In 1998, the Scottish Court in the Netherlands was established by the High Court of Justiciary (Proceedings in the Netherlands) (United Nations) Order 1998[2] which enacted the provisions of a treaty between the Government of the United Kingdom and Government of the Kingdom of the Netherlands.[3] This enabled the High Court of Justiciary to sit in a bench trial of Abdelbaset al-Megrahi and Lamin Khalifah Fhimah for the bombing of Pan Am Flight 103, at Camp Zeist in the Netherlands.[4]