“(2) Invasion by its armed forces, with or without a declaration of war, of the territory of another state;


“(3) Attack by its land, naval, or air forces, with or without a declaration of war, on the territory, vessels, or aircraft of another state;


“(4) Naval blockade of the coasts or ports of another state;


“(5) Provision of support to armed bands formed in its territory which have invaded the territory of another state, or refusal; notwithstanding the request of the invaded state, to take in its own territory all the measures in its power to deprive those bands of all assistance or protection.”

The various treaties concluded in 1933 by the Union of Soviet Socialist Republics and other states followed closely that definition. So did the draft convention submitted in 1933 by His Majesty’s Government to the Disarmament Conference.

However, it is unprofitable to elaborate here the details of the problem or of the definition of aggression. This Tribunal will not allow itself to be deflected from its purpose by attempts to ventilate in this Court what is an academic and, in the circumstances, an utterly unreal controversy as to what is the nature of a war of aggression, for there is no definition of aggression, general or particular, which does not cover and cover abundantly and irresistibly in every detail, the premeditated onslaught by Germany on the territorial integrity and political independence of so many sovereign states.

This, then, being the law as we submit it to be to this Tribunal—that the peoples of the world by the Pact of Paris had finally outlawed war and made it criminal—I turn now to the facts to see how these defendants under their leader and with their associates destroyed the high hopes of mankind and sought to revert to international anarchy. First, let this be said, for it will be established beyond doubt by the documents which you will see, from the moment Hitler became Chancellor in 1933, with the Defendant Von Papen as Reich Chancellor, and with the Defendant Von Neurath as his Foreign Minister, the whole atmosphere of the world darkened. The hopes of the people began to recede. Treaties seemed no longer matters of solemn obligation but were entered into with complete cynicism as a means for deceiving other states of Germany’s warlike intentions. International conferences were no longer to be used as a means for securing pacific settlements but as occasions for obtaining by blackmail demands which were eventually to be enlarged by war. The world came to know the “war of nerves”, the diplomacy of the fait accompli, of blackmail and bullying.