of any one of the States Parties to the dispute, to the International Court of Justice for decision". Cases founded on compromissary clauses have not been as effective as cases founded on special agreement, since a state may have no interest in having the matter examined by the Court and may refuse to comply with a judgment. Since the 1970s the use of such compromissory clauses has declined. Many modern treaties set out their own dispute-resolution regime, often based on forms of arbitration. In 1987, upon the initiative of Mikhail Gorbachev, all of the permanent members of the Security Council began negotiations for expanding the compulsory jurisdiction of the ICJ. The content of these negotiations is to date unknown, and no agreements were reached. See Richard B. Bilder, "Judicial Procedures Relating to the Use of Force," ch. 28 in Lori Damrosch & David Scheffer, Law and Force in the New International Order (1991). Optional clause declarations Thirdly, Article 36(2) allows states to make declarations accepting the Court's jurisdiction as compulsory ("optional clause declarations"). Not all countries accept the compulsory jurisdiction of the International Court of Justice, ICJ. For example, Australia accepts compulsory ICJ jurisdiction "with reservations" whereas Brazil has not accepted compulsory ICJ jurisdiction, directly. However, Brazil has accepted the compulsory jurisdiction by becoming a Party to the Pact of Bogota. It was, moreover, to a Brazilian delegate, Raul Fernandes, that the concept of the optional compulsory jurisdiction mechanism was owed. First adopted in 1922 for the Permanent Court of International Justice (the predecessor of the International Court of Justice under the League of Nations), this system was readopted in 1945 for the International Court of Justice. "The 'Fernandes clause' has thus had the merit, not only of having represented a historic step forward for international law, but also of constituting today, for 62 States, one of the bases of the Court's jurisdiction", according to its president. Succession from PCIJ Finally, 36(5) provides for jurisdiction on the basis of declarations made under the Permanent Court of International Justice's statute. Article 37 of the ICJ's statute similarly transfers jurisdiction under any compromissory clause in a treaty that gave jurisdiction to the PCIJ. Doctrine of Forum Prorogatum The doctrine of forum prorogatum entails the consent of the respondent state with regards to the ICJ having jurisdiction over the case. Refer to the Corfu Case. Advisory opinions An advisory opinion is a function