LITUANUS LITHUANIAN QUARTERLY JOURNAL OF ARTS AND SCIENCES   Volume 34, No. 2 - Summer 1989 Editor of this issue: Antanas Dundzila ISSN 0024-5089 Copyright © 1989 LITUANUS Foundation, Inc.

THE MOLOTOV-RIBBENTROP PACT OF 1939:
LEGAL AND POLITICAL CONSEQUENCES

DR. DOMAS KRIVICKAS*

Preliminaries to the Pact

The European balance of power established at the end of World War I came to an end with the Munich settlement of 1938. The settlement had great repercussions to all European countries, including Lithuania. The dissolution of Czechoslovakia was only the beginning of a new political development. Nobody in Europe was secure. Europe was divided into three camps: the Axis powers, the Soviet Union, and France with Britain and their allies, mostly in the process of disintegration after the Munich settlement. Given the circumstances, peace or war depended upon the Soviet Union. It, aware of this situation, had the upper hand.

Lithuania immediately came into the political plans of the two great Powers, since it was located between the rival parties. The incorporation of Klaipėda region into the German Reich, which followed the occupation of Prague, was preceded by the direct threat to the Lithuanian independence by Germany. The German Foreign Minister declared to the Foreign Minister of Lithuania that if Lithuania would resist the incorporation of Klaipėda into German Reich and, if there were any spilling of German blood, "the matter would have to be handed over to the German military authorities, in which case the matter might not eventually stop at the Memel (Klaipėda) territorial frontier."1

The German menace provoked concern not only in neighboring Poland, but also in Great Britain. Lord Halifax stated in his instruction to Sir Kennard (Warsaw) on March 21, 1939: "If Lithuanian independence were placed in jeopardy, this was a matter which would affect all of us."2 Consequently a joint declaration was issued after the British-Polish negotiations of April 4-6, 1939. Britain and Poland pledged for their mutual assistance in the event of any threat, direct or indirect, to the independence of the other countries. An indirect threat implicitly meant a threat to Lithuanian independence. This pledge was expressly established in the secret protocol attached to the Anglo-Polish Mutual Assistance pact signed on August 25, 1939. Aggression against Holland, Belgium and Lithuania was considered a "clear menace to the security" of the contracting parties.3

Soviet Plans of Expansion

The Soviet leadership was at work on its own plans of expansion. Stalin stated in March 1939 at the 18th Congress of the Communist Party, that the time is ripe "for a reappraisal of existing international pledges and agreements" under the existing political circumstances.4

At the time, the Soviet leaders anticipated the idea of eventual victory of the Communist Revolution by means of the Second World War:

Bourgeois politicians are well aware that the first imperialistic war brought about the victory of a revolution in one of the biggest countries. They fear that the second imperialistic war may bring about the victory of revolution in one or many countries.5

In the presence of such a prospect, the Soviet Union was not interested in maintaining the status quo, but rather in encouraging the conflict between capitalist countries in order to spread the revolution.

This new Soviet approach was well understood by certain diplomats. Ambassador Loraine (Rome) wrote to Viscount Halifax on May 4, 1939:

I should be very grateful to know appreciation of the significance of Mr. Litvinov resignation. My French colleague propounds the astonishing theory that Stalin sacked him in order to make arrangement with Germany which would of course enable the latter to attack Poland and retake the corridor with relative impunity.6

The Soviet plans for expansion at the expense of the neighboring states to the West became clearer during negotiations between the Soviet Union, Great Britain and France. The negotiations lasted almost four months and ended in fiasco. The main obstacle to concluding the British-French-Soviet mutual assistance pact was the Soviet insistence upon guarantees for the independence of Finland, Estonia, Latvia, Poland, Rumania, Turkey, Greece and Belgium whether or not those countries wanted such guarantees and insistence that the guarantees should be against direct and indirect aggression.

The definition of indirect aggression proposed by the Soviet Union on July 4, 1939, immediately provoked the suspicion that the Soviet Union had hidden intentions. It reads: "It is a case of a coup d'etat in the interior or a change of policy which is favorable to an aggressor."7 In the above mentioned article, B. Meissner pointed out that, in the opinion of Great Britain, such a definition, if accepted, would have given the Soviet Union the right to interfere in the internal affairs of the neighboring states.

With admirable perspicuity this was pointed out by Butler in the House of Commons on July 31, 1939:

We have proceeded with the utmost vigor to discuss with Russia our outstanding difficulties. The main question has been whether we should encroach on the independence of the Baltic States. We are in agreement that we should not do so, and the difficulty of reaching a formula on this point is one of the main reasons why there has been delay in these negotiations.8

On December 5, 1939, when the Molotov-Ribbentrop pact was already in effect, Lord Halifax, speaking before the House of Lords, was more explicit on the Soviet hidden plans concerning the Baltic region:

Earlier in the year we have tried to improve our relations with Russia, but in doing so we had maintained the position that the rights of the third parties must remain intact and be unaffected by our negotiations. Events have shown that the judgment of His Majesty's Government on refusing agreement with the Soviet Government of the terms of formula covering cases on indirect aggression on the Baltic State were right. For it is now plain that this formula might well have been the cloak for ulterior designs. I have little doubt that the people of this country would prefer to face difficulties and embarrassment rather than feel we have compromised the Honor of this country and of the Commonwealth on such an issue.9

Two noted American historians, taking into consideration that indirect aggression could be interpreted in many ways, these "ulterior designs", have been described as follows:

. . . there was more than sufficient reasons for believing that the Soviet Government had territorial ambitions with regard to the entire frontier region lost to it in 1917 and the succeeding years. London and Paris were well aware of Soviet claims and hopes and therefore found themselves in an awkward if not impossible position when confronted with the Soviet note of June 2, 1939. Apart of their unwillingness to aid and abet the expansion of Communist power, they felt strongly that, after posing as the defenders of small states against aggression, they could hardly themselves take part in forcing upon the Baltic States arrangements which they definitely did not want and would not accept . . . they would never, so they said, accept a definition of indirect aggression that would permit the Soviet to march into the Baltic States at their pleasure.10

Suddenly on July 24,1939, Molotov announced that the Soviet Government is in substantial agreement with the French and British position. The one condition was that the guaranteed states were to be Estonia, Latvia, Lithuania, Poland, Rumania, Turkey, Greece and Belgium. Lithuania was not included in the original list of guaranteed nations:

Why Lithuania was included among those nations to be guaranteed at the final stage of negotiations and not in the earlier period raises an important question. At that time Soviet Russia had not, apparently, considered Lithuania as lying within its sphere of vital interest because significantly later negotiations with Nazi-Germany, which culminated in the Molotov-Ribbentrop Pact of August 23, had placed Lithuania in German sphere. Not until the second Molotov-Ribbentrop agreement of September 28 was Lithuania finally considered as being part of the Soviet sphere.11

In the hope that Molotov's announcement meant that Moscow is ready to sign a Pact, special British and French delegations arrived in Moscow on August 11, 1939. In fact this was nothing but a shrewd maneuver.

The Molotov-Ribbentrop Pact Signed

While carrying on the negotiations for concluding a military alliance with Great Britain and France, the Soviet representatives made political contacts in Berlin. Already on March 17, 1939, the Soviet Ambassador in Berlin, in his conversation with Weizsaeker, State Secretary of the Foreign Ministry, mentioned, in passing, that there are no obstacles to improving Soviet-German relations. And later on, Molotov pointed out, in his conversations with German Ambassador Schulenburg concerning trade agreement, that the "creation of a political basis for the resumption of economic negotiations" is necessary.12 Finally on August 2, Ribbentrop said to the Soviet Charge:

. . . there was no problem from the Baltic to the Black Sea that could not be solved between us. I said that there was room for the two of us on the Baltic Sea and that Russian interests by no means needed to clash with ours there.13

On August 19, 1939, Schulenburg sent the draft of agreement submitted by Molotov to Berlin with the following postscript by Molotov:

The present Pact shall be valid only if a special protocol is signed simultaneously covering the points in which the High Contracting Parties are interested in the field of foreign policy. The Protocol shall be an integral part of the Pact.14

On August 23, 1939, Ribbentrop arrived in Moscow and met with Stalin and Molotov. When, at Stalin's request, Germany agreed that the ports of Libau and Window were to be included in the sphere of the Soviet Union, the last obstacle was eliminated. On August 23, 1939, the "Treaty of Non-aggression Between Germany and the Union of Soviet Socialist Republics" and "The Secret Additional Protocol" were signed by Ribbentrop and Molotov.

During the pact signing ceremonies Molotov raised the glass to Stalin, remarking that it had been Stalin who had brought about the reversal in political relations by his March speech, which had been well received in Germany. When they took their leave, Stalin addressed the German Foreign Minister words to this effect: "The Soviet Government takes the new Pact very seriously. He could guarantee on his word of honor that the Soviet Union would not betray its partner."15

The Molotov-Ribbentrop Pact allowed Germany to invade Poland without fear of being drawn into a battle with the Soviet Army. It also allowed Stalin to seize parts of Poland and Finland and then to annex Lithuania, Latvia, and Estonia in 1940.

The Pact reads as follows:

Treaty of Non-aggression Between Germany and the Union of Soviet Socialist Republics

The Government of the German Reich and the Government of the Union of Soviet Socialist Republics desirous of strengthening the cause of peace between Germany and the U.S.S.R., and proceeding from the fundamental provisions of the Neutrality Agreement concluded in April 1926 between Germany and the U.S.S.R., have reached the following agreement:

ARTICLE I

Both High Contracting Parties obligate themselves to desist  from any act of violence, any aggressive action, and any attack on each other, either individually or jointly with other powers.

ARTICLE II

Should one of the High Contracting Parties become the object of belligerent action by a third power, the other High Contracting Party shall in no manner lend its support to the third power.

ARTICLE III

The Governments of the two High Contracting Parties shall in the future maintain continual contact with one another for the purpose of consultation in order to exchange information on problems affecting their common interests.

ARTICLE IV

Neither of the two High Contracting Parties shall participate in any grouping of powers whatsoever that is directly or indirectly aimed at the other party.

ARTICLE V

Should disputes or conflicts arise between the High Contracting Parties over problems of one kind or another, both parties shall settle these disputes or conflicts exclusively through friendly exchange of opinion or, if necessary, through the establishment of arbitration commissions.

ARTICLE VI

The present treaty is concluded for a period of ten years, with the proviso that, in so far as one of the High Contracting Parties does not denounce it one year prior to the expiration of this period, the validity of this treaty shall automatically be extended for another five years.

ARTICLE VII

The present treaty shall be ratified within the shortest possible time. The ratifications shall be exchanged in Berlin. The agreement shall enter into force as soon as it is signed. Done in duplicate, in the German and Russian languages.

Moscow, August 23, 1939.

For the Government of the German Reich: v. Ribbentrop With full power of the Government of the U.S.S.R.:

V. Molotov16

Secret Additional Protocol

On the occasion of the signature of the non-aggression Pact between the German Reich and the Union of Soviet Socialist Republics the undersigned plenipotentiaries of each of the two parties discussed in strict confidential conversations the question of the boundary of their respective spheres of influence in Eastern Europe. These conversations led to the following conclusions:

1. In the event of a territorial and political rearrangement in areas belonging to the Baltic States (Finland, Estonia, Latvia, Lithuania), the northern boundary of Lithuania shall represent the boundary of the spheres of influence of Germany and USSR. In this connection the interest of Lithuania in the Vilnius area is recognized by each party.

2. In the event of a territorial and political rearrangement the areas belonging to the Polish state, the spheres of influence of Germany and the U.S.S.R. shall be bounded approximately by the line of the rivers Narew, Vistula, and San.

The question of whether the interests of both parties make desirable the maintenance of an independent Polish state and how such a state should be bounded can only be definitely determined in the course of further political developments. In any event both Governments will resolve this question by means of a friendly agreement.

3. With regards to Southeastern Europe attention is called by the Soviet side to its interests in Bessarabia. The German side declares its complete political disinterestedness in these areas.

4. This Protocol shall be treated by both parties as strictly secret.

Moscow, August 23, 1939

For the Government of the German Reich: v. Ribbentrop Plenipotentiary of the Government of the U.S.S.R..

V. Molotov

Thus, according to the Secret Protocol, Lithuania fell into the sphere of influence of Germany. Immediately Germany undertook steps to convert Lithuania into its protectorate, as B. Kaslas pointed out:

Once Lithuania was conceded as in its zone of interest, Germany began taking steps in an effort to convert Lithuania into a German satellite and protectorate as a buffer between itself and the U.S.S.R. German pressure on Lithuania to join it in attacking Poland came to nothing, however. ... All responsible Lithuanian officials unanimously agreed that Lithuania, under the circumstances, should not abandon neutrality.17

After the collapse of Poland on September 25, 1939, Moscow proposed that the Province of Lublin and a portion of the Province of Warsaw be added to the German share and, in return, Germany waive its right to Lithuania:

The German Ambassador in the Soviet Union (Schulenburg) to the German Foreign Office.

Very urgent. Strictly secret. No. 442 of September 25

Stalin and Molotov asked me to come to the Kremlin at 8 p.m. today. Stalin stated the following: In the final settlement of the Polish question anything that in the future might create friction between Germany and the Soviet Union must be avoided. From this point of view, he considered it wrong to leave an independent Polish rump state. He proposed the following: From the territory to the east of the demarcation line, all the Province of Lublin and that portion of the Province of Warsaw which extends to the Bug should be added to our share. In return, we should waive our right to Lithuania.

Stalin designated this suggestion as a subject for the forthcoming negotiations with the Reich Foreign Minister and added that, if we consented, the Soviet Union would immediately take up the solution of the problem of the Baltic countries in accordance with the Protocol of August 23, and expected in this matter the unstinting support of the German Government. Stalin expressly indicated Estonia, Latvia, and Lithuania, but did not mention Finland. I replied that I would report to my Government.

Schulenburg18

Germany agreed and on September 28, 1939, signed the Secret Supplementary Protocol:

Secret Supplementary Protocol

The undersigned Plenipotentiaries declare the agreement of the Government of the German Reich and the Government of the U.S.S.R. upon the following:

The Secret Supplementary Protocol signed on August 23, 1939, shall be amended in item 1 to the effect that the territory of the Lithuanian state falls to the sphere of influence of the U.S.S.R., while, on the other hand, the province of Lublin and parts of the province of Warsaw fall to the sphere of influence of Germany (cf. the map attached to the Boundary and Friendship Treaty signed today). As soon as the Government of the U.S.S.R. shall take special measures on Lithuanian territory to protect its interests, the present German-Lithuanian border, for the purpose of a natural and simple boundary delineation, shall be rectified in such a way that the Lithuanian territory situated to the southwest of the line marked on the attached map should fall to Germany. Further it is declared that the economic agreements now in force between Germany and Lithuania shall not be affected by the measures of the Soviet Union referred to above. Moscow, September 28, 1939.

For the Government of the German Reich: J. Ribbentrop By authority of the Government of the U.S.S.R.:

V. Molotow19

The Lithuanian strip to be ceded to Germany consisted of the following districts and circa 184,000 inhabitants:

Lithuania's territory ... is bounded in the southwest by the Lithuanian-German boundary and in the northeast is delineated by a line which unites the following populated palaces: Širvintai, Pilviškiai, Mariampolė, Simnas, Zapockinė. To it belong: almost the whole district of Vilkaviškis, 1/3 District of Mariampolė, 1/5 District of Seinai, and 1/5 District of Alytus. According to the data of the Lithuanian Statistical Bureau, the number and national composition was as follows: according to census of 1923 — 151,394 people, in December 1939 — 184,108 people.20

On October 3, 1939, Ambassador Schulenburg informed the German Foreign Office that the Soviet Government was willing to cede the city of Vilnius and its environs:

The German Ambassador in the Soviet Union (Schulenburg) to the German Foreign Office

Very urgent. Strictly secret. No. 463 of October 3 Molotov summoned me to his office at 2 p.m. today, in order to communicate to me the following:

The Soviet Government would tell the Lithuanian Foreign Minister who arrives today, that, within the framework of an amicable settlement of mutual relations (probably similar to the one with Estonia) the Soviet Government was willing to cede the city of Vilnius and its environs to Lithuania, while at the same time the Soviet Government would indicate to Lithuania that it must cede the well-known portion of its territory to Germany. Molotov inquired what formal procedure we had in mind for carrying this out. His idea was the simultaneous signing of a Soviet-Lithuanian protocol on Vilnius and a German-Lithuanian protocol on the Lithuanian area to be ceded to us.

I replied that this suggestion did not appeal to me. It seemed to me more logical that the Soviet Government should exchange Vilnius for the strip to be ceded to us and then hand this strip over to us. Molotov did not seem quite in accord with my proposal but was willing to let me ask for the viewpoint of my Government and give him a reply by tomorrow noon.

Molotov's suggestion seems harmful, as in the eyes of the world it would make us appear as "robbers" of Lithuanian territory, while the Soviet Government figures as the donor. As I see it, only my suggestion enters into consideration at all. However, I would ask you to consider whether it might not be advisable for us, by a separate secret German-Soviet protocol, to forego the cession of the Lithuanian strip of territory until the Soviet Union actually incorporates Lithuania, an idea on which, I believe, the arrangement concerning Lithuania was originally based.

Schulenburg21

On October 4, 1939, Ribbentrop approved his Ambassador's point of view:

I, too, do not consider the method suggested for the cession of the Lithuanian strip of territory as suitable. On the contrary, please ask Molotov not to discuss this cession of territory with the Lithuanians at present, but rather to have the Soviet Government assume the obligation toward Germany to leave this strip of territory unoccupied in the event of posting of Soviet forces in Lithuania, which may possibly be contemplated, and furthermore to leave it to Germany to determine the date on which the cession of the territory should be formally effected. An understanding to this effect should be set forth in a secret exchange of letters between yourself and Molotov.22

And on October 8, 1939, a new agreement was reached by an exchange of letters. Molotov wrote to the German Ambassador:

Secret Moscow, October 8, 1939 Mr. Ambassador: I have the honor hereby to confirm that in connection with the secret supplementary protocol, concluded on September 29 (28), 1939, between the U.S.S.R. and Germany, concerning Lithuania, the following understanding exists between us:

1) The Lithuanian territory mentioned in the protocol and marked on the map attached to the protocol shall not be occupied in case forces of the Red Army should be stationed (in Lithuania);

2) It shall be left to Germany to determine the date for the implementing of the agreement concerning the cession to Germany of the above-mentioned Lithuanian territory.

V. Molotov23

On June 15, 1940, the Red Army occupied Lithuania, including the strip of Lithuanian territory which the Soviet Union had promised not to occupy and to cede it to Germany. On July 13, 1940, Molotov asked to revise the German attitude toward that strip of Lithuania:

The German Ambassador in the Soviet Union (Schulenburg) to the German Foreign Office

Very urgent

No. 1363 of July 13

Reference your telegram of the 8th, No. 1164, and my telegram of the 12th, No. 1348.

Molotov summoned me today and stated the following: Stalin has carefully re-examined the situation with respect to the strip of Lithuanian territory and has concluded that our claim to this strip of territory and the Soviet obligation to cede it are incontestable. Under the present circumstances, however, the cession of this strip of territory would be very inconvenient and difficult for the Soviet Government. Therefore, Stalin and he himself earnestly request the German Government to consider whether in conformity with the extraordinarily friendly relations between Germany and the Soviet Union, a way cannot be found which would leave this strip of territory permanently with Lithuania. Molotov added that we could of course at any time move the population of German origin out of Lithuania as well as out of this strip of territory. Molotov stressed again and again the difficulties which would at present result for the Soviet Union from the cession of this strip of territory, and he made his and Stalin's request seem very urgent by repeatedly expressing hope of a German concession. Request instructions by wire. Perhaps the Soviet request can be used to put through our economic and financial demand with respect to the Baltic States. Schulenburg24

On August 2,1940, Ribbentrop asked quid pro quo what the Soviet Government would propose:

The Reich Foreign Minister to the German Ambassador in the Soviet Union (Schulenburg)

No. 1339 of August 2

Reference your telegram of July 13, No. 1363.
You are requested to inform Herr Molotov that the Reich
Government has taken cognizance of the wish of the Soviet
Government that Germany leave to the Soviet Union that
part of Lithuania allocated to Germany by the Moscow
agreements. This would represent a rather considerable
change in the Moscow Treaty to the disadvantage of
Germany. Before the Reich Government can consider the
matter in detail, therefore, I should be interested in hearing
what quid pro quo the Soviet Government would propose.

Ribbentrop25

After protracted negotiations, Germany agreed to take compensation for the ceded Lithuanian territory, and Molotov and Schulenburg signed the following Secret Protocol on January 10, 1941: 

Secret Protocol

The German Ambassador, Count von der Schulenburg, Plenipotentiary of the Government of the German Reich, on the one hand, and the Chairman of the Council of People's Commissars of the U.S.S.R., on the other hand, have agreed upon the following:

1. The Government of the German Reich renounces its claim to the strip of Lithuanian territory which is mentioned in the Secret Supplementary Protocol of September 23, 1939 and which has been marked on the map attached to this Protocol;

2. The Government of the Union of Soviet Socialist Republics is prepared to compensate the Government of the German Reich for the territory mentioned in Point 1 of this Protocol by paying 7,500,000 gold dollars or 31,500,000 Reichsmarks to Germany.

The amount of 31.5 million Reichsmarks will be paid by the Government U.S.S.R. in the following manner: one-eighth, that is, 3,937,500 Reichsmarks, in non-ferrous metal deliveries within three months after the signing of this Protocol, the remaining seven-eights, or 27,562,500 Reichsmarks, in gold by deduction from the German gold payments which German is to make by February 11, 1941 in accordance with the correspondence exchanged between the Chairman of the German Economic Delegation, Dr. Schnurre, and the People's Commissar for Foreign Trade of the U.S.S.R., Herr  A. I. Mikoyan, in connection with the "Agreement of January 10,1941, concerning reciprocal deliveries in the second treaty period on the basis of the Economic Agreement between the German Reich and the Union of Soviet Socialist Republics of February 11, 1940."

3. This Protocol has been executed in two originals in the German language and two originals in the Russian language and shall become effective immediately upon signature. Moscow, January 10, 1941

For the Government of the German Reich: Schulenburg By authority of the Government of the U.S.S.R.: V. Molotov26

Thus, the Soviet Union and Germany disposed of the Lithuanian territory as though it was their own property. These secret agreements present crystal clear evidence of the Soviet intent to incorporate Lithuania into the Soviet Union. Further actions on the part of the Soviet Union were nothing but the implementation of these secret agreements.

Consequences of Molotov-Ribbentrop Pact

The Molotov-Ribbentrop Pact opened the gates of aggression in Europe. It also sealed the fate of Lithuania. In September 1939, Germany and the Soviet Union were pursuing their plan of aggression. Germany divided Poland, and the Soviet Union immediately initiated its action against the Baltic States. The Soviet Union imposed the so-called pacts of mutual assistance upon the Baltic States with direct, military threat. The pacts gave the Soviet Union the right to establish land, navy and air bases in the territories of the Baltic States. The "Treaty of the Transfer of Vilnius and Soviet-Lithuania Mutual Assistance" was signed on October 10, 1939. According to this treaty, the Soviet Union, in addition to its former obligations, undertook not to interfere in internal affairs of Lithuania, promising that the "realization of this Pact shall not in any way affect the sovereign rights of the Contracting Parties, in particular the state of organization, economic and social systems, military measures and, in general, the principle of nonintervention in internal affairs."27

This principle of nonintervention in internal affairs was especially stressed by Molotov in his speech before the Supreme Soviet on October 31, 1939:

All these pacts of mutual assistance strictly stipulated the inviolability of the sovereignty of signatory states and the principle of noninterference in each other's affairs . . . We declare that all nonsensical talk about the sovietization of the Baltic countries is only in the interest of our common enemies and of all anti-Soviet provocateurs.28

John Foster Dulles, Secretary of State of the United States had a following comment on this:

So spoke the Soviet Minister on October 31, 1939. Scarcely had these passionate and authoritative words been uttered when the "Sovietization" which he had explained got underway. The concluding acts occurred eight months later when the Soviet Union marched its Red Armies into the Baltic territory, set up puppet governments, and caused them to apply for admission into the Soviet Union, an admission that was graciously granted. Thus the "nonsensical talk" of foreign newspapers became a bleak reality.29

The establishment of military bases was only the first part of the plan of aggression. On June 14, 1940, the Soviet Government presented her ultimatum to Lithuania demanding the immediate formation of a new Government acceptable to the Soviet Union and a free entry into the territory of Lithuania for an unlimited number of troops of the Red Army. On June 15, 1940, Lithuania was occupied by the Soviet troops. The President of Lithuania, Antanas Smetona, left the country. On June 16, 1940, the Soviet Government sent a special emissary, the Deputy Commissar of Foreign Affairs, Dekanozov, to negotiate the formation of the new government. In addition to the accredited Soviet Envoy, special envoys were likewise dispatched to Latvia and Estonia. On June 17, 1940, the Prime Minister, Antanas Merkys, acting as President, appointed the Soviet nominee Justas Paleckis, under duress, as Prime Minister.

The Soviet Union, to save face, attempted to cover its annexation of the Baltic States with a cloak of legality. Therefore Moscow ordered the puppet government of Paleckis to carry out elections for a Peoples Diet on July 14-15 with a single list of candidates. The Diet was assigned the mission of introducing a Soviet regime in Lithuania and requesting admission into the Soviet Union.

29 House of Representatives Eighty-Third Session Congress, First Session . . . H. Res. 346. Baltic States Investigation. Hearings Before the Select Committee to Investigate the Incorporation of the Baltic States into the U.S.S.R. (Washington, United States Printing Office: 1954) p. 3.

According to Lapradelle, an authority on international law:

Never before had an occupying power arranged general elections in an occupied country in order to create an elective parliament charged with the prescribed task of voting incorporation of its country in the occupying one. In order not to shock world's opinion, the Russian stage managers wanted that the Estonians, Latvians and Lithuanians should themselves go on record as petitioners for the admission into the Soviet Union. But if the elections, held under the conditions of military occupation, were to have any validity from the international point of view, the question of the surrender of sovereignty and the proposal for incorporation in the Soviet Union should have been explicitly announced to the electorate before the elections. The platform of the government-sponsored party, however, did not suggest this eventuality by a single word.30

The Committee of the United States Congress, after investigating the incorporation of the Baltic States into the Soviet Union, concluded:

The evidence is overwhelming and conclusive that Estonia, Latvia and Lithuania were forcibly occupied and illegally annexed by the U.S.S.R. Any claims by the U.S.S.R. that the elections conducted by them in July 1940 were free and voluntary or that the resolutions adopted by the resulting parliaments petitioning for recognition as a Soviet Republic were legal are false and without foundation in fact. That the continued military and political occupation of Lithuania, Latvia and Estonia by the U.S.S.R. is a major cause of the dangerous world tensions which now beset mankind and therefore constitutes a serious threat to the peace.31

After a military invasion of Lithuania, the Soviet Union became an aggressor according to the provisions of the Convention for the Definition of Aggression signed in London on July 5, 1933. An aggressor state is one which first commits one of the following acts: "invasion by the armed forces, even without declaration of war, of the territory of the other State." B. Meissner considers the act of annexation as an illegal act, regardless if it is carried out by war or other means of force.

In Soviet legal literature, annexation is described as "a seizure, forcible incorporation of a territory or part of another state." Additionally, "the Soviet State and other socialist states arė strongly opposed against any form of annexation, because annexation is contrary to the principle of self-determination of peoples and is one form of repression."32 Soviet legal experts proudly point out that in the Decree of Peace in November 8 (October 26), the Soviet Union was the first State which condemned annexation:

In accordance with the legal conscience of democracy in general, and working people especially, the Government considers annexation to be any incorporation of a small and weak nation into a large and strong state without definite, clear and free desire of the affected nation, irrespective of when this incorporation took place, irrespective of how developed or undeveloped the nation is kept within the limits of that state, and finally, irrespective if the nation is living in Europe or beyond oceans.

If a nation is kept forcibly within the frontiers of another state against its will, if this nation, contrary to its expressed desire, irrespective if this desire was expressed in the press, in the peoples meetings, in the resolutions of parties, or troubles or uprisings against national oppression, is not accorded the right to decide the problem of political existence by a free vote without any presssure, by complete withdrawal of the troops of incorporating or merely stronger nation, then the incorporation is an annexation, i.e. an arbitrary appropriation, an act of violence.33

The Soviet action of incorporating the Baltic States into the Soviet Union is illegal and prohibited by international law, as well as contrary to the right of self-determination of the Baltic Peoples. To this effect writes B. Meissner:

The incorporation of the Baltic States into the Soviet Union, which ensued pursuant to the Soviet laws of August 3, 5, and 6,1940, constituted not a voluntary unification of a federative basis but a forced appropriation of sovereign territory of a foreign state, that is, an annexation forbidden by modern international law. The legal arguments put forth from the Soviet side in this illegal acquisition of territory are easily refuted.

The public institutions of Soviet rule were based on the bayonets of the Soviet occupation forces and not on the will of the Baltic peoples. These institutions therefore could not express the right of self-determination of the respective nations. The Soviet Union contracted with itself, as it were, and through the act of annexation clearly violated not only the sovereignty of the Baltic States, but also the right to self-determination of the Baltic peoples.34

Annexation is an illegal act, an act of violence. Such a concept constitutes the basis of the Resolution of the League of Nations of March 11, 1932, which obligates its members not to recognize any situation, treaty or agreement made in violation of the provisions of the Chapter of the League of Nations or Pact of Paris. This Resolution became the basis of the Nuremberg Tribunal verdicts.

According to the provisions of Article 6 of the Charter of the International Military Tribunal, crimes against peace are:

"planning, preparing, initiating or waging a war of aggression or a war in violation of international treaties, agreements or assurances, or participation in a common plan of conspiracy for the accomplishment of any of the foregoing."35

The Tribunal justified at length the indictment of the defendants for crimes against peace, and for planning and waging of a war of aggression.

In the Austrian case, the Tribunal recognized that the Austrian occupation was an annexation, a crime against peace:

It was contended before the Tribunal that the annexation of Austria was justified by the strong desire expressed in many quarters for the union of Austria and Germany, that there were many matters in common between two peoples that made this union desirable; and that in the result the object was achieved without bloodshed.

These matters, even if true, are really immaterial for the facts plainly prove that the methods employed to achieve were those of aggressor. The ultimate factor was the armed might of Germany ready to be used if any resistance was encountered.36

Thus, the main factor was the presence of German military force. The Peoples Diet of Lithuania, elected under guise of the Soviet Union, in its Resolution On the Joining Lithuania to the Soviet Union, made it clear that the presence of the Red Army in Lithuania was a decisive factor in joining Lithuania to the Soviet Union:

Now the people, helped by the mighty Red Army, overthrow the yoke of Smetona oppressors and established the Soviet regime in their country .... If the people have been able to establish in their country the only just order — the Soviet order — it is all due to the Soviet Union.37

The Austrian and Lithuanian cases are analogous. In both cases the same arguments were used for the justification of annexation.38

Soviet Efforts to Justify Incorporation

The official explanation that Lithuania voluntarily joined the Soviet Union was so incredible that the Soviet writers searched for more plausible explanations. In 1941 the Soviet War News agency published the pamphlet The Soviet Union, Finland and the Baltic States on behalf of the Soviet Information Bureau. The Baltic States were accused of failing to observe the conditions of peaceful coexistence:

The Soviet Government considered that the Baltic States were in duty bound to fulfill only condition for peaceful coexistence. This condition was loyalty and readiness (and this not only in words but in deeds) on the part of the Baltic States not to violate the security of the Soviet Union, not to transform their territory into places d'armes for possible attacks on the Soviet Union, not to permit any country to establish protectorate over themselves, not to give their territory 'on lease' for its possible use by any aggressor or would be aggressor against the Soviet Union.39

The pamphlet concluded:

The Soviet Union could not but draw the only possible deduction from all these facts, and in 1940 it was constrained to demand that there should be a change in the Government of Estonia, Latvia and Lithuania — since their hostility toward the U.S.S.R. threatened the complete subordination of the Baltic States to German Fascism.40

In fact, the Soviet Union presented its ultimata to the Baltic States when their situation was as follows: According to the so-called mutual assistance treaties, the Baltic States were forced to turn over military bases "on lease" to the Soviet Union and to admit at least 50,000-60,000 Soviet troops. Thus, the Soviet Union itself was guilty of transforming the Baltic States into "places d'armes" and of establishing a protectorate over them.

In 1948, the Soviet Information Bureau published another pamphlet, Falsifiers of History, which contain some ramifications of the former arguments, namely the formation of the Eastern Front:

In the middle of June, 1940, the Soviet troops entered Estonia, Latvia and Lithuania. On June 27, 1940, the Soviet troops entered Bukovina and Moldavia .... Thus the formation of an Eastern front against Hitlerite aggression from the Baltic to the Black Sea was completed. The British and French ruling circles, which went on abusing the U.S.S.R. and calling it an aggressor for creating an "Eastern" front, evidently did not realize that the appearance of an "Eastern" front signified a radical turn in the development of the war — a turn in favor of a victory for democracy.

They did not realize that it was not a question of infringing upon the national rights of Finland, Lithuania, Latvia, Estonia, Poland, but that the point was to organize victory over the Nazis in order to prevent the conversion of those countries into disenfranchised colonies of Hitler Germany.41

The Soviet Union did as Hitler in the case of Austria, finally stressed strategic advantages and emphatically denied the national rights of the other nations. Yet the Soviet Union was not at war with Nazi Germany when the Soviet troops overran the Baltic states. On the contrary, this was a period of fraternization between the two countries. Soviet military actions against Finland, Poland, Lithuania, Latvia and Estonia were carried out in agreement with Germany on delimitation of their respective zones of influence.

Another effort to absolve themselves of the annexation showed that the establishment of the Soviet regime was the result of social revolutions in all three countries:

As a preliminary to armed intervention, the democratic-socialist opposition, cooperating with the local Communist Parties, staged coups d'etat. In all three capitals people's governments were set up. These governments gave power to local political forces grouped in the Left bloc; formal in Latvia and Estonia, informal in Lithuania.42

This is the presentation of events by G. Meiksins in Soviet propaganda booklet published in the United States.

The same point was presented by V. Niunka, a Secretary of the Lithuanian Communist Party: "In 1940 the antifascist movement of working people became a great force. Taking advantage of the situation, the working people of Lithuania, under the leadership of the Communist Party, overthrew the bourgeois dictatorship and took the power into their hands."43

The truth is completely different from what Meiksins and Niunka say. First, there were no changes in the governments before the troops occupied Baltic countries. Second, the formation of the new governments was directed by special emissaries: in Lithuania by Dekanozov, in Latvia by Vishinski and in Estonia by Zhdanov. In this connection it is worthwhile to note the words of K. Marek:

It must be borne in mind that a revolution is a spontaneous phenomenon; in the case of the Baltics, however, it took place with an uncanny identity or timing and procedure in what were, after all, three entirely separate states. Yet the dates of the consecutive stages of the allegedly revolutionary development were almost as identical as were the resolutions produced by the allegedly revolutionary bodies . . . ,44

Several authors, in particular A. M. Anreiev,45 attempted to prove that the establishment of the Soviet regime in 1940 had been nothing but reinstatement of the same regime that was first established in Lithuania in 1918. The only thing they succeeded in proving, however, was that the 1918 Soviet regime had been established by Moscow, just like the 1940 regime.

In July, 1918, on orders from Moscow, the Social Democratic Worker's Party of Lithuania and Byelorussia was formed. On August 14, 1918, it was changed to the Communist Party of Lithuania and Byelorussia. Contrary to the Declaration of November 15, 1917, "On the Rights of Peoples to Self-Determination", the Government of Russia decided on November 16, 1918, to form an army of three divisions and "to send them to help the working people of Byelorussia, Lithuania, Latvia and Estonia." The formation of the Communist Party was necessary to justify military intervention and to present this military action as assistance to the local population.

On December 8, 1918, on Stalin's order, the Central Committee of the Communist Party of Lithuania and Byelorussia formed the Provisional Revolutionary Workers Government of Lithuania, headed by V. Kapsukas-Mickevičius, chief of the Lithuanian Bureau of the Communist Party in Moscow. On December 22 of that year the Government of Soviet Russia recognized the authority of the Kapsukas government and "instructed all civil and military authorities to give all necessary assistance." In this way Soviet Russia tried to present intervention as an aid to an existing government, but in reality no revolutionary movement existed in Lithuania, as was openly admitted by the Deputy Chairman of the Kapsukas government, Angarietis: "The Soviet rule in Lithuania was not won through internal struggle, nor was it the result of a workers' revolt ... it was the Red Army that brought the Soviet rule to Lithuania."46

The Soviet efforts to justify the annexation of Lithuania are contradictory. On the one hand, they explain the action by trying to show it to be the result of the free determination of the Lithuanian people (election, social revolution) and, on the other, they advance reasons of security. These explanations cancel each other out. If Lithuania was incorporated into the Soviet Union for security and strategic reasons, the decisive factor was the will of the Soviet Union and not the will of the Lithuanian nation.

The aim of these efforts was not to find the truth, but to bolster Soviet political designs by endowing them with plausibility and legitimacy. Communist propaganda never fails to transform Soviet acts of violence and aggression into impressive acts of "liberation." But the fact remains that the Soviet Union, by entering into agreements with Nazi Germany on the division of Lithuania, and by occupying and incorporating Lithuania, did become an aggressor.

Non-recognition of the Soviet Annexation

Once the fate of Lithuania became obvious, the United States, faithful to the doctrine on non-recognition, condemned the Soviet action. On July 24, 1940, the Acting Secretary of the Department of the State, Sumner Welles, stated:

The policy of this Government is universally known. The people of the United States are opposed to predatory activities no matter whether they are carried on by the use of force of by the threat of force. They are likewise opposed to any form of intervention on the part of one state, however, powerful, in the domestic concerns of any sovereign state, however weak .... The United States will continue to stand by these principles, because of the conviction of the American people that unless the doctrine in which these principles are inherent once again governs the relations between nations, the rule of reason, of justice, and of law — in other words, the basis of modern civilization itself — cannot be preserved.47

H. Lauterpacht, an authority of international law, points out that a doctrine of non-recognition is based on the principles of ex injuria jus non oritur:

This construction of non-recognition is based on the view that acts contrary to international law are invalid and cannot become a source of legal rights for the wrongdoer. That view applies to international law one of 'the general principles of law recognized by civilized nation.' The principle ex injuria jus non oritur is one of the fundamental maxims of jurisprudence. An illegality cannot, as a rule, become a source of legal right to the wrongdoer.48

During the debates in the League of Nations in the case of Ethiopia, Maxim Litvinov, at that time Minister of Foreign Affairs of the U.S.S.R., spoke about the political and legal consequences of non-recognition:

Among the means for combating aggression and defending its Members which the League has at its disposal, nonrecognition does not by any means play a conspicuous part. It is improbable that any one would assert that the mere threat of non-recognition may avert aggression, or that non-recognition itself might free the victim of aggression from the grip of the conqueror ....

It would be quite wrong, however, to assert that resolutions on non-recognition are in themselves devoid of any particular value. While such resolutions have in every case a certain moral significance, and give satisfaction to public opinion, they also cause the aggressor some preoccupations and inconveniences, as is evidenced by the efforts which aggressors usually make to obtain recognition of their conquests, if only in an indirect way.

But, according to circumstances, non-recognition may be of vast importance, not only morally, but also politically — particularly when the victim of aggression itself continues to fight for its independence and for the integrity of its territory. In such cases, the recognition of the results of acts of violent aggression, or the abandonment of the policy of non-recognition, would be equivalent to abetting the aggressor directly, and to stabbing the victim in the back by discouraging and demoralizing him. We have to reckon, not only with the question whether any struggle between the aggressor and his victims has come to an end, but also — should that have occurred for the time being — whether there are chances of the struggle being renewed, and likewise we have to reckon with other circumstances which may bring about a change in the situation created by aggressive acts of violence.

... It must be made even more clear that the League of Nations has not changed its opinion on the general principle of non-recognition of accomplished fact produced by aggression, and on the appropriate resolutions adopted by the League in other cases. The latter particularly applies in cases where the States which have been the victims of attack have aroused the amazement and admiration of the world by the valiance of their citizens who continue to fight the aggressor with unweakening energy, obstinacy and fortitude. It must be clear that the League of Nations has no intention of changing its attitude, whether to the direct seizure and annexation of other people's territory, or to those cases where such annexations are camouflaged by the setting up of puppet "national" governments, allegedly independent, but in reality serving merely as a screen for, and an agency of, the foreign invader.49

When the war started between the Soviet Union and Nazi Germany in June of 1941, on July 12,1941, Great Britain and the Soviet Union signed an agreement for mutual assistance and undertook the mutual obligation not to sign a separate peace treaty. However, this agreement did not satisfy Stalin. He urged Great Britain to declare war on Finland, Rumania and Hungary, to provide necessary assistance to the Soviet Union, and that an agreement be made concerning the purpose of the war. On December 17, 1941, Stalin directly asked Eden, whether his Government would support the joining of the Baltic States to the Soviet Union after the end of the war. The United States suggested that Great Britain not make any agreement until the end of the war. When Eden, on Soviet pressure, became inclined to make some concessions, Churchill telegraphed Eden to point out that the 1941 frontiers had been acquired by acts of aggression in collusion with Hitler and British acquiescence of this "would be contrary to all principles for which we are fighting and would dishonor our Cause."50

Later on, on February 6,1942, Eden suggested three lines of approach to the frontier problem: Stalin's demands could be accepted, subject to American acquiescence; the Soviet Union could be granted the right to have bases in the Baltic States; or the Soviet Union could have overriding control of the defenses and foreign affairs of the three countries.

Cordel Hull in a memorandum to Roosevelt on February 4, 1942, explained that these suggestions are unfortunate:

Stalin was seeking to break down the British-American principle of not recognizing wartime territorial changes before the peace conference. His frontier demands were in clear defiance of the principles of the Atlantic Charter, and Eden's attempt to suggest that the plebiscites of July 1940 in the Baltic States in some way did meet the Charter's demand that the wishes of the inhabitants be taken into account was tartly dismissed by the Secretary of State. Such casuistry would only serve to undermine the whole structure of the Atlantic Charter. In Hull's view. Soviet security needs could best be met by a strong postwar organization; the absorption of the independent Baltic States was certainly not necessary to the interests of Soviet security.51

When the problem of the Soviet frontiers with Poland arose, the deliberations were set aside. Thus Great Britain still did not de jure recognize incorporation of the Baltic States into the Soviet Union.

The attitude of the Federal Republic of Germany pertaining to non-recognition, was explained by Boris Meissner in following words:

As a result of the German-Soviet war, an exchange of the already-completed ratification documents of the German-Soviet border treaty of January 10,1941, never took place. De jure recognition of the Soviet annexation has therefore not been granted by Nazi Germany. From the standpoint of the Federal Republic of Germany, the Baltic States have not forfeited their sovereign international rights. The competent German federal authorities have consequently continued to recognize Estonian, Latvian, and Lithuanian citizenship on the basis of passports issued by the official representatives of the Baltic States. The German position in the Baltic question has not changed through the conclusion of the Moscow Treaty of August 12, 1970. In a statement of September 14, 1955, which was unanimously approved by the Bundestag, the Federal Republic's government expressly stipulated that the establishment of diplomatic relations between the two powers did not constitute a recognition of existing territorial possessions of both parties. In accordance with the renunciation of force agreement the Moscow Treaty speaks only of the parties' mutual responsibility "to respect the territorial integrity of all European states within their present boundaries." From this formulation there emerges no de jure recognition of the Soviet annexation of the Baltic States, especially since the question of the Soviet Union's western boundary is excluded from the treaty. The German Foreign Office, in response to a petition from the Baltic side, has therefore stipulated in a communique of August 27, 1970, "that the Federal Republic has not altered its commonly known position on the question of the Baltic States." In this connection it is essential to point out that the Exequatur of West Germany's newly established Consulate General in Leningrad also extends to the cities of Tallinn and Riga but not to the two union republics.52

The European Parliament in its Resolution On the Situation in Estonia, Latvia, and Lithuania of January 13,1983, condemned "the fact the occupation of these formerly independent and neutral states by the Soviet Union occurred in 1940 following the Molotov-Ribbentrop Pact, and still continues."53

The significance of the non-recognition policy was stressed by John Foster Dulles, Secretary of State of the United States. On November 30, 1953, appearing at the Hearings before the Select Committee to investigate the incorporation of the Baltic States into the Soviet Union, he said:

Some may say that it is unrealistic and impractical not to recognize the enforced incorporation of Estonia, Latvia, and Lithuania into the Soviet Union. We believe, however, that a despotism of the Soviet type cannot indefinitely perpetuate its rule over hundreds of millions of people who love God, who love country, and who have a sense of personal dignity. The Soviet system which seeks to expunge the distinctive characteristics of nation, creed, and individuality must itself change or be doomed ultimately to collapse. The time of collapse depends largely on whether the peoples who remain free produce spiritual, intellectual, and material richness, and whether we have a faith which can penetrate any Iron Curtain; and we must be sure that the captive peoples know that they are not forgotten, that we are not reconciled to their fate, and, above all, that we are not prepared to seek illusory safety for ourselves by a bargain with their masters which would confirm their captivity. These, Mr. Chairman, I can say to you, are our purposes. We have not forgotten the Atlantic Charter and its proclamation of "the right of all peoples to choose the form of government under which they will live." We still share the wish expressed in that charter, "to see sovereign rights and self-government restored to those who have forcibly been deprived of them.54

William J. H. Hough, III, in his thorough analysis of the annexation of the Baltic States, came to the following conclusions:

Refusal to recognize the annexation of the Baltic States is clearly mandated by international law. The international community has consistently rejected the legitimacy of the U.S.S.R.'s claim to title and no post-war international agreement has confirmed the state of affairs in the region .... For the first time in recorded history, the majority of the members of the world community have refused over a lengthy period to recognize the legitimacy of the title acquired through conquest.55

* Dr. Domas Krivickas is a former professor of the Universities of Kaunas and Vilnius (1932-1944), prorector of the University of Vilnius, and an associate member of the Academy of Science of Lithuania. He also contributed to numerous publications, including Lituanus. Before WW-II, he was a legal advisor to the Ministry of Foreign Affairs of the Republic of Lithuania and participated in negotiations with Germany, the Soviet Union, and Poland. During 1951-1975 Dr. Krivickas served as a Senior Legal Specialist at the European Law Division of the Library of Congress.
1 "Sir G. Ogilvie-Forbes (Berlin) to Viscount Halifax, March 20, 1939," Documents on British Foreign Policy 1919-1939, vol. IV (London: Great Britain Foreign Office, 1951) 347, No. 441. Hereafter, Documents.
2 Documents, (No. 471), p. 436.
3 R. Umiastowski, Poland, Russia and Great Britain 1941-1945: A Study of Evidence (London: Hollis and Carter, 1946) 519-20.
4 Sovetskoe gosudarstvo i pravo (1939:2): p. 6.
5 Ibid., 5. Documents, vol. V, No. 802, p. 104.
6 Documents, vol. V, No. 372, p. 429.
7 B. Meissner, "Die Grossmachte und die Baltische Frage," Osteuropa (1952:4): p. 246.
8 M. Beloff, The Foreign Policy of Soviet Russia 1929-1941, vol. 2 (London, 1949) p. 262.
9 Speeches on Foreign Policy by Lord Halifax (London: 1940) p. 272,340-351.
10 Third Interim Report of the Select Committee on Communist Aggression. House of Representatives Eighty-third Congress Second Session Under Authority of H. Res 346 and H. Res 438. Report of the Select Committee to Investigate Communist Aggression and the Forced Incorporation of the Baltic States in the U.S.S.R. United States Printing Office, Washington, 1954. p. 204. Hereafter Third Interim Report.
11 Third Interim Report, p. 204.
12 Nazi-Soviet Relations 7939-7947. The Department of State, 1948. p. 28.
13 Ibid. p. 38.
14 Ibid. p. 66.
15 Ibid. p. 76.
16 Ibid. p. 76-78. 12
17 Bronis J. Kasias. The Secret Protocols. The Lithuanian Strip in Soviet-German Secret Diplomacy, 1939-1941. (Euroamerica Press, Pittston, PA) p. 212.
18 Ibid. p. 103.
19 Ibid. p. 107.
20 Bronis J. Kasias, The USSR-German Aggression Against Lithuania, 1973. p. 257.
21 Nazi-Soviet Relations, p. 112. 16
22 Ibid. p. 113-114.
23 Ibid. p. 118-119.
24 Ibid. p. 166.
25 Ibid. p. 174.
26 Ibid. p. 267.
27 Art. IV.
28 Pravda. November 6, 1939.
30 Government, Law and Courts in the Soviet Union and Eastern Europe, vol. I (New York, Frederick and Praeger, 1959) p. 150-151.
31 Third Interim Report, p. 8.
32 "Aneksiia" Entsiklopedicheskii slovar provovykh znanii, Bratus, See also C. Bursegov. Teritoria v mezhdunarodnom prave. Moskva, 1958, p. 103.
33 Sobranie Uzakonenii i Rasporiazhenii Rabochevo Krestianskogo Pravi-telstva. December 1, 1917, No. 1.
4 Boris Meissner. "The Baltic Question in World Politics" The Baltic States in Peace and War 1917-1945. Ed. V., Stanley Vardys, Romuald J. Misiūnas. Philadelphia: Pennsylvania SUP, 1978. p. 145-146.
35 Charles G. Fenwick, International Law, 3 ed. (New York/London: Appleton-Century-Crofts. 1948) p. 671.
36 Trial of the Major War Crimes Before the International Military Tribunal. Nuremberg, 14 November 1945 — 1 October 1946.1947. vol. I. p. 194.
37 Vyriausybės Žinios (Official Gazette), No. 719.
38 Domas Krivickas, "Formalities Preliminary to Aggression. Soviet and Nazi Tactics Against Lithuania and Austria." Baltic Review No. 5, p. 5-22.
39 The Soviet Union, Finland and the Baltic States, published by the "Soviet War News" on behalf of the Soviet Information Bureau, 1941. p. 3.
40 Ibid., p. 4.
41 Soviet Information Bureau, Falsifiers of History: An Historical Note. (Moscow, 1948) p. 48-49.
42 Gregory Meiksins, The Baltic Riddle: Finland, Estonia, Latvia, Lithuania. (New York, L. B. Fisher, 1943) p. 161.
43 Sovetskaia Moldavia, October 20, 1957.
44 Krystina Marek, Identity and Continuity of States in Public International Law. (Geneva, Librair E. Droz, 1954) p. 389.
45 A. M. Andreiev, Borba Litovskogo naroda za sovetskuiu vlast (The Struggle of the Lithuanian People for the Establishment of the Soviet Regime) (Moscow, 1954) p. 44f.
46 Zigmas Angarietis. "Ar viskas taip buvo?" Komunaras (No. 6,1922) p. 67. Quoted from A. Tarulis. Soviet Policy Toward Baltic States 7978-7940. (Notre Dame: University of Notre Dame Press, 1959) p. 47.
47 Department of State Bulletin, July-December, 1940, vol. Ill, p. 48.
48 H. Lauterpacht. Recognition in International Law. Cambridge, University Press, 1947 p. 420.
49 William J. Hough, III. "The Annexation of the Baltic States and its Effect on the Development of Law Prohibiting Forcible Seizure of Territory." New York Law School Journal of International and Comparative Law, (v. 6, No. 2. Winter 1985) p. 334-335.
50 David Kirby. Morality or Expediency? The Baltic Question in British-Soviet Relations 1941-1942. In the Baltic States on Peace and War 1917-1945. Edited by V. Stanley Vardys and Romuald Misiūnas,. The Pennsylvania University Press, 1978, p. 163.
51 Ibid., p. 162.
52 B. Meissner. "The Baltic Question in World Politics", op. cit. p. 104.
53 European Parliament 1982-1983. Minutes of Proceedings of the Sitting of 13 January 1983.
54 Baltic States Investigation, op. cit., p. 4.
55 William J. H. Hough, III. op. cit., p. 480-481.