International investment arbitration is one of the most important mechanisms for resolving disputes between foreign investors and host States. However, the absence of a binding system of precedent has resulted in a lack of consistency and uniformity in arbitral decisions. The purpose of this study is to examine the possibility or impossibility of the formation of jurisprudence in international investment arbitration, with particular emphasis on the arbitral awards issued in the SGS v. Pakistan, SGS v. Philippines, and SGS v. Paraguay cases before the International Centre for Settlement of Investment Disputes (ICSID). This research adopts a descriptive-analytical method and employs a case study approach to analyze how arbitral tribunals interpret obligations arising from bilateral investment treaties, particularly umbrella clauses and the scope of arbitral jurisdiction. The findings indicate that the absence of a judicial hierarchy, the lack of a binding doctrine of precedent, and divergent interpretations of similar treaty provisions are among the primary factors contributing to inconsistent arbitral decisions. At the same time, such divergences do not necessarily represent a structural weakness but may reflect the inherent flexibility of the arbitration system in adapting to the specific context of each treaty.