic law Without the existence of an international body that can enforce it, the human right to water relies upon the