Abstract
Article 23, paragraph (c) of the League Covenant entrusted the League with the task of general supervision over the traffic in opium and other dangerous drugs. Article 2 of the Covenant provided that “the action of the League under the Covenant shall be effected through the instrumentality of an Assembly and of a Council, with a permanent Secretariat.” Article 3, paragraph 3 of the Covenant gave the League Assembly wider powers by authorizing it to “deal at its meetings with any matter within the sphere of action of the League or affecting the peace of the world.” Article 4, paragraph 4 of the Covenant authorized the League Council also to “deal at its meetings with any matter within the sphere of action of the League or affecting the peace of the world.” The spheres of activities of the Assembly and the Council under Articles 3 and 4 of the Covenant would appear to be identical, but their activities were not the same in nature. As there was no definite line of demarcation between the functions of the Assembly and the Council,3 it cannot, therefore, be said that the Council performed executive functions only;4 on the contrary, more often than not, the functions of these two bodies overlapped.5
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Notes
By the time the League of Nations was established, the world of drugs had been so enlarged that it contained not only opium and its allied substances but also narcotic drugs, i.e., the drugs manufactured chemically. It was for this reason that Article 23 (c) included “opium and other dangerous drugs.”
The only other convention existing at that time was the Hague Convention which came into force on the date when the Treaty of Peace with Germany became effective. See chapter 2, p. 54; see also fn. 107.
The Report of the First Committee on the Relations Between, and Respective Competence of, the Council and the Assembly, as amended and adopted by the Assembly on 7 December 1920 also mentioned that “Article 2 of the Covenant provides that the action of the League shall be effected through the instrumentality of an Assembly and a Council. It follows that the League is a single organism...” It also stated that “the Council and the Assembly have each their distinctive rights and duties, there are matters the decision of which is left to the League of Nations, without its being specified to which organ of the League the right of decision belongs. Articles 23 and 24 of the Covenant; Article 103, Article 336, Article 338, Article 376 of the Treaty of Versailles.” See League of Nations: The Records of the First Assembly: Plenary Meetings, Annex A, pp. 318–319.
See further J. F. Williams, Some Aspects of the Covenant of the League of Nations, (London: OUP, 1934), p. 70.
Under the second paragraph of Article 11 of the League Covenant it was declared to be the friendly right of each Member of the League to “bring to the attention of the Assembly or of the Council any circumstance whatever affecting international relations which threatens to disturb international peace or the good understanding between nations upon which peace depends.”
F. P. Walters, A History of the League of Nations (Oxford, 1969), p. 177.
Assembly Resolution dated 15 December 1920, Twenty-fourth Plenary Meeting, Records of the First Assembly, pp. 538–539.
F. P. Walters, op. cit., p. 169.
Such requests were made by the League Assembly also.
See below, Sub. Sec. 3.2.2.2.
See below, p. 86.
Articles 8 and 10 of the Geneva International Opium Convention of 1925.
Article 11 of the Limitation Convention of 1931.
See further H. R. G. Greaves, The League Committees and World Order: A Study of the Permanent Expert Committees of the League of Nations as an Instrument of International Government (Oxford, 1931).
See further H. R. G. Greaves, op. cit., p. 11 et. seq.
League of Nations, Records of the First Assembly, 1920, pp. 538–539. It should be noted that the Members of the League considered the drug problem as an international problem of great magnitude since they preferred to constitute a special committee which was to be entrusted with the task of securing co-operation between nations, instead of leaving the task to the League Council, which would be assisted by the Secretariat. In fact, this was the alternative proposal.
League of Nations, Records of the First Assembly, op. cit., pp. 538–539.
Germany and Yugoslavia joined in 1921, Switzerland and Bolivia joined in 1924, and Italy joined in 1926. In 1922, the Council invited the United States to nominate a member to serve on the Committee. The US government appointed its representative in an advisory and un-official capacity, since US never became a Member of the League of Nations.
Italy left the Committee because she withdrew from the League of Nations in 1937. Germany also withdrew from the League in 1933.
The Tenth Assembly adopted a resolution to the effect that more non-manufacturing countries should be represented on the Opium Advisory Committee. See “Report of the Fifth Committee to the Assembly,” L.N. Document A 86. 1929.XI, pp. 6–7.
Sweden left the Committee in 1937 because her representative was appointed to a diplomatic post and no other person was sent to the Committee to replace him.
The first assessors were: Sir John Jordan who contributed significantly to the conclusion of the Indo-Chinese Opium Agreement of 1907, M. Henri Brenier, an experienced administrator who served the government in French Indo-China and who was very familiar with the opium problem, and Mrs. Hamilton Wright, the widow of the late Dr. Hamilton Wright, who was also familiar with the opium problem and who was the nearest person to continue the policy of her husband.
The assessors were paid daily subsistence allowance during meetings and travelling expenses out of the budget of the League.
Official Journal of the League of Nations, L.N. Doc. C.71.1936 (Extract No. 105).
Members of the Committee were not paid by the League because they were not representatives of governments.
See further L. E. Eisenlohr International Narcotics Control, p. 53.
The League Assembly in adopting the resolution to form an Advisory Committee found it preferable “... to undertake the duties placed upon the Netherlands Government by the Opium Convention with regard to the collection of data and dealing with disputes.” League of Nations, Records of the First Assembly, (1920), op. cit., p. 538.
Minutes of the Advisory Committee on Traffic in Opium, 1st Session, 2–5 May 1921, p. 17, L.N. Doc. C.77.M.39.1921.XI.
29.Ibid.
Article 6 of the International Opium Convention signed at the Hague on 23 January 1912: “The Contracting Powers shall take measures for the gradual and effective suppression of the manufacture of, internal trade in, and use of prepared opium, with due regard to the varying circumstances of each country concerned, unless regulations on the subject are already in existence.”
L.N. Doc. C.418. M. 184.1923.XI. p. 15.
The text of the proposal was as follows: (1.) “If the purpose of the Hague Opium Convention is to be achieved according to its spirit and true intent, it must be recognised that the use of opium products for other than medicinal and scientific purposes is an abuse and not legitimate.” (2.) “In order to prevent the abuse of these products, it is necessary to exercise the control of the production of raw opium in such a manner that there will be no surplus available for non-medicinal and non-scientific purposes.” League of Nations Advisory Committee on Traffic in Opium and Other Dangerous Drugs, Minutes of the Fifth Session, 2nd Meeting, p. 15 (L.N. Doc. C. 418.M. 184.1923.XI). 33.Ibid.
France, Germany, Great Britain, Japan, the Netherlands, Portugal and Siam.
The Chairman of the Committee, however, pointed out that not only in the opinion of doctors, medical use only was considered legitimate, but that such an inference could also be drawn from the text and spirit of the Convention as well as from the discussions of the Advisory Committee. He also mentioned that the word “legitimate” should be understood in a special sense in this instance, which had been attributed to it by the Legal Section of the Secretariat. The Legal Section of the Secretariat had given the following interpretation of Article 6: “The complete and effective suppression of the manufacture of, home trade in, and use of prepared opium constitutes one of the ultimate obligations undertaken by Governments under the 1912 Convention; but it is for each State to decide, according to individual circumstances, as to the precise manner in which its suppression may be brought about.” League of Nations Advisory Committee on Traffic in Opium and Other Dangerous Drugs, Minutes of the Fifth Session, 3rd Meeting, p. 21 (L.N. Doc. C.418.M. 184.1923.XI).
This opinion was also held by the Indian delegate.
League of Nations Advisory Committee on Traffic in Opium and Other Dangerous Drugs , Minutes of the Fifth Session, op. cit., p. 13 (L.N. Doc. C.418.M. 184.1923.XI).
See Records of the First Assembly, op. cit., p. 538.
See further, S. H. Bailey, op. cit., p. 108.
The practice followed in the preparation of the Limitation Convention is very instructive. See further L.N. Doc. C.138.M. 51.1930.XI, pp. 8–9 and Appendix 5, pp. 20–24, C.669.M. 278.1930.XI, C.168.M.62.1931.XI; see also B. Renborg, International Drug Control, Carnegie Endowment for International Peace, pp. 178 et. seq.
See further B. Renborg, op. cit., p. 180.
L.N.Doc. A.80.1931.V.
L.N.Doc. C.285. M.186.1937.XI, Section IX, pp. 19–22.
See further S. H. Bailey, op. cit., p. 110.
A Model Code was devised to serve as a “guide” to the national legislatures in drafting laws and regulations for the application of a drug convention. Such a Code was prepared in connection with the International Opium Convention of 1925. This Code consisted of provisions which had stood the test of practice and was based on a selection of the most important rules of those countries which had a complete system of control. When the Limitation Convention was prepared, the sub-committee of the Advisory Committee on the Model Committee decided to draft a separate and temporary code for this Convention instead of amending the previous Code which was drafted at the instance of the 1925 Convention. The new code supplemented the old code. This Code was circulated to the Members and non-members of the League and the Signatories to the Limitation Convention. See further L.N. Doc. C.774. M.365.1932.XI and S. H. Bailey, op. cit., pp. 110–111.
See Report of the Advisory Committee on the Traffic in Opium and Other Dangerous Drugs (First Session), L.N. Doc. A.38.1921.XI. The system of government replies had, in fact, been devised in the Hague Opium Convention of 1912 (Article 21).
L.N. Doc. A. 15.1922. Annex I, pp. 14–17.
Articles 22 and 23 of the International Opium Convention, 1925.
See further Renborg, op. cit., p. 182.
L.N. Doc. C. 530. M.241.1934.XI., p. 10 and Annex 3, pp. 25–30.
Renborg, op. cit., p. 183.
The Opium Advisory Committee entrusted the Secretariat of the League with most of the preparatory studies for the 1936 Conference and similar studies for its subsequent sessions. See further L.N. Doc. C.285.M.186.1937.XI, Sec.IX., C. 221. M. 123.1938.XI, and C.175.M. 104. 1939.XI.
Article 21, paragraph (a) of the Hague Opium Convention, 1912, Article 30 of the International Opium Convention, 1925, Article 21 of the Limitation Convention, 1931, and Article 16 of the Convention for the Suppression of the Illicit Traffic in Dangerous Drugs, 1936.
B. A. Renborg, op. cit., p. 186.
Article 11, paragraph 4 of the Limitation Convention, 1931.
See the Section on the WHO Expert Committee on Drug Dependence, see below, Part III especially pp. 296–297.
S. H. Bailey, op. cit., p. 109.
This report was based on the Progress Report which was prepared by the Secretariat of the League. This Progress Report contained important information from the member governments, and also the replies of the governments which received circular letters issued by the Secretariat conveying the decision taken by the Opium Advisory Committee and approved by the League Council, on matters concerning administration of the drug-trade. Such Progress Reports were submitted by the Secretariat to the Opium Advisory Committee at each session.
It was for this reason that the Committee in its reports was able to criticize many governments on their unsatisfactory progress in combating the illicit traffic in drugs.
S. H. Bailey, op. cit., p. 116.
The main task of documentation for this Conference was however done by the Secretariat. See L.N. Doc. C.587.M.228.1930.XI., Parts I, II and III.
Article 21 of the Limitation Convention: “The High Contracting Parties shall communicate to one another through the Secretary-General of the League of Nations the laws and regulations promulgated in order to give effect to the present Convention, and shall forward to the Secretary-General an annual report on the working of the Convention in their territories, in accordance with a form drawn up by the Advisory Committee on Traffic in Opium and Other Dangerous Drugs.” The other matters for which the Committee was authorized to work independently were: the appointment of a member of the Supervisory Body and the selection of one of a body of three experts, to whom, in the event of the Health Committee deciding that a product was not itself a drug capable of producing addiction, but was convertible into such a drug, the question whether the drug in question should fall under sub-group (b) of Group I or under Group II should be referred a decision in so far as the scientific and technical aspects of the matter was concerned. Article 5, paragraph (6) and Article 11, paragraph (4) respectively of the Limitation Convention, 1931.
See footnotes 42 and 62.
Records of the Second Opium Conference (17 November 1924–19 February 1925, Geneva), vol. 1, p. 13. L.N. Doc. C.760.M.260. 1924.XI.
L.N. Doc. A 32(a). 1924.XI., p. 5.
See Annex to the Records of the Second Opium Conference, vol. 1, p. 371. L.N. Doc. C.415.M.149.1925.XI., p. 1.
Ibid.
M. van Wettum (the Netherlands) Chairman Nominated by the Opium Advisory Committee M. Bourgois (France) Nominated by the Opium Advisory Committee Sir Malcolm Delevingne (Great Britain) Nominated by the Opium Advisory Committee Mr. Neville (USA) Nominated by the Council of the League M. Brenier—Assessor Nominated by the Council of the League Sir John Jordan—Assessor Nominated by the Council of the League
At that time the chief drug producing and manufacturing countries were the following: (a) Morphine and Heroin: Germany, Japan and Switzerland. (b) Cocaine: Germany, Japan and Switzerland. (c) Raw Opium: Greece, India, Kingdom of the Serbs, Croats and Slovenes, Russia and Turkey. (d) Coca Leaf: Bolivia and Peru. See Annex 1, op. cit., p. 371. L.N. Doc. C.415.M. 149.1925.XI.
Ibid., p. 372.
Ibid.
Ibid.
Records of the Second Opium Conference, vol. I., op. cit., p. 14.
Ibid., see also the reports of the respective delegates, Records of the Second Opium Conference, vol. I., op. cit., pp. 373–381.
Ibid., p. 380.
Ibid., p. 14. The efforts made by Sir John Campbell (India) and Dr. Anselmi-no (Germany) contributed to a great extent to the determination of a compromise formula. See Annex 2 to the Records of the Second Opium Conference, vol. I. L.N. Doc. A 32(a) 1924.XI., O.C. 216(5).
L.N. Doc. A.32(a) 1924., p. 5.
Article 19.
In discussing the relationship between the Central Board and the Opium Advisory Committee, the Sub-Committee, in its report, maintained that the Board was not an independent body. See further O.C. 669, and L.N. Doc. C.557.M.199.1927.XI., pp. 43–45.
Opium Advisory Committee, Minutes of 10th (Extraordinary) Session, p. 44. L.N. Doc. C.557.M. 199.1927.XI.
The International Opium Convention, 1925.
Opium Advisory Committee, Minutes of 10th (Extraordinary) Session, op. cit., p. 44.
Ibid., p. 45.
Article 23 of the League Covenant.
L.N. Doc. O.C. 669, 1927.
It remains to be seen whether this conflict of opinions and interests was overcome subsequently, and even under the United Nations system.
Opium Advisory Committee, Minutes of 11th Session, 18th Meeting, p. 98. L.N. Doc. C.328.M.88.1928.XI.
Ibid., p. 99. According to Article 20 of the Geneva Convention of 1925, “... The Secretary-General shall appoint the Secretary and staff of the Board on the nomination of the Board and subject to the approval of the Council.”
Records of the Second Opium Conference, vol. 2, op. cit., p. 98. (L.N. Doc. C.760.M. 260.1924.XI).
Ibid., p. 99.
Ibid., p. 102.
France, Great Britain, Japan, the Netherlands and the United States.
Records of the Second Opium Conference, vol. 2, op. cit., p. 102.
Ibid., p. 104.
The draft Article provided that “the Contracting Powers should send to the Permanent Central Board... estimates of the quantities of substances covered by the Convention to be imported for internal consumption during the following year into their territory for medical and scientific purposes.” Ibid., p. 104. Article 21 of the International Opium Convention of 1925 reads as follows: “The Contracting Parties agree to send in annually before December 31st, to the Permanent Central Board set up under Article 19, estimates of the quantities of each of the substances covered by the Convention to be imported into their territory for internal consumption during the following year for medical, scientific and other purposes. These estimates are not to be regarded as binding on the government concerned, but will be for the purpose of serving as a guide to the Central Board in the discharge of its duties. Should circumstances make it necessary for any country, in the course of the year, to modify its estimates, the country in question shall communicate the revised figures to the Central Board.”
Articles 22 and 23 of the International Opium Convention, 1925.
Article 22 of the International Opium Convention, 1925: “1. The Contracting Parties agree to send annually to the Central Board, in a manner to be indicated by the Board, within three (in the case of paragraph (c), five) months after the end of the year, as complete and accurate statistics as possible relative to the preceding year, showing: (a) Production of raw opium and coca leaves; (b) Manufacture of the substances covered by Chapter III, Article 4(b), (c) and (g) of the present Convention and the raw material used for such manufacture. The amount of such substances used for the manufacture of other derivatives not covered by the Convention shall be separately stated; (c) Stocks of the substances covered by Chapters II and III of the present Convention in the hands of wholesalers or held by the government for consumption in the country for other than government purposes; (d) Consumption, other than for government purposes, of the substances covered by Chapters II and III of the present Convention; (e) Amounts of each of the substances covered by the present Convention which have been confiscated on account of illicit import or export; the manner in which the confiscated substances have been disposed of shall be stated, together with such other information as may be useful in regard to such confiscation and disposal. The statistics referred to in paragraphs (a) to (e) above shall be communicated by the Central Board to the Contracting Parties.” “3. In furnishing the statistics in pursuance of this Article the governments shall state separately the amounts imported or purchased for government purposes, in order to enable the amounts required in the country for general medical and scientific purposes to be ascertained. It shall not be within the competence of the Central Board to question or to express any opinion on the amounts imported or purchased for government purposes or the use thereof.” “4. For the purposes of this Article, substances which are held, imported, or purchased by the government for eventual sale are not regarded as held, imported or purchased for government purposes.”
Article 23 of the International Opium Convention, 1925.
Raw opium, coca leaves, Indian hemp and the narcotic drugs as enumerated in Article 4 of the International Opium Convention, 1925.
The Board received no statistics of internal seizures or confiscations; such statistics were to be submitted to the Opium Advisory Committee.
Article 13 of the Limitation Convention, 1931.
Article 13, paragraph 2.
Article 13, paragraph 2, sub-paragraph (c), clause (ii).
In fact, the system of acquiring statistical information as regards trade in raw opium, prepared opium, morphine, cocaine and their respective salts, as well as in the other drugs or their salts or preparations was prescribed in the Hague Opium Convention of 1912; see Article 21, paragraph (b).
See further B. Renborg, op. cit., p. 195.
See below, Section on Supervisory Body, pp. 93–97.
Article 24 of the International Opium Convention, 1925.
16 May 1933.
L.N. Doc. C.480. M. 244. 1933.XI., p. 10.
The Dutch delegate pointed out that there would be no deadlock between the two doctors and the other two members of the Advisory Body, who would presumably represent the administrative side. He thought that it would be advisable to appoint a member of the Opium Advisory Committee on the understanding that the person selected would never be responsible to the Committee. See Opium Advisory Committee, Minutes of 16th Session, p. 11. L.N. Doc. C.480.M. 244.1931.XI.
Ibid., p. 12.
L. E. Eisenlohr, op. cit., p. 199.
Article 5, paragraphs 4 and 5 of the Limitation Convention, 1931.
Article 5, paragraph 6 of the Limitation Convention, 1931.
B. A. Renborg, op. cit., p. 38.
Article 21 of the International Opium Convention, 1925.
Article 2, paragraphs 2 and 3 of the Limitation Convention, 1931.
Such a situation arose in 1933, when some of the countries failed to furnish the required information on reserve stocks. L.N. Doc. C.610.M.286. 1933.XI., p. 7.
See L.N. Doc. C.400.M.280.1921.III. op. cit., pp. 3–4. The other constituent parts of the Health Organization were: (a) the Advisory Council, and (b) the Health Section forming part of the Secretariat of the League of Nations. The Health Section was primarily an executive organ. In fact, a chain of events led to the formation of the Health Committee: the unofficial conference held in London in July 1919 followed by the official conference, also held in London in April 1920, which drew up the plan of a health organization, and the meetings of the Council at San Sebastian, in the course of which the plan was adopted with certain modifications. This plan provided for the establishment of an organization entrusted with the duty of advising the Council on technical matters concering health, organized on the same line as the Transit, Economic and Financial Organizations previously established by the League of Nations. Its duty was to convene international conferences, to exchange information and to take all necessary steps to ensure an effective international co-operation in all matters of health. The Council of the League was unable to establish this organization since it was based on the collaboration of the Office International d’Hygiene Publique, such collaboration being essential for all work undertaken in matters of health. This Office was unwilling to make the Rome Convention of 1907 (which was the basis of its existence) conform to the plan of the League of Nations. The Council had, therefore, been unable to establish the Technical Committee laid down in the Assembly Resolution, but it had decided to create a health committee.
The Head of the Federal Health Service of the United States was a member.
See further Health Organization, published under the auspices of the League of Nations, 1931; see also N. M. Goodman, International Health Organizations and Their Work (London, 1971).
Held on 29 August 1921.
L.N. Doc. C.400.M.280.1921.III, pp. 25–26.
Provisional Health Committee of the League of Nations, Minutes of the First Session of the Committee (held in Geneva) 25–29 August 1921, pp. 25–26. L.N. Doc. C.400.M.280. 1921. III.
See L.N. Doc. C.588.M.202.1924 II, especially Annex 35, (C.H. 251), p. 56.
See further B. A. Renborg, op. cit., p. 64. Also, the procedure of work adopted by the Health Committee appeared to be slow. In order to perform the function under Article 10 of the Convention, a Committee of Experts was appointed by the Office International d’Hygiene Publique in Paris to determine whether a drug was dangerous or not. The Report of the Experts went first to the Permanent Committee of the Office, and then on to the Health Committee. Thereafter, the Health Committee transmitted the report to the League Council. The procedure therefore proved to be time-consuming, and in fact, it might take several years to complete the cycle.
See B. A. Renborg, op. cit., p. 65. Such an initiative was taken by the Limitation Conference in an effort to ensure that the Hague Opium Convention and the International Opium Convention should be applied to all the drugs included in Group I of Article 1 of the Limitation Convention.
Article 27 of the Limitation Convention: “The present Convention, of which the French and English texts shall both be authoritative, shall bear this day’s date, and shall, until December 31st, 1931, be open for signature on behalf of any Member of the League of Nations, or of any non-member State which was represented at the Conference which drew up this Convention, or to which the Council of the League of Nations shall be communicated a copy of the Convention for this purpose.”
In terms of the provisions of Article 6 of the Limitation Convention “domestic requirements” seems to have included “reserve stocks” and “government stocks.”
The implication was that an estimate should have been submitted to the Supervisory Body before the issue of any permit “authorising the trade in or manufacture for tradeofthedrugin question.”L.N. Doc. C.642.M. 305.1933.XI., p. 5.
Article 10 of the International Opium Convention, 1925 provided, inter alia, that: “In the event of the Health Committee of the League of Nations, after having submitted the question for advice and report to the Permanent Committee of the Office International d’Hygiène publique in Paris, finding that any narcotic drug to which the present Convention does not apply is liable to similar abuse and productive of similar ill-effects as the substances to which this Chapter of the Convention applies, the Health Committee shall inform the Council of the League accordingly and recommend that the provisions of the present Convention shall be applied to such drugs.”
See Report to the Council on the Work of the Seventeenth Session, p. 4, L.N. Doc. C.642.M.305.1933.XL
This was not so under the International Opium Convention, 1925, Article 10.
Article 8 of the International Opium Convention, 1925: “In the event of the Health Committee of the League of Nations, after having submitted the question for advice and report to the Permanent Committee of the Office International d’Hygiène publique in Paris, finding that any preparation containing any of the narcotic drugs referred to in the present Chapter cannot give rise to the drug habit on account of the medicaments with which the said drugs are compounded and which in practice preclude the recovery of the said drugs, the Health Committee shall communicate this finding to the Council of the League of Nations. The Council will communicate the finding to the Contracting Parties, and thereupon the provisions of the present Convention will not be applicable to the preparation concerned.”
See below, sub. sec. 5.4.2.5 for the relationship between the World Health Organization and the UN Narcotics Commission concerning this matter.
Article 5, paragraph 6 of the Limitation Convention, 1931.
The following was the text of the recommendation put forward by Dr. May: “Notwithstanding anything contained in Article 10 of the Second Geneva Convention, the provisions of that Convention shall apply to all alkaloids of opium and coca leaves and their derivatives, and all derivatives of all substances mentioned in Article 4 of the said Convention, unless and until the Health Committee of the League of Nations, after having submitted the question for advice and report to the Permanent Committee of the Office International d’Hygiène publique in Paris, finds that any such alkaloid or derivative cannot give rise to the drug habit, and unless and until the Health Committee communicates this finding to the Council of the League of Nations, and unless and until the Council communicates the finding to the Parties to this Agreement.” L.N. Doc. C.191.M.136.1937.XI., pp. 300–301 (O.C. 1347, pp. 2–3 dated 13 January 1931).
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Chatterjee, S.K. (1981). The Organizational and Functional Framework as Devised by the League of Nations for the Purpose of Controlling the Manufacture of, and Trade and Traffic in, Drugs. In: Legal Aspects of International Drug Control. Springer, Dordrecht. https://doi.org/10.1007/978-94-017-7066-8_3
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