ARTICLE 23

ratifies this Convention, it makes itself party to a policy of allowing a choice to other signatories on this subject, and so should not be heard to insist that it will not permit a political or military refugee to be transported through its territory. It is true that there may be occasions when transportation of a national, or of a political or military refugee through the territory of a State might threaten violence because of a strong public opinion. It is believed that this situation can be taken care of as the result of the requirement for notice of a desire to transport an extradited person through the territory of a State, for under the circumstances suggested the notified State would request that another route be arranged and this would naturally be done. There are found no provisions in the multipartite conventions as to the expenses involved in the transportation of the extradited person through the territory of a third State. All treaties providing for transit stipulate that expenses connected with the transit shall be borne by the State to which the person is extradited. This seems a reasonable provision, as the State of transit, not taking any active part in extradition, should not be obliged to share any expense resulting from it. PART V. LIMITATIONS UPON THE REQUESTING STATE
TRIAL, PUNISHMENT AND SURRENDER OF EXTRADITED PERSON

ARTICLE 23.

(1) A State to which a person has been extradited shall not, without the consent of the State which extradited such person: (a) Prosecute or punish such person for any act committed prior to his extradition, other than that for which he was extradited; (b) Surrender such person to another State for prosecution or punishment; COMMENT Paragraph (1) of this article imposes a twofold limitation upon the requesting State's freedom of action: First, the requesting State, having obtained the extradition of the person sought may not, without the consent of the surrendering State, either try or punish such person for any act committed prior to his extradition, other than that on which the request was based. This limitation does not apply to acts committed by such a person after his surrender. Second, such person may not, without the consent of the surrendering State, be re-extradited to a third State. The limitation placed upon the requesting State that it may try and punish an extradited person only for the act for which extradition is obtained, is recognized in the international law of extradition as the doctrine of specialty.1 Many national extradition statutes condition extradition on a
1 See Moore, Extradition (1891), I,148-177, pp. 194-259, and authorities there cited; Billot, Trait de I'Extradilion(1874), pp. 308-317, 341-346. See also the Resolutions of Oxford (Iiistitutde Droit Irdernatioral),Art. 22, Appendix IV, No. 2, declaring that a government which obtains extradition for a specific act is bound, in the absence of a treaty to the contrary, not to allow the surrendered person to be tried or punished except for that act.

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guarantee (by treaty or municipal law of the requesting State) that the surrendered person will not be tried for any other act than that for which he was extradited.1 The rule on this point, enunciated in the text, is generally accepted as implied, when it is not stated, 2 and is scrupulously observed in practice even in the absence of any treaty. 3 Existing treaty-law amply supports the provision contained in paragraph (1) (a) of this article, as is shown 4 by the conventions, drafts and bipartite treaties in the appendices. Although the phraseology varies widely, the universal practice is to provide that the surrendered person may not be tried or punished for an offense committed prior to extradition, other than that for which he is extradited. Moreover, the majority of treaties provide expressly that the person surrendered may be tried or punished for another offense if the surrendering State consents thereto.5 A number of treaties provide that the surrendering State may not refuse its consent if the offense, other than that for which extradition was granted, would be extraditable under the treaty. 6 The number of treaties (13) containing such a proviso is small, and those treaties affect a comparatively narrow circle of nations (to eight out of these 13 treaties Czechoslovalda is a party). The inclusion of such a proviso in this article does not appear advisable. It seems preferable to leave it to the discretion of the surrendering State to grant or withhold its consent, rather than to impose on it an absolute duty. It may reasonably be assumed that the surrendering State, guided by a spirit of international cooperation in the repression of crime, will not withhold its consent if the offense would be extraditable under this Convention. The surrendering State would have little interest in impeding the
E.g. (references are to Appendix VI): Canada, 33, No. 4; France, Art. 7, No. 6; Germany, Art. 6, No. 7; Great Britain, 3 (2), No. 8; Italy, Code of Criminal Procedure, Art. 661, No. 10; Switzerland, Art. 7, No. 13. 2 United States v. Raucher (1889), 119 U. S. 407. 3 Thus the German Supreme Court allowed an appeal from the conviction for the unlawful export of horses when the person was surrendered, without a treaty, by Czechoslovakia for
1

larceny and theft. Reichsgericht decision of April 4, 1921. Entscheidungen des Reichsgerichts in Strafsachen, 55, 284; Annual Digest of Public International Law Cases, 1919-1922, p. 259, Case 182. 4 Appendices I I, IV, V. The following treaties do not provide for trial and punishment with the consent of the surrendering State for offenses other than that for which extradition is granted (references are to Appendix I): The treaties of the United States with: Siam, No. 7; Venezuela, No. 13; Latvia, No. 14; Estonia, No. 15; Finland, No. 23; Bulgaria, No. 24; Lithuania, No. 26; Czechoslovakia, No. 31; Poland, No. 57.-(It should be noted, however, that consent of the surrendering State is provided for in the treaties of the United States with Germany, Art. 5, No. 70; and with Austria, Art. 4, No. 71); the treaties of Great Britain with: Latvia, No. 20; Finland, No. 25; Czechoslovakia, No. 26; Estonia, No. 30; Lithuania, No. 46; Albania, No. 47; Iraq, No. 93; Brazil-Paraguay, No. 8; Latvia-Denmark No. 79. See also the South American Convention of 1911, Appendix III, No. 4; Field's ode, Appendix IV No. 1; International Law Association Draft, Appendix IV, No. 5; International Penal and Prison Commission Draft, Appendix IV, No. 6; the extradition statutes of Canada, Appendix VI, No. 4, and of Great Britain, Appendix VI, No. 8. 6 (References are to Appendix I): Finland-Latvia, Art. 8, No. 21; Rumania-Czechoslovakia, Art. 12, No. 36; sonia-Czechoslovakia, Art. 13, No. 37; Latvia-Czechoslovakia, Art. 13, No. 38; Bulgaria-Czechoslovakia, Art. 13, No. 39; Greece-Czechoslovakla, Art. 13, No. 50; Spain-dzechoslovakia, Art. 14, No 51; Portugal-Czechoslovakia, Art. 14, No. 52; Hungary-Yugoslavia, Art. 6, No. 61; Bulgaria-&reece, Art. 13, No. 62; Bulgaria-Spain, Art. 14, No. 73; Latvia-Spain, Art. 14, No. 74; Denmark-Czechoslovakia, Art. 12, No. 89.

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course of justice by insisting on another extradition proceeding with all the time and expense involved. Another exception to the limitation imposed on the requesting State is contained in a proviso to a number of the treaties that the person surrendered may be tried or punished for an offense other than that for which he was extradited, if he freely and voluntarily consents thereto, or if he himself requests to be brought to trial for such other offense.' A few treaties put the proviso in the form that the consent of the surrendering State is not necessary if the surrendered person thus agrees to be tried for an offense other than that for which he was extradited, 2 although, in some cases, a notice to 3 the surrendering State is required. The inclusion of such a provision in this article was deemed inadvisable for several reasons. First, this Convention seeks to regulate the reciprocal rights and duties of States in their relations with each other, and it does not seem appropriate to cause the exercise of such a right or the observance of such a duty to depend upon the will of an individual. Second, the practical working of such a provision is open to question. The rule of specialty was designed to safeguard the interests of the individuals concerned, as well as those of the requested State, by limiting trial and punishment to the particular act or acts for which extradition was granted. While a person is being detained by a State by reason of extradition, it is difficult to be sure that he really acts freely and voluntarily in consenting to be tried for a different crime from that stated in the requisition. It can hardly be asserted that such a proviso would generally be desired in a multipartite convention in view of the fact that the great majority of treaties and draft conventions and a number of the national extradition statutes do not recognize the surrendered person's consent as an exception to the rule of specialty. 4 The limitation provided for in paragraph 1 (b) of this article is also very 8, No. 18; Switzerland-Uruguay, Art. 6, No. 19; France-Poland, Art. 5, No. 32; AustriaArt. 4, No. 48; Belgium-Czechoslovakia, Art. 13, No. 53; Belgium-Lithuania, Art. 5, No. 56;
I (References are to Appendix I): Finland-Sweden, Art. 6, No. 17; Finland-Denmark, Art. Norway, Art. 6, No. 34; Finland-Norway, Art. 6, No. 35; Belgium-Paraguay, Art. 4, No. 40; Belgium-Estonia, Art. 5, No. 41; France-San Marino, Art. 3, No. 43; Liberia-Monaco, Belgium-Finland, Art. 5, No. 58; Bulgaria-Turkey, Art. 12, No. 65; Turkey-Czechoslovakia, Art. 16, No. 69; Austria-Sweden, Art. 7, No. 72; Estonia-Denmark, Art. 8, No. 77; EstoniaSweden, Art. 7, No. 80; Belgium-Poland, Art. 13, No. 85; Belgium-Austria, Art. 10, No 90; Iraq-Turkey, Art. 13, No. 91. Similar provisions can be found in some of the national extradition statutes, see e.g., Sweden, Art. 11, Appendix VI, No. 12; Switzerland, Art. 7, Appendix VI, No. 13. The only exception to the rule of specialty provided for in the (a), Appendix III, No. 6. 2 (References are to Appendix I): Switzerland-Uruguay, Art. 6, No. 19; Bulgaria-Rumania, Art. 5, No. 22; Hungary-Rumania, Art. 4, No. 27; Liberia-Monaco, Art. 4, No. 48; Colombia-Panama, Art. 9, No. 54; Colombia-Nicaragua, Art. 11, No. 63; Bulgaria-Turkey, Art. 12, No. 65; Austria-Belgium, Art. 10, No. 90; Iraq-Turkey, Art. 13, No. 91. To the same effect see the Central American Convention of 1934, Art. 10, Appendix III, No. 7; the extradition statutes of Sweden, Art. 11, Appendix VI, No. 12; Switzerland, Art. 7, Appendix VI, No. 13. But cf. Turkey-Czechoslovakia, Art. 15, Appendix I, No. 69, which requires the consent of the surrendering State in spite of the agreement of the extradited person. E.g., Iraq-Turkey, Art. 13, Appendix I, No. 91; also in several of the treaties enumerated

Montevideo Convention of 1934, is the express consent of the surrendered person, Art. 17

in footnote 1. 4No such provision is contained in any of the treaties of the United States or Great Brit-

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generally accepted and is supported by existing treaty and statute law, although a fairly large number of treaties, draft conventions and several statutes do not contain provision prohibiting re-extradition without the consent of the surrendering State.' The tendency is, however, decidedly toward the inclusion of such a provision as shown especially by the fact that since 1920 the number of treaties failing to provide for this contingency steadily decreased. With this additional safeguard to the interests of the requested State and of the individual concerned, there should be less reluctance to extradite fugitives from justice, and thus this provision should further the general purpose of this Convention. It may be pointed out that, in most of the treaties, re-extradition and the rule of specialty are dealt with together, and are usually made subject to the same conditions and
aim. See (references are to Appendix I) the treaties of the United States with: Siam, No. 7; Venezuela No. 13; Latvia, No. 14; Estonia, No. 15; Finland, No. 23; Bulgaria, No. 24; Lithuania, No. 26; Czechoslovakia, No. 31; Poland, No. 57; Germany, go. 70; Austria, No. 71; Greece, No. 84; the treaties of Great Britain with: Latvia, No. 20; Finfand, No. 25; Czechoslovakia, No. 28; Estonia, No. 30; Lithuania, No. 46; Albania, No. 47; Iraq, No. 83; also the following bipartite treaties: Greece-Austria-Hungary, No. 1; Germany-Greece, No. 2; Chile-Colombia, No. 3; Estonia-Latvia, No. 4; Estonia-Lithuania, No. 5; Latvia-Lithuania, No. 6; Brazil-Paraguay, No. 8; Italy-Yugoslavia, No. 10; Italy-Czechoslovakia, No. 12; Finland-Latvia, No. 21; Germany-Czechoslovakia, No. 24; France-Latvia, No. 29; Estonia-Finland, No. 33; Rumania-Czechoslovakia, No. 36; Estonia-Czechoslovakia, No. 37; Latvia-Czechoslovakia, No. 38; Bulgaria-Czechoslovakia, No. 39; Belgium-Latvia, No. 42; Austria-Estonia, No. 45; Albania-Greece, No. 49; Greece-Czechoslovalda, No. 50; Spain-Czechoslovakia, No. 51; Portugal-Czechoslovakia, No. 52; Latvia-Norway, No. 55; Austria-Finland, No. 59; France-Czechoslovakia, No. 60; Hungary-Yugoslavia No 61; Bulgaria-Greece, No. 62; Latvia-Hungary, No. 64; Finland-Italy, No. 66; Italy-Venezuela, No. 67; Latvia-Netherlands, No. 68; Bulgaria-Spain, No. 73; Latvia-Spain, No. 74; Germany-Turkey, No. 75; Estonia-Norway, No. 76; Tatvia-Sweden, No. 78; Latvia-Denmark, No. 79; Poland-Sweden, No. 81; Italy-Panama, No. 82; Lithuania-Czechoslovakia, No. 83; Netherlands-Czechoslovakia, No. 86; Italy-Brazil, No. 87; Sweden-Czechoslovakia, No. 88, Denmark-Czechoslovakia, No. 89; Austria-Latvia, No. 92; Finland-Netherlands, No. 95. See to the same effect the Caracas Convention, Appendix III, No. 4; the following draft conventions (references are to Appendix IV): Field s Code, No. 1; Oxford Resolutions, No. 2; International Law Association, No. 5; International Penal and Prison Commission No. 6; the following extradition statutes (references are to Appendix VI): Canada, No. 4; France, No. 6; Germany, No. 7; Great Britain, No. 8; Italy, No. 10. It may be noted that Traver's Projet,Art. 12, Appendix IV, No. 4, expressly excludes consent of the surrendered person as an exception to the rule of specialty. 1 E.g. (references are to Appendix I): the treaties of the United States with: Siam No. 7; Venezuela, No. 13; Latvia, No. 14; Estonia, No. 15; Finland, No. 23; Bulgaria, 24; Lithuania, No. 26; Czechoslovakia, No. 31; Austria, No. 71; Greece, No. 84; (but there is provision for re-extradition with the consent of the surrendering State in the treaty with Germany, Art. 5, No. 70); the treaties of Great Britain with: Latvia, No. 20; Finland, No. 25; Czechoslovakia, No. 28; Estonia, No. 30; Lithuania, No. 46; Albania, No. 47; Iraq, No. 93; Greece-Austria-Hungary, No. 1; Brazil-Paraguay, No. 8; Italy-Yugoslavia, No. 10; Italy-Czechoslovakia, No. 12; Bulgaria-Yugoslavia, No. 16; France-San Marino, No. 43; Albania-Yugoslavia, No. 44; Albania-Greece, No. 49- Italy-Venezuela, No. 67; Italy-Panama, No. 81; See to the same effect the Bustamante Code, Appendix III, No. 5; the Montevideo Convention of 1933, Appendix III, No. 6; Field's Code, Appendix IV, No. 1; The Draft of the International Law Association, Appendix IV, No. 5; also the following statutes (references are to Appendix VI): Canada, No. 4; Great Britain, No. 8; Italy, No. 10. It is interesting that in United States ex rel. Donnelly v. Mulligan (1934), 74 F. (2d), 220, the Circuit Court of Appeals held that the United States-French treaty, which expressly forbade the trying of an extradited person for a different crime from that for which he was extradited, but which said nothing about re-extradition, by implication prohibited re-extradition since the person claimed was extradited only to be tried for the crime specified. Donnelly was therefore discharged. (However, permission for his re-extradition was obtained from France, and his extradition was then upheld. United States ex. rel. Donnelly v. Mulligan, U. S. Cir. Ct. of App., April 1, 1935.) See Note in Cornell Law Quarterly for April, 1935.

ko.

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exceptions. Therefore, what has been said of the exceptions to the rule of specialty (consent of the surrendering State, consent of the surrendered person) is equally applicable to the exception to the rule against reextradition. [(1) A State to which a person has been extradited shall not, without the consent of the State which extradited such person:] (c) Prosecute such person before a court specially constituted for the trial, or to which special powers are granted for the trial. COMMENT The purpose of this paragraph is to prevent the subjection of the extradited person to a trial before a special court called only for that occasion, or before a court granted special powers for that occasion, and whose judgement may be affected by political considerations, or by conditions of public hysteria, thus denying to the prosecuted person the ordinary guarantees of a judicial hearing. However, there may be situations when no ordinary court would have jurisdiction over the extradited person, because of special conditions in a certain area, and the State which has granted extradition may be satisfied that substantial justice will be done in a special tribunal which has been set up. This paragraph is drafted so that trial of an extradited person is not absolutely prohibited in the situation here contemplated, but to the requested State is reserved the right to prevent a political or sensational trial of the extradited person, which would undermine the main purpose of extradition as an international aid to the administration of justice. A similar article is found in the Montevideo Convention: 1 The surrendering State shall not be obliged to grant extradition: . . . (d) when the accused must appear before any extraordinary tribunal or court of the demanding State (tribunal o juggade de excepcion de costado requiriente). Military courts will not be considered as such 2 tribunals. There is a rather large number of bipartite treaties which either prohibit extradition when the extradited person is to be prosecuted before a special court, or which impose a duty on the requesting State not to submit the extradited person to trial by such a court.' The provision restricting prosecution of the extradited person to the courts which normally have jurisdiction over the crimes for which the extradition has been granted is not totally strange to the statutory law on
I Art 3 Appendix III, No. 6. 2 '1he United States in ratifying this Convention made reservation to this article. ' (References are to Appendix I): Finland-Sweden, Art. 6, No. 17; Denmark-Finland, Art. 8, No. 18; Switzerland-Uruguay, Art. 7, No. 19; Estonia-Finland, Art. 7. No. 33; Belgium-Paraguay, Art. 6, No. 40; Austria-Estonia, Art. 6, No. 45; Latvia-Norway, Art. 1, No. 55; Austria-Finland, Art. 6, No. 59; Latvia-Hungary, Art. 7, No. 64; Estonia-Norway, Art. 1, No. 76; Denmark-Estonia Art. 8, No. 77; Latvia-Spain, Art. 3 (h), No. 74; LatviaSweden, Art. 7 (3), No. 78; Poland-Sweden, Art. 10, No. 81;7Brazil-Italy, Art. 6, No. 87, also in Appendix V, No. 4; Austria-Latvia, Art. 6, No. 92; Brazil-Switzerland, Art. 3-d, No. 94; Finland-Netherlands, Art. 7, No. 95, also in Appendix V, No. 8.

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extradition, being found in the statutes of the following States: Estonia,' Finland, 2 Latvia, 3 Lithuania, 4 Sweden 5 and Switzerland.' (2) Paragraph (1), subparagraphs (a) and (b), of this article shall not apply, if the person who was extradited voluntarily remains within the territory of the State to which he was extradited for a period of thirty days, or voluntarily returns thereto. COMMENT Paragraph (2) of this article provides for an exception to the three-fold limitation imposed by paragraph (1) upon the requesting State. The rule of specialty, the prohibition of re-extradition without the surrendering State's consent and the prohibition of trial before a specially constituted court do not apply if the extradited person, after being set at liberty, voluntarily remains for more than thirty days within the territory of the State to which he was extradited, or if, having left that State, he subsequently returns thereto of his own free will. At least as to paragraphs (1-a) and (1-b), the exception provided in this paragraph is very generally recognized in extradition, and its inclusion is amply supported by existing treaty and statute law. A provision of similar import is contained in the great majority of treaties, draft-conventions and statutes.7 It seems reasonable to make the exception of the present paragraph apply also to the subject matter of paragraph (1-c). The period provided for in paragraph (2)-thirty days-is the same as provided for in the majority of treaties (they provide either for thirty days or one month), although some treaties provide for different periods, ranging from 48 hours to three months,8 and a few treaties do not specify any time limit.0
1 Code of Criminal Procedure, Art. 859(9). 2 The Law of Feb. 11, 1922, Art. 9(3). 4 3 Penal Code, Art. 852(8). Code of Criminal Procedure, Art. 854. 6 ' Art. 11(3), Appendix VI, No. 12. Art. 9, Appendix VI, No. 13. 7The exception is not provided for in the following treaties (references are to Appendix I): the treaties of the United States with: Siam, No. 7; Venezuela, No. 13; Latvia, No. 14; Estonia, No. 15; Finland, No. 23; Bulgaria, No. 24; Lithuania, No. 26; Czechoslovakia, No. 31; (but in the treaties with Poland, Art. 4, No. 57, Germany, Art. 5, No. 70, Austria, Art. 4, No. 71, and Greece, No. 84, there is such a proviso); Greece-Austria-Hungary, No. 1; Germany-Greece, No. 2; Italy-Yugoslavia, No. 10; Italy-Czechoslovakia No. 12; FranceLatvia, No. 29; Albania-Greece, No. 49; Finland-Italy, No. 66; Italy -anama, No. 82. See also the Montevideo Convention of 1933, Appendix III, No. 6; Field's Code, Appendix IV, No. 1; the Oxford Resolutions of the Institutde Droit International,Appendix IV, No. 2; Italy, Code of Criminal Procedure, Appendix VI, No. 10. 8 Forty-eight hours in the following treaties (references are to Appendix I): EstoniaCzechoslovakia, Art. 13, No. 37; Latvia-Czechoslovakia, Art. 13, No. 38; Greece-Czechoslovakia, Art. 13, No. 50; Bulgaria-Greece, Art. 13, No. 62. Travers' Draft, Art. 13, Appendix IV, No. 4, provides for five days. The following three treaties provide for one wccl3 (references are to Appendix I): Spain-Czechoslovakia, Art. 14, No 51; Portugal-Czechoslovakia, Art. 14, No. 52; Latvia-Spain, Art. 14, No. 74. The draft of the International Penal and Prison Commission, Art. 15, Appendix IV, No. 6, provides for fourteen days. The treaty between Denmark and Czechoslovakia, Art. 12, Appendix I, No. 89, provides for four weeks. The following treaties provide for three months references are to Appendix I): Chile-Colombia, Art. 7, No. 3; Switzerland-Uruguay, Art. 6, No 19; Liberia-Monaco, Art. 4, No. 48; United States-Poland, Art. 4, No. 57. Three months are also provided in the Bustaante ode, Art. 377, Appendix III, No. 5; and in the extradition statutes of Argentina, Art. 6, Appendix VI, No. 1; Switzerland, Art. 7, Appendix VI, No. 13. 1 See the treaties of Great Britain with (references are to Appendix I): Latvia, No. 20; Finland, No. 25; Czechoslovakia, No. 28; Estonia, No. 30; Lithuania, No. 45; Albania, No.

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The exception provided for in paragraph (2) seems to balance equitably the interests of the extraditing State in seeing that the person extradited is not tried for any act other than that for which he was extradited, and the interests of the State to which extradition is granted in regaining its freedom of action, after the extradited person has voluntarily remained in or returned to its territory. PART VI. PROPERTY ARTICLE 24. DELIVERY AND RETURN OF PROPERTY REQUESTED (1) When a person claimed is extradited, a requested State shall deliver to the requesting State the following categories of property, if requested, and if such delivery will not work an injustice to any other person, and will not interfere with the administration of justice by the requested State: (a) Property which appears to have been acquired by the person claimed or by an accomplice of such person by means of the act for which the extradition is made; (b) Property which may serve as evidence in the prosecution of the person extradited. COMMENT This paragraph provides only for delivery of property with an extradited person. There are conventions, treaties and statutes which countenance delivery when an accused person cannot be extradited because he has died or escaped.' These provisions seem to belong rather in a convention on judicial assistance than on extradition, and have therefore been omitted here. Treaties and conventions frequently do not condition delivery of property upon a request by the requesting State, 2 but such a request seems a reasonable condition of a duty to deliver, and provision is made in this Convention for such request to accompany a requisition, 3 and for detention of property to be requested in connection with a request for provisional arrest. 4 In a good many international agreements and statutes only objects found in the possession of the person claimed are to be delivered, 5 but this seems too
47; Iraq, No. 93;IV, Iraq-Turkey, No. See also the draft of of the International Law tion, Appendix No. 5; and the91. extradition statutes Canada, Appendix VI,AssociaNo. 4; Great. Britain, Appendix VI, No. 8.
1 Montevideo Convention of 1933, Art. 15, Appendix III, No. 6; Travers' Draft of 1928, Art. 10, Appendix IV, No. 4; Draft of International Penal and Prison Commission of 1931, Art 19, Appendix IV, No.6; German-Turkish treaty, Art. 16, Appendix V, No. 3; BrazilianItalian treaty, Art. 13, Appendix V, No. 4; French-Czechoslovakian treaty, Art. 22, Appendix V, No.5; Belgian-Polish treaty, Art 11, Appendix V, No. 6; Colombian-Panama treaty, Art. 15, Appendix V, No. 7; French statute of 1927, Art. 29, Appendix VI, No. 6. 2 See, for example, the multipartite conventions in Appendix III, the United StatesBritish treaty, Art. 12, Appendix V, No. 1; German-Turkh treaty, Art. 14, Appendix V, No. 3. But French-Ozechoslovakian treaty, Art. 22, Appendix V, No. 5, and BelgianPolish treaty, Art. 11, Appendix V, No. 6, call for a request. 3 Article 12. Article 15. 5 Pan American Convention of 1902, Art. 10, Appendix III, No. 3; South American Convention of 1911, Art. 12, Appendix III, No. 4; Bustamante Code of 1928, Art. 370, Appendix III, No. 5; Montevideo Convention of 1933, Art. 15, Appendix III, No. 6; Central American

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