CONCEPT OF "INTERVENTION" IN INTERNATIONAL LAW

JUDE IBEGBU

In this article, we shall discuss the concept of intervention in international Law. To this end we shall discuss the following: (1) Concept of "Intervention";" (2) forms of "intervention"; (3) domestic jurisdiction; (4) lawful and unlawful intervention.

The word "intervention" is derived from the Latin word intervenire, which means to come between According to Eppstein, it is used in international law and ethics to indicate the assistance given by one or more governments to one belligerent against another, or action taken by governments outside their own territory to bring help to individuals or to assist one or more parties to internal dissension within another State. Historically the term has been used by Christian moralists in the sense of action taken to defend others against injury in order to perform a natural obligation of human society.

In international Law, the word "intervention" is used both in a loose sense and in the strict sense. When used in the strict sense, it is illegal under international Law because it necessarily involves the threat or use of force which constitutes a breach of the UN Charter’s prohibition of use of force against a sovereign State. Thus article 2 paragraph 4 of the Charter of the United Nations states: All Members shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any State, or in any other manner inconsistent with the Purposes of the United Nations."

But generally, when used in the loose sense it is not necessarily illegal since it does not involve the use of force. However, the question of its legality when used in this sense depends on the nature of the intervention and context in which it is applied. For example article 62 of the Statute of the International Court of Justice permits States whose interest may be affected by the decision in the case to submit a request to the Court to be allowed to intervene in that case.

In any case, in the strict or technical sense of the word, the threat or use of force against a sovereign State constitutes the essence of the term "intervention" under international law. It is this type of "intervention" that is mainly prohibited under international Law. Thus the ICJ. in the Case against military and paramilitary activities stated: "The element of coercion, which defines, and indeed forms the very essence of, prohibited intervention, is particularly obvious in the case of an intervention which uses force...."

There is also consensus among international lawyers, that the essential element of the word "intervention" is threat or use of force. Potter maintained that the essential and minimum element which must be present in "intervention" is interference of one or several States in the affairs of one or several States. He affirmed that constraint is the essence of intervention, and it can be individual or collective. Also, it can take place both in the internal and external affairs of the State. It can be the act of one or of several States against one or several others. He affirmed: "The distinctive character of intervention, therefore, is the intention of the intervening State to get his claims fulfilled even if it entails at least to exercise some pressure with this end in view." It is necessary that there be on the part of the petitioning State, the intention, declared or implicit, to exercise pressure with the view to obtain reparation. Intervention does not consist in simple suggestion: it deals with a demand, followed or not by consent. All the more gentle forms of diplomatic action are excluded from this category.

Equally J. L. Brierly stated that "intervention" is used generally to express almost any act of interference by one State in the affairs of another. In a more special sense, it is limited to "acts of interference either in the domestic or the foreign affairs of another State which violate that State's independence." He added that "the interference must take an imperative form; it must either be forcible or backed by the threat of force."

Explaining what is meant by prohibition of "intervention" on the part of the United Nations in accordance with article 2 paragraph 7 of the Charter of the United Nations, Lauterpacht affirmed that it refers only to any action that is tantamount to "intervention" but does not exclude "measures falling short of intervention." He stated: "Intervention is a technical term of, on the whole, unequivocal connotation. It signifies dictatorial interference in the sense of action amounting to a denial of the independence of the State." Further, he stated that "it implies a peremptory demand for positive conduct or abstention - a demand which, if not complied with, involves a threat of or recourse to compulsion in some form." He argued that "in order to justify the use of the term "intervention" in its accepted scientific connotation there must be an attempt to "impose the will" by one State upon another in an "imperative form." Intervention therefore is "a peremptory demand accompanied by enforcement or threat of enforcement in case of non-compliance."

Oppenheim's international Law made a clear distinction between "intervention" which involves the use of force - which is the real concept of intervention in international Law- and that which does not involve the use of force. It maintained that although States often use the term "intervention" loosely to include such matters as criticism of the conduct of another State, it has a stricter meaning in international law, according to which, "intervention is forcible or dictatorial interference by a State in the affairs of another State, calculated to impose certain conduct or consequences on that other State." It emphasised that for an interference to constitute "intervention" it "must be forcible or dictatorial or otherwise coercive."Since acts like granting or withholding recognition of government, good offices, various forms of co-operation, making representations, or protesting against an alleged wrongful act of a State, are not forcible or dictatorial, they do not constitute intervention. Likewise other acts like severing of diplomatic relations with another State, discontinuance of exports to it or withdrawal of a programme of aid, organising a boycott of its products, do not constitute a commission of an act of intervention by a State.Interference which is coercive enough as to amount to intervention "may involve the use of armed force in the direct form of military action, or in a more indirect form as where support is given to subversive or terrorist armed activities in another State."

In conclusion we maintain that in line with the other authors considered above Oppenheims international Law equally held that the concept of "intervention" in international Law necessarily involves an element of force.

Stowell while maintaining that intervention must involve the use of force affirms that for it to be legitimate it must follow the procedure recognised by States before it is used against a State. He maintained that for a long time, the word, "intervention" has been used in the interventional affairs in order to designate the recourse to some measures of force, either by ways of act, or under the form of threat, with the view to getting the other States to adopt a certain line of conduct or put an end to some hostilities or other undesirable activities. Defining "intervention" from the point of view of international law he stated that "intervention" is "the juridical use of force with regard to another State or to its nationals in order to ensure the respect of international law."

He maintained that if we accept this definition, it is first of all necessary to understand what the juridical or legal use of force means. Of course, force cannot be used in the juridical sense, unless it is used in conformity with the recognised procedure to be followed meticulously, the rules of procedure practised by the States in their reciprocal relationships at each of their stages. Besides, it is necessary to note that the force duly applied must, according to the recognised procedure, be legitimate, that is to say used in order to ensure the enforcement of a recognised principle of international law. Because that is, indeed, a principle which one discovers in the practice of States, a principle normally observed, and moreover furnished by sufficient sanction in order to compel its observation by whoever would wish to evade it.

Intervention according to Stowell therefore, would not be legitimate unless it is used in accordance with the procedure followed by States. Under the current international law, one of these procedures followed by States for the legitimacy of intervention is that peaceful means should be used first to obtain compliance from the State. These peaceful means include, diplomatic appeals, peaceful means of settlement of disputes which include recourse to international Court of Justice etc. and when these procedures have failed to make the offending State comply, then intervention becomes the last resort.

From the above consideration we can conclude that the essential element of the concept of intervention is that it must involve the use or threat of force and for it to be legitimate its use must be preceded by peaceful measures to make the offending State comply with its international obligation.

Brierly maintains that the word "intervention" is often used quite generally to express almost any act of interference by one State in the affairs of another; but in a more special sense it is restricted to acts of interference either in the domestic or the foreign affairs of another State which infringes that State’s independence. Consequently, "a mere tender of advice by one State to another about some matter within the competence of the latter to decide for itself, would not be an intervention in this sense; the interference must take an imperative form; it must either be forcible or backed by the threat of force." Thus, not only must intervention always involve the use of force but also it must be effectuated on a matter which is within the domestic jurisdiction of the State.

In every type of intervention, force or coercion must be present, but not all forcible interventions are prohibited in international law. For example intervention of the UN for the enforcement measures of the Security Council is not illegal. Nor intervention in the exercise of the right to self-defence illegal nor is provision of humanitarian aid by a third State to subjects of a State in a civil war an illegal intervention. From this clarification it follows that not every type of intervention is illegal and therefore not every type of intervention is prohibited under international law.

There are two essential elements in the concept of intervention. First, it must involve a threat or use of, force. Secondly the object of intervention must be a matter which is within the domestic jurisdiction of the targeted State It is these two elements that make intervention an unlawful act in international law. Thus, as a matter of principle, "intervention" is prohibited in international law.

Intervention should be distinguished from war. Unlike war, intervention has the purpose of attaining a specific objective, for example, to stop genocide or mass killings occurring within the territory of another State.

From the above considerations, we can define "intervention" as direct or indirect, an individual or collective threat or use of force against another State in a matter which is within its domestic jurisdiction .

We shall proceed to discuss all the various forms of intervention.

PREAMBLE

From the above consideration, it can been seen that intervention can take various forms. It can be armed or non-armed; it can also be forceful but not armed. It can be direct or indirect, unilateral or collective. Finally, intervention can also be defensive. We shall consider these various forms of intervention in this section. First we will consider the various forms of armed or military intervention by discussing the following: (1) Forms of armed or military intervention (2) Forms of intervention without force.

2.1. FORMS OF ARMED OR MILITARY INTERVENTION

2.1.1. ARMED OR MILITARY INTERVENTION

Armed or military intervention is intervention by armed troops of a foreign State within the territory of another sovereign State. Armed intervention can take the form of land or air or sea attack or all combined, by a State against another sovereign State.

Armed -intervention can be effectuated by air, land , sea attack or all three combined in order to achieve a particular objective. It involves the intrusion into the territory of another State. According to Fawcett, "the notion of intervention connotes the intrusion of alien forces into a political community, and generally their crossing of a national frontier."

2.1.2. DIRECT AND INDIRECT MILITARY INTERVENTION

Military intervention can be either direct or indirect. Thus the ICJ in the Case against military and paramilitary Activities stated:"…prohibited intervention, is particularly obvious in the case of an intervention which uses force, either in the direct form of military action, or in the indirect form of support for subversive or terrorist armed activities within another State....General Assembly resolution 2625 (XXV) equates assistance of this kind with the use of force by the assisting State when the acts committed in another State ‘involve a threat or use of force.’".Armed intervention can therefore be either direct or indirect. We shall first discuss direct military intervention and later indirect military intervention.

2.1.2.1. DIRECT MILITARY INTERVENTION

Military intervention is direct when a State or group of States intervenes militarily and directly in the territory of another State in order to compel it to comply with the demand of the intervening State or States which may be to fulfil its international obligation. Thus the ICJ in the Case against military and paramilitary Activities stated:"…prohibited intervention, is particularly obvious in the case of an intervention which uses force… in the direct form of military action…." Military intervention can be carried out through air or land or sea attack or all three combined.

2.1.2.2. INDIRECT OR SUBVERSIVE MILITARY INTERVENTION

Indirect or subversive armed intervention as distinguished from direct armed intervention takes place when a State or a group of States indirectly engages in a military action against another State, through terrorist groups supported and controlled by the intervening State or States. Thus the ICJ in the Case against military and paramilitary activities stated:"…prohibited intervention, is particularly obvious in the case of an intervention which uses force… in the indirect form of support for subversive or terrorist armed activities within another State." Fawcett stated that "subversive intervention may be carried forward by irregular or self-organised groups, already in the territory but subject to the control of a neighbouring State."

The use of force by such units or bands, with the aim of ‘subverting the will of the people’ and weakening of, or overthrowing the established political order of another State, constitutes an act against the political independence of that State in contravention of article 2, paragraph 4, of the Charter of the United Nations. In so far as it sends these units or bands, or encourages or tolerates their crossing the frontier, or assists them when they are already in the territory, of the other State, a State will be using such force.

Indirect or subversive intervention is also a violation of the principle of non-intervention. Thus, the ICJ in the Nicaragua Case stated: "The Court considers that in international law, if one State, with a view to the coercion of another State, supports and assists armed bands in that State whose purpose is to overthrow the government of that State, that amounts to an intervention by the one State in the internal affairs of the other, whether or not the political objective of the State giving such support and assistance is equally far-reaching."

2.1.3. UNILATERAL MILITARY INTERVENTION

Military intervention can either be unilateral or collective. Unilateral military intervention occurs when only a State or a group of States intervenes militarily in the territory of another State without the authorisation of the UN Security Council. The objective may be humanitarian, such as, intervention to protect the citizens of the targeted State who are victims of massive human rights violations.

2.1.4. COLLECTIVE MILITARY INTERVENTION

Collective military intervention occurs when a group of States launches an armed attack against another sovereign State is order to achieve a specific objective for example to compel the State to comply with its international obligation.

Collective military intervention can be legal or illegal depending on whether it is undertaken with or without the authorisation of the UN Security Council.

2.1.4.1. UN COLLECTIVE MILITARY INTERVENTION

Article 2 paragraph 7 of the UN Charter states: "Nothing contained in the present Charter shall authorise the United Nations to intervene in matters which are essentially within the domestic jurisdiction of any State or shall require the Members to submit such matters to settlement under the present Charter; but this principle shall not prejudice the application of enforcement measures under Chapter VII."

Although the exception to the principle of non-intervention contained in article 2 paragraph 7 of the Charter refers to the application of enforcement measures under chapter VII, however, in so far as these measures involve the use of force against the will of a sovereign State concerned in a matter which is within its domestic jurisdiction in our view they constitute UN collective intervention. Thus, article 2 paragraph 7 expressly prohibits the UN from intervening in matters which are within the domestic jurisdiction of States but makes enforcement measures under chapter VII an exception to this prohibition. Thus Fawcett stated: "Collective intervention under the Charter is an aspect of intervention , distinct from the intervention as a measure of collective self-defence. The Charter term ‘enforcement action,’ would include what may well be intervention on force...." Their legality is what differentiates them from any other type of collective intervention not authorised by the UN Security Council. However, their legality does not change their nature as intervention. It is therefore logical to describe these collective enforcement measures as lawful collective intervention. Thus, UN enforcement measures are lawful intervention.

Article 42 of chapter VII empowers the UN Security Council to authorise the Member States of the United Nations to take military action when non-armed forceful measures stated in article 41 are not sufficient to maintain or restore international peace and security. It states: "Should the Security Council consider that measures provided for in Article 41 would be inadequate or have proved to be inadequate, it may take such action by air, sea or land forces as may be necessary to maintain or restore international peace and security. Such action may include demonstrations, blockade, and other operations by air, sea or land forces of Members of the United Nations." Such military action when carried out by States is an example of collective intervention.

An example of collective armed intervention authorised by the UN Security Council was the intervention of the UN Member States to expel the illegal regime that seized power from the democratically elected government of Haiti in 1994. Under Resolution 940 (1994) of 31 July 1994, the Security Council, while determining that the situation in Haiti continued to constitute a threat to peace and security in the region, stated: "Acting under Chapter VII of the Charter, authorises Member States to form a multinational force under unified command and control and, in this framework, to use all necessary means to facilitate the departure from Haiti of military leadership, consistent with the Governors Island Agreement, the prompt return of the legitimately elected President and the restoration of the legitimate authorities of the Government of Haiti, and to establish and maintain a secure and stable environment that will permit implementation of the Governors Island Agreement, on the understanding that the cost of implementing this temporary operation will be borne by the participating member States..."

The UN peace-keeping programmes are not technically speaking intervention since they do not involve the use of force except for self –defence and they are undertaken only with the consent of the State involved.

Regional collective intervention can be legal or illegal depending on whether they are authorised by the UN Security Council or not in accordance with article 53 paragraph 1 of the Charter which states:"...no enforcement action shall be taken under regional arrangements or by regional agencies without the authorisation of the Security Council...."

2.1.5. DEFENSIVE MILITARY INTERVENTION

If permissible action taken in exercise of the right of individual or collective self-defence includes also a degree of intervention, that intervention is itself justified on the basis of self-defence. Thus article 51 of the Charter of the United Nations embodies the right to defensive intervention. This article states: "Nothing in the present Charter shall impair the inherent right of individual or collective self-defence if an armed attack occurs against a Member of the United Nations, until the Security Council has taken measures necessary to maintain international peace and security."

Thus, when a State is attacked by another State, in accordance with the right to self defence, the State which is the victim of armed attack has the right to repel the invader irrespective of the fact that the self-defence may entail intervention in order to counter it. This is in accordance with the exercise of right to individual self-defence recognised in article 51 of the Charter.

Also the State attacked has the right to request other States to assist it to defend itself against the unjust aggressor and to expel it from its territory if it is unable to so alone. When this obtains, the victim State together with the other States assisting it while exercising their right to individual and collective self-defence, also exercise their right to defensive intervention.

2.1.6. HUMANITARIAN INTERVENTION

Humanitarian intervention obtains when a State or a group of States - with or without the authorisation of the United Nations Security Council – or when UN forces established by the UN Members with the mandate of UN Security Council intervene within the territory of another State in order to achieve a particular humanitarian objective. The objective must be humanitarian, for example to prevent or stop a State from perpetrating genocide or mass killings or committing other atrocities that shock the conscience of humanity.

Having considered the different forms of armed or military intervention, we shall now discuss the forceful non-military intervention.

Besides armed intervention there can also be forceful non-armed intervention; that is intervention that is not armed, but at the same time is forceful. When there is forceful non-armed intervention, there is a use of force that is not armed. This obtains when States take forcible actions that are not armed, against a State, in order to make the State fulfil its international obligation, diplomatic representations, economic embargo

3.1. COLLECTIVE FORCEFUL NON-MILITARY INTERVENTION

Collective non-armed forceful intervention obtains when a group of States together intervenes militarily within the territory of another State for the same objectives. Collective non-armed intervention may or may not be authorised by the UN Security Council. It is authorised by the UN Security Council when, after the Security Council determines that a situation is a threat or a breach to international peace and security the Security Council under chapter VII authorises the Member States to use the enforcement measures stated in article 41 of chapter VII of the Charter. In fact, article 2, paragraph 7, of the Charter stipulates that this intervention is an exception to the prohibition of intervention by the UN in the matters which are within the domestic affairs of the State. Thus article 41 of Chapter VII states: "The Security Council may decide what measures not involving the use of armed force are to be employed to give effect to its decisions, and it may call upon the Members of the United Nations to apply such measures." Giving examples of these types of non-armed forceful intervention it states: "These measures may include complete or partial interruption of economic relations and of rail, sea, air, postal, telegraphic, radio and other means of communications, and the severance of diplomatic relations."

When there is intervention without force, there is neither military intervention nor forceful non-military intervention since neither arms nor force without the use of arms is employed. This type of intervention is therefore neither armed nor forceful. This is not intervention in the technical sense of the word therefore it is not prohibited under international Law. Thus, the UN can lawfully resort to different forms of intervention without force, in order to protect human rights. Thus, Oppenheim’s international Law stated: "Although article 2(7) of the Charter provides that it does not authorise the United Nations to intervene with regard to matters which are essentially within the domestic jurisdiction of States, that provision does not exclude action, short of dictatorial interference with the view to implementing the purposes of the Charter. Thus with regard to the protection of human rights and freedoms - a prominent feature of the Charter -, the prohibition of intervention does not preclude study, discussion, investigation and recommendation on the part of the various organs of the United Nations."

This type of intervention can be: public condemnations of human rights violations by a State by political leaders, diplomatic representations. Some Human Rights instruments have provisions for inter-State complaint for the State Parties. Thus article 41 paragraph 1 of the International Covenant on Civil and Political Rights 1966 states: "A State Party to the present Covenant, may at any time declare under this Article that it recognises the competence of the Committee to receive and consider communications to the effect that a State Party claims that another State Party, is not fulfilling its obligations under the recent Covenant." They can also take the form of legal action against the offending State in international Courts like the International Court of Justice or condemnations of human rights violations by quasi international judiciary organs like human rights commissions etc. These types of intervention are neither armed intervention nor non-armed forceful interventions and are therefore not prohibited under international Law. Any State can resort to them in order to protect human rights in accordance with the norm of obligation erga omnes of the principles of human rights.

Intervention without force can also take place when a third State, not directly involved in the case, intervenes in that case, in order to protect its interest. This type of intervention is exemplified in the definition of "intervention" given by the Black’s Law Dictionary. Defining "intervention" it states: "The procedure by which a third person, not originally a party to the suit, but claiming an interest in the subject matter, comes into the case, in order to protect his right or interpose his claim....Intervention may exist either as a matter of right ...or at the discretion of the court.." Thus article 62 paragraph 1 of the Statute of the International Court of Justice states: "Should a State consider that it has an interest of a legal nature which may be affected by the decision in the case, it may submit a request to the Court to be permitted to intervene."

On account of obligation erga omnes of human rights, any breach of these rights affects the legal interest of every State. Consequently, every State has the right to intervene in any suit filed before the International Court of Justice which deals with human rights violations. This is the logical consequence of obligation erga omnes of human rights.

In principle, these types of non-forcible interventions are those which are legitimate for the protection of human rights by all States when the violations do not amount to genocide or mass killings. But when human rights violations are tantamount to genocide or mass killings, in accordance with the norm of the principles of obligation erga omnes human rights and humanitarian law, States have the right to undertake humanitarian intervention to prevent or stop such crimes provided among other things, they have the authorisation of UN Security Council and they respect the principle of proportionality and observe international humanitarian Law. Their right to intervene arises from the norm of obligation erga omnes of human rights in international Law. We shall now proceed to discuss another element of prohibited intervention which is that the matter for which intervention is undertaken must be within the domestic jurisdiction of the targeted State.

A prohibited intervention must also deal with a matter which is within the domestic jurisdiction of the targeted State. Thus in the Nicaragua Case the ICJ stated:" A prohibited intervention must accordingly be one bearing on matters in which each State is permitted, by the principle of State sovereignty, to decide freely. One of these is the choice of a political, economic, social and cultural system, and the formulation of foreign policy. Intervention is wrongful when it uses methods of coercion in regard to such choices, which must remain free ones. Intervention therefore cannot be justified if it deals with a matter which is solely within the domestic jurisdiction of a State.

It is therefore necessary to explain the meaning of the phrase "solely within the domestic jurisdiction" of the State." In the Advisory Opinion on Nationality Decrees in Tunis and Morocco, 1923, the P.I.C.J. stated:" From one point of view, it might well be said that the jurisdiction of a State is exclusive within the limits fixed by international law.... The words "solely within the domestic jurisdiction" seem rather to contemplate certain matters which, though they may very closely concern the interests of more than one State are not, in principle, regulated by international Law. As regards such matters, each State is sole judge." The same view is maintained by doctrine. Thus Brownlie affirmed that matters which are within the competence of States under general international Law are regarded "to be within the reserved domain, the domestic jurisdiction of States." He further stated that the general view is that the "reserved domain" is the domain of State activities where the jurisdiction of the State is not under the obligation of international law. The extent of this domain depends on international law and varies in accordance with its development. Equally Schachter explained that "domestic jurisdiction" is a concept "intended to mark the boundary between matters governed by international law and those left exclusively to the national State."

However, in international Law, it is a generally accepted rule that once a State assumes an international obligation on a particular matter, that matter automatically ceases to be within the domestic jurisdiction of that State.

It follows from the foregoing that "intervention" must involve the use of force in a matter which is within the reserved domain of domestic jurisdiction of the targeted State.

PREAMBLE

We find it necessary to make a further distinction between lawful and unlawful intervention.

6.1. LAWFUL INTERVENTION

6.1.1. NECESSARY CONDITIONS FOR LEGALITY OF INTERVENTION

There are conditions under which intervention can be justified in international Law. However, in such exceptional cases the intervening State is nevertheless subject to certain restrictions as to the manner and circumstances of its intervention. Especially, it must act consistently with the prohibition against the use or threat of force laid down in the United Nations Charter. Its actions must be proportional to the circumstances causing the intervention and other means of changing the situation like diplomatic representations must be shown to have been unsuccessful or to be so unlikely to succeed as to make resort to them unnecessary. Besides, any justification for intervention, being an exception to a fundamental rule of international law, has to be applied rigorously. Finally, it is indispensable that the intervening State or States should have obtained the authorisation of the UN Security Council.

On the other hand lawful intervention is any intervention without force. Enforcement measures stated in chapter VII of the Charter for maintenance of international peace and security are lawful intervention. This can take the form of collective armed intervention authorised by the UN Security Council on universal or regional levels. Collective lawful intervention at universal level is undertaken by collective forces formed by the Members of the United Nations with the mandate of the UN Security Council.

Lawful regional intervention obtains when enforcement action taken under regional arrangements or by regional agencies with the authorisation of the UN Security Council intervenes to maintain or restore international peace and security. Also included among lawful intervention are all types of intervention without force.

6.2. UNLAWFUL INTERVENTION

An unlawful intervention must be military, or forceful non-military intervention. It must also deal with a matter that is solely within the domestic jurisdiction of the State.

It must be unilateral and carried out by a State or group of States acting in their individual capacity, without the authorisation of the UN Security Council. This type of intervention is unlawful not only because it is involves the use of military force, but also because it is unauthorised by the Security Council. Thus, this type of intervention is not only a breach of article 2 paragraph 4 of the UN Charter but also a breach of the principle of non-intervention.

Therefore with the exception of intervention without force, defensive intervention and collective intervention authorised by the UN Security Council for the maintenance of international peace and security, all the other forms of intervention, in so far as they involve the use of force and deal with a matter which is solely within the domestic jurisdiction of a State, are prohibited under international law.

CASES

Case concerning military and paramilitary Activities in and against Nicaragua 1986.

Advisory Opinion on Nationality Decrees issued in Tunis and Morocco, (1923), Series B, No. 4.

WORKS

ENCYCLOPEDIAE AND DICTIONARIES