# Example — verifying citations end-to-end Two worked examples: one for Nuremberg, one for Tokyo. Illustrative, not scripts. --- ## Example A — A Nuremberg citation (the famous "men, not abstract entities" passage) ### The request The user is drafting a chapter and writes: > "As Nuremberg famously held, 'crimes against international law are committed by men, not by abstract entities.' Can you give me the citation with the page?" ### Step 0 — Identify the document The quoted passage is from the **IMT Judgment** (the four-power trial of the major war criminals, 1945-46) — not from any of the subsequent NMT cases, and not from the IMTFE. It appears in the section of the Judgment dealing with the law of the Tribunal — specifically the response to the *nullum crimen* objection and the doctrine of individual criminal responsibility. ### Step 1 — Plan the citation One quoted passage; one citation needed. The preferred form: > *Judgment of the International Military Tribunal*, in *Trial of the Major War Criminals before the International Military Tribunal*, Vol. XXII (Proceedings), pp. [n] (Nuremberg 1948). ### Step 2 — Verify 1. **Avalon Project** (`https://avalon.law.yale.edu/imt/judgen.asp`). The Judgment transcription is searchable; locate the passage. Found in the section on the law of the Charter and individual criminal responsibility. **Content verified.** 2. **Harvard Nuremberg Trials Project** (`https://nuremberg.law.harvard.edu/`) for cross-check. 3. **Blue Series Vol. XXII** (via Library of Congress digitisation). Open Vol. XXII and locate the section reproducing the Judgment (delivered in the session of 30 September – 1 October 1946; in Vol. XXII it begins around page 411). Find the passage at a specific page. **Page verified.** 4. Cross-check spelling and wording against both Avalon and Blue Series. Standard wording: "**Crimes against international law are committed by men, not by abstract entities, and only by punishing individuals who commit such crimes can the provisions of international law be enforced.**" ### Step 3 — Draft > The IMT held: "Crimes against international law are committed by men, not by abstract entities, and only by punishing individuals who commit such crimes can the provisions of international law be enforced." *Judgment of the International Military Tribunal*, in *Trial of the Major War Criminals before the International Military Tribunal*, Vol. XXII (Proceedings), p. [verified page] (Nuremberg 1948). If the precise page was not pinned down: > The IMT held: "Crimes against international law are committed by men, not by abstract entities, and only by punishing individuals who commit such crimes can the provisions of international law be enforced." *Judgment of the International Military Tribunal*, 30 September – 1 October 1946, in *Trial of the Major War Criminals*, Vol. XXII (Proceedings), Nuremberg 1948 (the specific page within Vol. XXII was not confirmed in this session; the passage was verified against the Avalon Project transcription and the Blue Series). ### Step 4 — Self-audit - IMT (not NMT, not IMTFE)? Yes. - Wording exact? Yes (verified against Avalon and the Blue Series). - Citation form correct? Yes. - Verification level disclosed? Yes (in the alternative form). --- ## Example B — A Tokyo citation (the Pal dissent on aggressive war) ### The request The user is writing on the post-colonial critique of international criminal law and asks: > "Can you give me a citation for Justice Pal's view that aggressive war was not a crime under international law before the Tokyo Trial?" ### Step 0 — Identify the document The proposition concerns the **Pal dissent** at the IMTFE. This is **a dissenting opinion** at the Tokyo Trial — not the majority Judgment. Critical distinction: - The majority IMTFE Judgment **affirmed** jurisdiction over crimes against peace and held that aggressive war was already a crime under international law. - Justice Radhabinod Pal **dissented**, holding that aggressive war was not a crime under international law in 1928-1945 and that the prosecution was retroactive (*ex post facto*). If we attribute Pal's view to "the IMTFE", we miscite the Tribunal. ### Step 1 — Plan the citation One citation needed. The form: > *Dissentient Judgment of Justice Radhabinod Pal* (IMTFE, 1948), in *The Tokyo War Crimes Trial*, ed. R. J. Pritchard & S. M. Zaide, Vol. 21 (Separate Opinions), pp. [n] (New York: Garland Publishing 1981). ### Step 2 — Verify 1. **University of Virginia IMTFE Digital Collection** (`https://imtfe.law.virginia.edu/`). Locate Pal's separate opinion. **Existence verified.** 2. **ICC Legal Tools Database** — Navigate to "Other International(ised) Criminal Jurisdictions" > "IMTFE". Locate the separate opinions. Cross-check. 3. **Pritchard-Zaide Vol. 21** for paginated pinpoint. The dissent is long (over 1,000 pages of original typescript, condensed in publication); identify the specific section on the legality of aggressive war. 4. Where possible, verify the wording of any specific quote against the Pritchard-Zaide text. ### Step 3 — Draft > Justice Radhabinod Pal, dissenting at the IMTFE, held that aggressive war was not a crime under international law at the time of the acts charged and that the prosecution was retroactive. *Dissentient Judgment of Justice Radhabinod Pal* (IMTFE, 1948), in *The Tokyo War Crimes Trial*, ed. Pritchard & Zaide, Vol. 21 (Separate Opinions) (Garland 1981). The majority Judgment of the IMTFE took the contrary view and affirmed jurisdiction over crimes against peace. *Judgment of the International Military Tribunal for the Far East*, 4-12 November 1948, in Pritchard-Zaide Vol. 20. ### Step 4 — Self-audit - IMTFE (not IMT)? Yes — Pal is Tokyo. - Majority vs dissent? Correctly identified as dissent. The reader is not invited to confuse Pal's view with the Tribunal's holding. - Pritchard-Zaide volume? Vol. 21 (Separate Opinions), correct. - Are both the dissent and the contrary majority position cited? Yes — for honesty, the reader needs both. --- ## The common thread The danger in Example A was misquoting and confusing IMT with NMT. The danger in Example B was attributing a dissent to "the Tribunal". Both are caught by Step 0 (identify the document) and Step 4 (self-audit). In international criminal law, *who said what* is as important as *what was said*.