My Lord, the next page deals with a specific case illustrating the matter set out above. It is in the first paragraph of that page, the third sentence:

“The sinking of the City of Benares on the 17th September 1940 is a good example of this. The City of Benares was an 11,000-ton liner with 191 passengers on board, including nearly 100 children. She was torpedoed without warning just outside the ‘war zone,’ with the loss of 258 lives, including 77 children. It was blowing a gale, with hail and rain squalls and a very rough sea when the torpedo struck her at about 10 p. m. In the darkness and owing to the prevailing weather conditions, at least four of the 12 boats lowered were capsized. Others were swamped and many people were washed right off. In one boat alone 16 people, including 11 children, died from exposure; in another 22 died, including 15 children; in a third 21 died. The point to be emphasized is not the unusual brutality of this attack but rather that such results are inevitable when a belligerent disregards the rules of sea warfare as the Germans have done and are doing.”

I think the rest of that paragraph is not important.

I turn to the next document, 641(c), which is part of Exhibit GB-191.

THE PRESIDENT: It is clear, I suppose, from that statement of facts that there was no warning whatever given?

COL. PHILLIMORE: No, My Lord.

THE PRESIDENT: We think that you should read the next paragraph too.

COL. PHILLIMORE: If Your Lordship pleases.

“There are hundreds of similar stories, stories of voyages for days in open boats in Atlantic gales, of men in the water clinging for hours to a raft and gradually dropping off one by one, of crews being machine-gunned as they tried to lower their boats or as they drifted away in them, of seamen being blown to pieces by shells and torpedoes and bombs. The enemy must know that such things are the inevitable result of the type of warfare he has chosen to employ.”

My Lord, the rest is very much to the same general effect.