United Nations Security Council reform continues to be a hotly contested issue for the modern United Nations. However, fractures in reform ideas and geopolitical barriers mean that substantive reform appears unlikely in the current climate. Accordingly, this note returns to the question of whether the International Court of Justice could have jurisdiction to review the validity of Security Council resolutions, a question raised (yet ultimately left unresolved) in Questions of Interpretation and Application of the 1971 Montreal Convention Arising from the Aerial Incident at Lockerbie. This note argues a lacuna exists in Article 36(1) of the Statute of the International Court of Justice (Statute), which contains the jurisdiction of the Court, but that this lacuna could be filled through the utilisation of a general principle of judicial review under Article 38(1)(c) of the Statute. This, in turn, would facilitate judicial review of Security Council resolutions in limited circumstances. This note then proposes a model that could be adopted in such situations to allow the International Court of Justice to apply this general principle of judicial review in a way that does not undermine the functionality of the United Nations system.