7 31 Consent by a SLate Part) is the only condition for the Court to exercise jurisdiction with regard to applications brought by individuals. This consent may be expressed before the filing of an application against the State Party. with the submission of the declaration mentioned in Article 3-1 (6) of the Protocol. It may also be expressed later. either formally through the filing of such a declaration, or infor mally or implicitly through jorum prorogalllm. 14 32. Fonu n prorogalum or "prorogation or comp etence" may be understood as the acceptance of the jurisdiction of an international Cour t by a State after the seizure of this Court by another State or an individual, and this either, expre ssly or tacitly, throu gh decisive acts or an unequivocal behavior. 15 ll was in particular this possi bility that the letters issued by Senegal dated I0 and 17 of February 2009 led the Court to fores ee in this case 33. Up to 9 April 2009, the date on which the Registry recei ved the written observations of Senegal, th!.!re was the possibility that Senegal migh t accept the jurisdiction of the Court. It was onl> on this date that it became unequivocally clear that Senegal had no intention of accepting the Court'sjurisdiction to deal with the appli cation. 34. It was therefore up to the Court to take into account Sene gal's refusal to consent to the jurisdiction of the Court to deal with the application and to draw the consequences thereof by puttJng an end to the matter and removing the case from the general list. 35. Under the former Rules or tht: International Court of Justice (before 0 I July 1978). when a case was brought against a State which has not previously accepted the jurisdiction of the Court by ti1ing the optional declaration and such a Stnle did not accept lhe Court'~ jurisdiction in regard to the case after having been invite d to do so by the Applicant State, such a case was closed by the issuance of u succinct order. 16 In the Europe'an Court of Human Rights where the problem of jurisdiction occur~ less frequ t:ntly than that of admissibility of applications. when there is no serious doubt as to the inadmissibility of an application, the corresponding decision is notified to the applicant throu gh a simp le letter. 17 14 "Nonnully junsdJCllon pn:cc:dcs seizure . [.. Jin somo Cilscs, however. the ~equence moy h~:. ~v~rsed Such as the cs~enc !he lheory of forum prorogatum accordmg 10 which the e of roun rna) huve been properly sei?eJ uf an application who:! reus 1ls JurisdJcuon may nllt hnve existed ol the time the appllcu uon was nteclantl may only have been assumed subsequently bcca~ of tilt! consent orth~ defendant", Prosper Weil. op Cit . p 839 [Translatton by the RegtstryJ n "Forum prorogmum . Laun expresSion usunll) tran:.la ted by the expression "prorogated ;urisdicuon" Accepl lillce by a State of the JUrisdiciJon of an international judiCial body. such us the lntemutionul Col111 of Justice. alter u mauer hus b~c:n referred thereto. either by an e)(press declaration to that effc:tt, or by 11 dectStve acl implymg tncit ucceptnnce. The dectStve acrs may eunsist in effective participation 10 the proceedmgs, either by pleading on the mems, or by making tlndings on the merils or uny other act 1mplying lack of ob;eclion agatns tany future dt:CISJOn on lhe meriLS In the: opinwn of the: lntemauonal Coun of Justice. such conduct can be tantamount to tncll .u:cepumce ol Its junsdictJOn, which cannot subseq uently be revokc:t.l, by virtue of the bonafidtt or estoppel principle. Jcun S:~lmon (l:d ) op c11 , p. 518. On I his doctrine. see Mohammed Bed;aow & Fatsnh Ouguc:rgouz, "Le forum prorogatum devant Ia Cour lnternntlonal de Just1ce /es resourc11.1 d ·une /nstiltlllon ou/a fact! cachee du con.rensual/smtl• in A.frican ~earbook of lmerna/lona/ Law 1998, Vol. V. pp. 91-11 ;I 10 See for example, "Trerumcnl in llungary of Aircraft und Cn:w of the UnneJ States of Amc:ricu". Order or 12 Julv 1954 /.C.J Repor1 !95-1, p 100 or"Ac:nalln~adent of7 October 195.:!", Order or 14 March 1956, /.C.J R<!port 1·956, p 10 . . " l'.:rsonul Jl•ristJJ~;tlun uf Lhc: European t.uun m mutter s ol md1v1tluul cummunicu11ons 1~ mJeed aulomauc; the: Coun mw.l therefore lirsl deol wiJh Ihe 155\Jt: or admtSSJbilll)• or oppliCI ILi01~ lind. in UliS n:specl ArtiCle 53 of I~ Interim Rules, enllllcd ~