United Nations War Crimes Commission
United Nations War Crimes Commission
The United Nations War Crimes Commission (UNWCC) was inaugurated on October 20, 1943, by representatives of the seventeen Allied nations. It was the only international framework that dealt with the issue of war crimes and war criminals during World War II. The commission continued to operate until March 31, 1948, and in the course of its four-and-a-half years of existence had created a total of 8,178 files (representing 36,810 individuals and groups). Significantly, some of the most important notions elaborated by the UNWCC found their way into the Nuremberg Charter.
The idea of establishing a United Nations (UN) "commission on atrocities" was first advanced by British prime minister Winston S. Churchill in June 1942 during his visit to the United States. Churchill was in part responding to intense pressure coming from the exiled Polish and Czech governments in London, who envisioned the threat of reprisals against Germany by the Allied nations as a deterrent against further atrocities by the Nazis. However, both Britain and the United States ascribed low priority to the war crimes problem at the time and wanted to postpone dealing with the issue of punishing war criminals for as long as possible.
On September 7, 1942, John Viscount Simon, the Lord Chancellor and Chair of the British Cabinet Committee on the Treatment of War Criminals (CCTWC) introduced to the House of Lords the British government's proposal to set up a UN Commission for the Investigation of War Crimes. Its task would be "to collect material, supported wherever possible by depositions or by other documents, to establish such crimes, especially where they are systematically perpetrated, and to name and identify those responsible for their perpetration." Simon asserted that the proposal had the support of the United States and of the European allies, though he acknowledged that replies from the Soviet Union, China, the British Dominions, and India were still forthcoming.
The Soviet Union put up the greatest obstacles to the establishment of the UNWCC. Moscow had been piqued by the fact that London had ignored the Soviet Union during the preliminary stages of the establishment of the Commission and had appealed to the Soviet Union for support only at the last moment. In January 1943 Moscow responded in a positive manner, but then prompted further delay by opposing London's intention to include participation by the Dominions in the work of the Commission. On July 27, 1943, Moscow announced that it was prepared to meet British wishes regarding the participation of the Dominions, India, and Burma on the condition that the Federated Republics of the USSR—Ukraine, Belorussia, Moldavia, Lithuania, Latvia, Estonia, and Karelo-Finska—would also be allowed to participate. This move by the Soviet Union was clearly designed to gain political capital: recognition of its annexation of the Baltic States, would set a precedent that would help the Soviet Union claim the right to enlarge its representation in future international organizations. When London declined, Moscow decided not to respond to Britain's invitation to the Allied meeting to establish the UNWCC, scheduled for October 20, 1943.
The meeting was chaired by Viscount Simon, who set out the two principal aims of the Commission: first, to investigate allegations of war crimes and, where possible, to record evidence of the crimes and identify the individuals responsible; and second, to report those cases in which it appeared that adequate evidence of such crimes might be forthcoming to the appropriate governments. A clear distinction was made between investigation, which would be the work of the Commission, and the task of trying war criminals. The latter, Simon told the delegations, would represent a later stage requiring decisions by the relevant governments, not the Commission. Finally, according to Simon, British policy held that the fates of those judged to be major war criminals was a political question that remained to be answered. The participants agreed to locate the UNWCC's headquarters in London, and appointed Mackinon Wood, a British citizen, secretary-general. In part because the Soviets were absent, the appointment of a chairman was left to the Commission's plenum.
British officials did not assign a high priority to the UNWCC, despite the fact that Britain had been the driving force behind its establishment. One reason was fear of acts of revenge by Germans against British prisoners of war. Another was trepidation over the possibility that the Commission, under pressure from the various governments-in-exile in London, might act in ways that were not consonant with British interests. In fact, officials of the British Foreign Office succeeded in limiting the Commission's mandate to investigating war crimes committed against Allied nationals. For them the Commission was largely a means to neutralize the insistent calls for acts of retribution against the Germans that were being made by the governments-inexile, and to create an impression that the war criminals issue was being handled. There had also been foot-dragging in the U.S. State Department. The United States wanted to maintain as low a profile as possible vis-à-vis the punishment of war criminals out of fear for the fates of its own captives in German hands, and until the final months of the war, never delved deeply into this complex question.
Almost as soon as the UNWCC had begun to function, the fears of both the British Foreign Office and the U.S. State Department materialized. Although British and U.S. officials expected the UNWCC to confine itself to the investigation of alleged war crimes and criminals, leading members of the Commission refused to accept this narrow mandate and urged the UNWCC to come up with a comprehensive plan for trying war criminals, and to devise ways and means to track and apprehend individuals charged with war crimes. The chairman of the Commission, Sir Cecil Hurst, and, to an even greater extent, Herbert C. Pell, the U.S. representative, failed to be faithful to the Foreign Office's and State Department's objectives, but prompted the Commission to formulate its own proposals for policy and action. Hurst had served as the Foreign Office's Legal Adviser (1928–1929), and subsequently became a panel judge for the Permanent Court of International Justice (and was its president from 1934 to 1936). Pell, a former U.S. congressman from New York and a friend of U.S. president Franklin D. Roosevelt, had served as U.S. minister to Portugal from May 1937 to 1941 when he was posted to Hungary, where he stayed throughout most of the year.
Many of the UNWCC representatives (who were legal scholars of sterling reputation), agreed that the work of the Commission should not be limited to an examination of dossiers and the compilation of lists of criminals, and decided that the Commission should tackle arguments of a legal nature, as well. The Commission's activities developed along three lines: the investigation of allegations and evidence in relation to war crimes; law enforcement and the punishment of war crimes; and the formulation of legal principles having to do with war crimes and the liability of perpetrators. Accordingly, the Commission appointed three committees.
The Committee on Facts and Evidence (Committee I) was charged with the review of complaints (to be submitted by the various governments), the compilation of lists of alleged war criminals for consideration by the Commission, and the formulation of recommendations with respect to the investigation of war crimes. The Belgian representative, General Marcel de Baer, a lawyer and judge in the city of Antwerp, was elected its chairman.
It was the responsibility of Committee I to determine whether material that had been submitted to the Commission was legally sufficient to establish a case. As the UNWCC possessed no detective or investigative powers, it had to wait until charges were submitted by the various governments, and then had to hope for the best with regard to the accuracy of the information it received, and the diligence and good faith of the providers of this information. A name was entered on a list, not in the aftermath of judicial proceedings, but consequent to the statement of a single party. The person charged was not summoned to answer questions, and evidence was obtained, not from persons under oath, but from written statements. In addition to its designation of persons as "accused," the Commission introduced lists of "suspects," and "witnesses."
The Committee on Means and Methods of Enforcement (Committee II) would recommend to the Commission the methods and policies it should adopt in regard to the apprehension, surrender, detention, investigation, and prosecution of alleged war criminals. The recommendations, if adopted by the Commission's plenum, were then to be transmitted to the member governments for their consideration. The chief efforts of Committee II were to be directed toward the incorporation of clauses providing for the apprehension of war criminals into the anticipated armistice with Germany; the composition of draft conventions that would provide for the establishment of courts to prosecute the war criminals who could not be tried or were not likely to be tried before national courts; and the creation of war crimes offices or agencies in defeated enemy countries that would carry out the identification and arrest of war criminals. Pell was chairman of Committee II.
The Committee on Legal Questions (Committee III), chaired by Professor of Criminal Law Stephan Glaser of Poland, was the advisory board of the Commission. It strove to articulate the more theoretical aspects of the arguments that centered on: the concept of war crimes, the putative criminal nature of aggressive war, collective responsibility, individual responsibility vis-ávis orders by superiors, gaps in national legislation, and the putative criminal nature of specific acts resembling (but technically not classifiable as such) the notion of war crimes. At the same time the committee was called on to make determinations on the criminal nature of alleged criminal acts or the liability of accused persons in cases in which there were multiple sources of ambiguity. The committee's counsel was also sought in regard to what should be, in the context of changing international laws and customs of war, the scope of the retributive actions of the UN.
On November 29, 1944, the UNWCC established a branch in Chungking, China (at the time the provisional capital of China), which it named the Far Eastern Sub-Commission. Its mission was to undertake a study of the alleged criminal acts perpetrated by the Japanese. Wang Chung Hui, Secretary-General of the Supreme National Defense Council of China was elected its first chairman. Until March 1947 (when it was dissolved), the Far Eastern Sub-Commission held thirty-eight meetings—each of them attended by UNWCC representatives from the United States, Britain, China, and the Netherlands. About 90 percent of the allegations of crimes presented to the Sub-Commission came out of the Chinese National Office. In addition, the UNWCC created a small subcommittee of in London, under the chair of Wellington Koo, the Chinese UNWCC representative.
Guidelines for the operation of the UNWCC took shape during its initial meetings. Fears for the safety of persons who participated in any way in the work of the Commission led to a press ban and a ban on the taking of photographs of UNWCC members. It was also agreed that the Commission needed to work in closed sessions; only those Commission proceedings that centered on select matters of special interest would make their way into written communiqués. To encourage members of the Commission to express their views, it was decided that debates that were part of Commission proceedings would not be recorded. The Commission was scheduled to meet every week, but much of its actual work was conducted within the three committees.
Not surprisingly, the Commission was furnished with limited resources and inadequate facilities. Its secretariat consisted of only a secretary-general, a liaison officer, and three clerks. The Commission was given no lawyers, investigators, technical assistants, or other specialists. Except for clerical tasks, all work was performed by the representatives and their deputies. Furthermore, Commission representatives, with the exception of those from the United States and the United Kingdom, held other positions and could devote only part of their time to Commission affairs.
The first question on which the Commission had to determinations was: What is a war crime? No agreed-upon definition existed, nor did there exist a binding list of war crimes. In early December 1943 the UNWCC, instead of compiling an extensive and binding list of war crimes, decided to adopt the list of war crimes that had been prepared by the 1919 Commission on the Responsibility of the Authors of the War and on the Enforcement of Penalties established by the preliminary peace conference of Paris in January 1919. Not only did this measure reduce the risk of being criticized for inventing new war crimes after the acts had been perpetrated, but Italy and Japan had been parties to the preparation of the 1919 document and Germany had never objected to it. Commission members recognized, however, that this list could be neither final nor definitive, and saw it as a starting point and a practical foundation for their work. Accordingly, there was no steadfast definition of the term war crime until the end of the war.
Another point of debate that the Commission failed to reach agreement on until the end of the war was the question of whether a war of aggression amounted to a war crime. There were two competing schools of thought. One school of thought held that acts committed by individuals for the purpose of launching an aggressive war were, strictly speaking, lega lata, not war crimes; the other maintained that international law had developed in such a way as to almost guarantee that aggressive war amounted to a war crime that entailed individual liability. All agreed, however, that the launching and waging of a war of aggression was illegal. Only after the London Conference (June 26, 1945–August 8, 1945), where delegates of the United States, Great Britain, the Soviet Union, and France negotiated the guiding principles for prosecuting war criminals at the insistance of the United States, had incorporated the notion of aggressive war into the Charter of the International Military Tribunal and identified aggressive war as a war crime did the War Crimes Commission include this high crime as being within its purview.
International law did not recognize war crimes as any offenses committed by an enemy nation against its own nationals or those of other enemy countries. The initiative to limit the War Crimes Commission's jurisdiction to investigating crimes committed against nationals of the Allied nations came from the British. According to this notion, German atrocities perpetrated against, for example, Polish citizens were considered war crimes, whereas atrocities perpetrated against Hungarian, Romanian, or, of course, German nationals were not. The latter were deemed to appertain to the domestic policy of sovereign states, and were therefore to be prosecuted by the successor governments of former enemy countries, Germany included. This reasoning would of course have bearing on Hitler's principal victims—European Jews, but also on populations such as the nationals of neutral countries, stateless persons, and non-Jewish nationals of the Axis.
Several UNWCC members, however, objected to such an asymmetrical interpretation of the term war crime, and the ensuing discord developed into a severe crisis of confidence between, on the one hand, the American and British representatives on the Commission and, on the other, their respective foreign ministries. Shortly after the UNWCC began its work, Pell raised the question of crimes perpetrated by Germans against citizens of the Third Reich and insisted on allowing the Commission to investigate such offenses. He wanted all such atrocities committed after January 30, 1933—the day Hitler became Germany's Chancellor—to be classified as war crimes. In addition, he recommended that the term crimes against humanity (which was hardly common at that time) should refer to, among other things, crimes committed against stateless persons or against any persons by reason of their ethnicity or religion.
The members of Committee III, having been appointed to make determinations on the kinds of crimes that would make up the Commission's scope of work, proposed as one category of crime: ". . . crimes committed against any person without regard to nationality, stateless persons included, [as well as crimes committed] because of race, nationality, religious, or political belief, irrespective of where they have been committed." Accordingly, Hurst notified the British government of the Commission's readiness to investigate atrocities that had been committed on racist, political, or religious grounds. Any decision in this regard, however, depended on the concurrence of the British and U.S. governments. As late as mid-November 1944 (after the United States had been consulted), Hurst was notified by officials of the British government that the crimes that Committee III was putting forward were not to be considered war crimes. He was also notified that the Commission could collect evidence with respect to the German campaign of mass murder—though the British government thought that it would be a mistake for the Commission to undertake this additional and heavy burden.
Pell was no more successful with U.S. government officials, who continued to endow the term war crime with a narrow interpretation. But through his repeated appeals (some made directly to Roosevelt), Pell prevented the U.S. administration from pushing the issue asside. The United States reversed its position when it realized that the American public would not accept distinctions made among the victims of Axis nation atrocities according to whether they were Allied or Axis nationals—particularly after the massacre of European Jewry had been publicly revealed. The altered U.S. position led to the incorporation of the notion of crimes against humanity into the Nuremberg Charter of August 8, 1945 (admittedly in its narrow form), and so into international law. When Pell was discharged from the Commission in January 1945, it would take until January 1946 for the Commission to agree that crimes against humanity as described in the London Charter were war crimes within its jurisdiction.
Evidence and Cases
The Commission's prime task was, as stated previously, to investigate allegations of war crimes, and (where possible) to record evidence of the crimes and identify the perpetrators. In December 1943 each of the member governments of the UNWCC was asked to establish its own National War Crimes Office for the purpose of investigating war crimes that had caused detriment to it or its nationals, preparing charges against the alleged war criminals, and transmitting the charges, along with the relevant information and material, to the Commission for examination. The National War Crimes Offices were also encouraged to transmit to other governments information pertaining to war crimes that might be of value to those governments. In other words, the responsibility for field investigations and the preparation and transmission of charges fell to the individual National Offices. The War Crimes Commission had to examine the charges in the presence of representatives of the National Office that had made the allegations. Whenever the Commission then determined that there appeared to be sufficient evidence that a war crime had been committed, it placed the names of the alleged war criminals on its list.
Until the end of the war the number of charges that had been transmitted to the Commission by the National Offices remained small, relative to the enormous number of crimes that had been perpetrated. In an effort to overcome this difficulty, Committee I adopted the practice of listing the names of persons belonging to an entire military unit when it appeared that war crimes had been committed on such a scale that all members of that unit could be presumed to have taken part in them. The Commission also wanted the governments of enemy-occupied countries to submit to the Commission lists of all enemy personnel in authority, military and civilian, in each occupied district since 1939. Moreover, the Commission suggested that all members and former members of the SS and the Gestapo be apprehended and interned. It was anticipated that there would be difficulties with regard to identifying, investigating, and convicting members of these notorious organizations, and the arrest of these persons was meant to assure that they would be available on request. The Commission, in fact, had adopted the view that these organizations were, by definition, criminal, and that membership in them, by itself, was sufficient evidence against to warrant the accused for the purpose of both his being listed by the Commission and put on trial. In this instance also, the Commission made a final decision only after the Americans had incorporated the concept of criminal organizations into their memorandum, "The Trial and Punishment of Nazi War Criminals," which would become the core of the Nuremberg Charter.
The UNWCC completed its first list of German and Italian war criminals in December 1944. It contained 712 names, all of them submitted by European governments. Among those named were forty-nine highranking Nazi officials. In addition to Adolf Hitler, Hermann Göring, Joseph Goebbels, Heinrich Himmler, and Hans Frank, the group of forty-nine consisted of generals, administrators of occupied regions, and political appointees such as Joachim von Ribbentrop, Konstantin von Neurath, Hjalmar Schacht, and Arthur Seyss-Inquart. The Commission was of the opinion that the proper course for bringing these high-ranking war criminals to justice was to try them in a court of law—not to impose penalties by political fiat. Furthermore it rejected as irrelevant the doctrine of the immunity of heads of state or members of government.
An International Court
Still another complex issue, one that had preoccupied the UNWCC from its earliest meetings, centered on the type of court that should be used to try persons accused of war crimes. Although legal proceedings were beyond the Commission's jurisdiction, its members insisted on examining the issue. On February 25, 1944, Committee II, under Pell's chairmanship, began to examine prospects for the creation of an international court. No consensus was reached as to whether such a court would be a body composed exclusively of jurists or some sort of military tribunal. Most Committee members seemed to prefer a combination of the two. For his part, Pell preferred a judicial body that would be composed of jurists, military officers, and lay persons. He wanted the prospective court's trial judges to recognize that a major part of their endeavor would be to make the outbreak of future wars less probable.
The creation of an international court quickly became a focal point of discord between the UNWCC and the British government. The increasing disposition of the Commission members to delve into questions such as the type of court or code of law to be used greatly troubled the British Foreign Office, which objected to the creation of a court or any other judicial machinery. The Foreign Office wanted persons accused of war crimes to be tried by military courts or, in some countries, civil courts that would apply existing laws and principles. Each Allied government was to be entrusted with trying all cases that arose from allegations of offenses that had been committed on its own territory or against its own nationals.
Nevertheless, in September 1944, the Commission approved a final draft of the Convention for the Establishment of a UN Joint Court. It contained twenty-nine Articles, but did not include a detailed list of war crimes. Instead, the court would handle allegations of offenses committed against the laws and customs of war. The Commission wished to endow the Court with the latitude of action to carry out the intentions of the Allied governments—such as they had been expressed in numerous public statements and in general international treaties or conventions pertaining to the laws of war. Although it proposed that the court be given the power to impose the death penalty, the draft convention made sure to protect the rights of defendants.
Yet members of the Commission realized that setting up such a court would be a long process, and that therefore interim courts would be needed. Moreover, Pell, who was aware that both the President and the U.S. State Department of favored military courts, had put much effort into convincing Commission members to support the idea of interim military courts. According to the draft convention, "mixed military tribunals" would have the jurisdiction to try nationals of enemy countries accused of having committed war crimes. The judges were to be nationals of Allied countries, and each tribunal would consist of no less than five members. The rules of procedure were to be consistent with practices that were habitual in the Allied nations and to be framed by the tribunals' appointing authorities. Prosecution was to be left to the relevant nation, and the tribunals would have the power to subpoena persons and documents. Trial in a mixed military tribunal would not bar proceedings before an international tribunal. The Commission regarded both types of courts—an eventual UN Court (to be created by treaty) and mixed military tribunals to be appointed by military commanders—as complementary, not as competitors.
Strongly opposed to the UNWCC proposal of a treaty court, the British government tried to enlist Washington's support in its effort to have the proposal withdrawn, and meanwhile held back its response to the UNWCC. Frustrated, Hurst reached the conclusion that the Foreign Office was once again disregarding Commission proposals. Similarly, Pell was extremely disappointed when he found that neither the President nor Secretary of State of the United States had reacted in a positive way to what he regarded as his major achievement—convincing the Commission to propose the establishment of a military court. When the two governments finally adopted the military tribunal proposal, both Pell and Hurst were no longer the respective American and British representatives to the UNWCC.
Hurst felt he had been put in an impossible position being unable to decipher the views of the British government, and therefore unable to relay them to Commission members. As chairman, he found it increasingly difficult to contend with the repeated complaints within the Commission about the scarcity of attention or guidance coming from London, and he resigned in early January 1945—ostensibly for medical reasons. The British government quickly appointed William Viscount Finlay to replace him, who had been a judge in England since 1924 and during World War II served as Chairman of the Blockade Committee at the Ministry of Economic Warfare. It was calculated that the appointment of this prominent figure was done to dispel accusations of Britain's indifference to the Commission. When Finlay died a few months later, on July 4, 1945, Sir Robert Craigie replaced him.
The British government was extremely fearful that Pell would become UNWCC chairman. In the end, Lord Robert Alderson Wright, a senior British judge who was the Commission's nominal Australian representative, was elected chairman, on January 17, 1945. The British were not alone in opposing Pell. Relations between Pell and the U.S. State Department, tense from the outset, had grown worse. The State Department, motivated in part by animosity toward Pell, had worked to constrain whatever actions he wished to take, to reject most of his initiatives, and to undermine his position in the eyes of the British. State Department officials could not abide Pell's independence of judgment and action. Perhaps the best explanation for the clash between Pell and the U.S. government lay in the U.S. government's lack of an established policy or even principles vis-à-vis the treatment of suspected war criminals, and in the State Department's predilection for postponing decisions on the issue. Pell, who regarded himself as a statesman and not a bureaucrat, had believed (erroneously) that he could influence overall U.S. policy toward Germany. His limited legal knowledge had naturally prompted him to focus on policy matters. When, shortly after his appointment, Pell realized that the State Department did not regard the question of the treatment of suspected war criminals as a serious matter and that no one in the State Department actually cared much about the UNWCC, he decided that he had better act on his own initiative to further the development of a policy toward war criminals. Taking advantage of the fact that he had been Roosevelt's appointee, Pell did not hesitate to bypass the State Department and attempt to enlist Roosevelt's support for his proposals directly. Inevitably, the poor relations between the State Department and Pell influenced the State Department's overall attitude toward the UNWCC. In the end, the State Department maneuvered to have Pell replaced (as the Commission's U.S. representative) by his deputy, Colonel Joseph V. Hodgson.
With the conclusion of the war, Wright was determined to prevent the Commission from being pushed to the sidelines. He even sought to have the scope of the Commission's mandate expanded and to have the Commission play an active part in the gathering of evidence on war crimes. However, when he proposed to set up a War Crimes Investigation Team at the Supreme Headquarters of the Allied Expeditionary Force (SHAEF, the command headquarters of the commander of Allied forces in Europe), the British government ruled out the possibility because of its longstanding low appreciation of the UNWCC and its interest in transferring responsibility for dealing with war criminals to the individual countries. Wright had more success in furthering the goals of the Commission when he convened a conference of representatives of the various National War Crimes Offices, which took place in London on May 31, 1945. At the conference he spoke about the importance that the UNWCC had ascribed to the work of the National War Crimes Offices, and explained that the Commission's primary function had been to act as a sort of central clearing house for the written statements in which war crimes were alleged. The Commission had promulgated its conviction that justice and not revenge should be the aim of those working to prosecute alleged war criminals. With this in mind, Wright wanted the Commission to act as a central advisory bureau and liaison that could coordinate the activities of the National War Crimes Offices and military authorities in Germany and Austria.
The Commission's wish to cooperate with military authorities was partially fulfilled when the Allied theater commanders in Germany and Austria were authorized to accept lists of war criminals directly from the Commission, and to apprehend and detain those listed in the absence of further proof of their having committed war crimes. An officer of SHAEF, furthermore, had been attending the Commission's meetings regularly, starting in May 1945. Wright also succeeded in coming to an agreement with U.S. Supreme Court Justice Robert J. Jackson, who had been appointed Chief of Counsel for the Prosecution of Axis Criminality by president Harry S. Truman on May 2. Jackson regarded the Commission as a supporting body, and expected it to provide him with evidence that would help him to acquire an overview of the war crimes that had been perpetrated by the highest-ranking Axis authorities. Following Jackson's appointment, there were close contacts between the Commission and the staffs of the Chief Prosecutors of the United States, Great Britain, and France, prior to and during the trial of the major war criminals at Nuremberg—as well as between the Commission and the attorneys preparing the subsequent proceedings. The UNWCC furnished the prosecution with first-hand information and evidence of crimes committed in the occupied countries.
In the final analysis, despite the obstacles put up mainly by the British Foreign Office and U.S. State Department, the UNWCC was successful in its undertaking to formulate a policy on the handling of war criminals, and had prompted individual governments to grapple with the question of which policies they would adopt. The most important of the UNWCC proposals that made their way into the U.S. ground plan for punishing war criminals and, thereafter, into the Charter of the International Military Tribunal, were the concepts of aggressive war, criminal organizations, mixed military courts, and crimes committed by an enemy against its own nationals. Summing up the importance of the Commission's activities for the year 1944 and the beginning of 1945, Wright would declare, in the official history of the UNWCC, that "[T]he United Nations had ready to their hands when the time came, a more or less practical scheme for the prosecution and punishment of war criminals, which was capable of being completed and put into effect when the Nazi resistance collapsed." The UNWCC ultimately presented 80 lists that contained the names of 36,529 suspected war criminals (of whom 34,270, were German and 1,286 Italian).
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"United Nations War Crimes Commission." Encyclopedia of Genocide and Crimes Against Humanity. . Encyclopedia.com. (November 19, 2018). https://www.encyclopedia.com/international/encyclopedias-almanacs-transcripts-and-maps/united-nations-war-crimes-commission
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