reaffirmed its claim of sovereignty over the Zhongsha Islands in its 1992 Law on the territorial Sea and the Contiguous Zone. China claims all the islands, reefs, and shoals within a U-shaped line in the South China Sea drawn in 1947 as its territory. Scarborough shoal lies within this area.[29]

China further asserted its claim shortly after the departure of the US Navy force from Subic, Zambales, Philippines. In the late 1970s, many scientific expedition activities organized by State Bureau of Surveying, National Earthquake Bureau and National Bureau of Oceanography were held in the shoal and around this area. In 1980, a stone marker reading "South China Sea Scientific Expedition" was installed on the South Rock, but was removed by Philippines in 1997.[11]

Claim by the Philippines

The Philippines state thatits assertion of sovereignty over the shoal is based on the juridical criteria established by public international law on the lawful methods for the acquisition of sovereignty. Among the criteria (effective occupation, cession, prescription, conquest, and accretion), the Philippine Department of Foreign Affairs (DFA) has asserted that the country exercised both effective occupation and effective jurisdiction over the shoal, which it terms Bajo de Masinloc, since its independence. Thus, it claims to have erected flags in some islands and a lighthouse which it reported to the International Maritime Organization. It also asserts that the Philippine and US Naval Forces have used it as impact range and that its Department of Environment and Natural Resources has conducted scientific, topographic and marine studies in the shoal, while Filipino fishermen regularly