The twelfth year of the Permanent Court of International Justice has not been marked by a large number of judgments and opinions, but in the Eastern Greenland Case the Court had the greatest triumph which it has achieved down to this time. During the year 1933, the Court was in session for 178 days. The 26th session of the Court, which had begun on October 14, 1932 and in which a recess was taken on December 16,1932, was resumed on January 16, 1933, and continued until April 5, 1933. The 27th session, the ordinary annual session, began on February 1 and continued until April 19, 1933. The 28th session was held from May 10 to May 16, and the 29th session from July 10 to July 29,1933. The 30th session began on October 20, 1933, and continued until December 15,1933.

John Smith, an American citizen, is engaged in a profitable local business in a foreign country. He unexpectedly receives information from a reliable source that the people of the vicinity plan to attack and destroy his establishment within twenty-four hours. Smith at once imparts this information to the local authorities, who take no steps whatever to protect him. The threatened attack occurs and his business is either severely damaged or ruined. It is obvious that we have here a case for diplomatic representations. A foreigner residing in a friendly state has suffered injury to his property at the hands of the nationals of that state, under conditions where national responsibility attaches. The state of residence has failed to meet its international duty of taking adequate steps to afford the resident foreigner the protection of the local law; in other words, it has not been diligent in attempting to prevent the perpetration by its nationals of acts violative of the local law directed against the foreigner and resulting in injuries to his business interests.

The first phase of the dispute between China and Japan before the League of Nations began in September, 1931, when China, following upon the invasion of Manchuria by Japanese troops, invoked Article 11 of the Covenant and asked the Council to take measures to restore the territorial status quo and to determine the amount and the character of the compensation due to her as the result of the invasion of her territory. It ended in April, 1933, when, subsequently to the adoption by the Assembly of a report under Article 15 of the Covenant, it became clear that no effective action would be taken to implement the purposes of the Covenant. The charter of the community of nations organized in and through the League proved, to all appearances, to be of illusory value in its fundamental aspect, namely, in the undertaking to protect the members of the League from external violence and aggression. The prediction of the sceptics that the authority of the League would be unable to assert itself if challenged by one of the Great Powers seemed to have been amply confirmed. It seemed to have been fulfilled by a successful defiance of the Covenant so unprecedented in its magnitude, obviousness and persistence as to constitute a fair test case of the value and of the potentialities of the League.

Since the reasoned decisions of international arbitral tribunals are tending constantly to influence, in larger degree, the development of a sound body of international law, a broad interest naturally attaches to the decisions resulting from any such general claims arbitration as that of the Governments of the United States and Panama which was concluded on June 30, last.

The power of making laws with respect to immigration into Canada is given by the British North America Act to the Parliament of Canada. But under the provisions of the same act the legislature in each province may make laws in relation to immigration into the province which shall “have effect in and for the Province as long and as far only as” they are “not repugnant to any Act of the Parliament of Canada.” This power of a provincial legislature is not without restrictions, for the “Governor-General of Canada in Council within one year of the receipt of an authentic copy of an Act of a Provincial Legislature may disallow the Act, in which case the Act is annulled from and after the day on which the Lieutenant-Governor of the Province signifies the disallowance by Speech or Message to the Legislature or by Proclamation.”

It is interesting to know that a hundred years before the well-known attempt of Great Britain to stop corn on its way to the French, on the ground ridiculed by Woolsey, that the republic had incorporated its whole laboring class in its army, a similar attempt was made under Queen Anne, though not on the same ground, but rather as an appeal ad misericordiam. Henry Boyle, Secretary of State, wrote on April 12,1709, to Daniel Pulteney, then British Minister in Denmark (see Record Office, Foreign Entry Book, 4) as follows.

In June, 1929, James Pugh, an Irish seaman, was arrested in a bar in the city of Colon, Republic of Panama, because of his belligerent attitude toward two policemen and his refusal to pay a bill. On the way to the police station a serious fight occurred, the circumstances of which were in dispute. Pugh died shortly thereafter. The Panamanian judicial investigation of the affair acquitted the two policemen of criminal responsibility for Pugh’s death, a result which apparently was not satisfactory to the British Government, for in July, 1930, a formal request was made upon the Government of Panama by the British Government for an indemnity of ®1,000 on behalf of the children of the deceased, based upon the allegation that his death had been caused by unjustified acts of Panamanian policemen in beating him and dissatisfaction with the manner in which the police agents had been tried.

In 1932, representatives of the legal practitioners, the judges, the law schools and the legal and diplomatic departments of the governments, founded the Australian and New Zealand Society of International Law, with the object of fostering in Australia the study of public and private international law, particularly the study of those topics which affect, or are likely to affect, Australia or New Zealand. The First Annual Conference was held at the Sydney University Law School from Thursday, August 17, until Saturday, August 19, 1933.