The American Society of International Law celebrated last April its thirty-fifth anniversary. It can, therefore, scarce claim the prestige of an ancient and time-honored institution. Notwithstanding this fact, however, in the thirty-five years of its existence theinternational law which it was founded to promote, to expound and to develop, has hadanextraordinarily dramatic existence. Let us look at some of the high lights on this lawduring its historic years from 1906 to the present time.

The above question has been raised in the present European conflict, particularly in connection with the use of parachute troops. At the time of the German invasion of France and the Low Countries, many of the German parachute troops who landed behind the Allied lines in those countries and there proceeded to destroy important military objectives or to seize and hold them until joined by reinforcements, allegedly wore Belgian or Netherland uniforms.

Recently, certain small uninhabited islands in the central Pacific Ocean have assumedsudden importance for the British Empire and the United States. Their value as landing places for commercial aviation and as strategic bases for air and naval forces is being increasingly recognized. Acquired during the past century by Great Britain and the UnitedStates, many of these islands have been the object of conflicting claims to sovereignty by the two nations. To clarify their status, it has been found desirable to review the past practice of these states and to examine those factors which were considered adequateto create sovereign rights over uninhabited islands in the Pacific.

It is impossible to deny that the early rule of international law was that the head of state, either directly or through his agents, was alone competent to make treaties, which were binding upon his successors. This was natural at a time when no type of international agreement was known other than the treaty in solemn form to which monarchs were parties. Today, new types of agreement have come into being, to which the parties are not heads of states but either the state itself (as in the Treaty of Versailles, 1919) or governments or departments of state. In all these cases, and even in cases where the parties are formally the heads of states, the unit now considered to be bound is the state, through its organs. This substitution of states for monarchs as the subjects of the law of nations, at any rate in the matter of treaties, has been brought about very largely by the French and American Revolutions of the eighteenth century, and by the development of the notion of the state as an international person. The question of the competence to make treaties binding on states, who may by their laws have limited that competence, has therefore become one of great interest in modern theory.

The second sentence of Article 60 of the Statute of the Permanent Court of International Justice, reads: “ In the event of dispute as to the meaning or scope of the judgment, the Court shall construe it upon the request of any party.” The jurisdiction of the Court to construe its judgments is, therefore, obligatory. The Court shall give an interpretation of its judgment.whether the case decided was brought before it by unilateral application or special agreement.