[Page 24]

COLONEL SMIRNOV: Your Honours: my problem to-day consists of presenting to you the written documents and other judicial evidence testifying to the very grievous crimes committed by the Hitlerian conspirators against the peaceful population in the territories of the USSR, Yugoslavia, Poland and Czechoslovakia when under temporary occupation.

The number of such depositions at the disposal of the Soviet Prosecution is unusually great.

Suffice it to say that in the reports of the Extraordinary State Commission for the Determination and Investigation of the Crimes of the German Fascist Invaders and the Accomplices, there are 54,784 reports of the crimes by the Hitlerite criminals, directed against the peaceful citizens of the Soviet Union.

But even these documents do not by a long way cover all the crimes perpetrated by these war criminals against the peaceful population.

The Soviet Prosecution asserts, and I submit to the Tribunal evidence to this effect, that along the entire length of the far-flung front, from the Barentz to the Black Sea, and throughout the entire depths of the infiltration of the German hordes into my Motherland, wherever the German soldier or the men of the S.S. set foot, crimes of unspeakable cruelty were committed and the victims of these crimes were the women, the children, and the aged.

The crimes of the German fascist criminals became apparent as and when the Red Army units moved west. The reports on these Hitlerite crimes against the peaceful population were made by officers of the advance units of the Red Army, by local authorities, and public organisations.

[Page 25]

Far different were the sources of their information. Returning to their native haunts the soldiers of the Army of Liberation saw the many villages, towns, and cities which had been reduced to so much "waste land".

At the foot of the communal graves where rest the bodies of the Soviet people murdered by "typical German methods" (I shall, later on, present to the Tribunal evidence of these methods and of the regularity of their application); at the foot of the gallows where the feet of the adolescents danced on the air; at the ovens of the gigantic crematoriums where the murdered internees from the extermination camps were burned; at the sight of the dead women and girls - victims of some sadistic whim of the fascist bandits; and of children who had been torn in half. By all this evidence did the Soviet people recognize the mighty chain of crime extending, as the Chief Prosecutor of the USSR so aptly said, "from the ministerial armchair to the hands of the executioner."

All these monstrous crimes had a definite system of their own; there was uniformity in the murder methods. One and the same system prevailed in the construction of the gas chambers, in the mass production of the round tins containing the poisonous substances "Cyclone A" or "Cyclone B". The ovens of the crematoriums were all built on the same typical lines, and one was the plan extending over all the camps of destruction. There was uniformity in the construction of the evil-smelling death machines, which the Germans referred to as "Gaswagen", but which our people called the "Soul Destroyers", and there was the same technical elaboration in the construction of mobile mills for grinding human bones. All this indicates one sole and evil will, uniting all the individual assassins and executioners.

It became obvious that German thermotechnicians and chemists, architects, toxicologists, mechanics and physicians were engaged in this rationalisation of mass murder on instructions received from Hitler's Government and from the Supreme Command of the German Armed Forces.

It was also evident that the "death factories" brought into existence an entire series of auxiliary industries.

But the unity of this deliberate evil was not only apparent there, where a special technique had been evolved to serve the purpose of murder most foul.

The unity of this deliberate evil was also apparent from the similarity of the methods employed by the murderers, from the uniformity of type in the murder technique evolved, as well as from the fact that in cases where no special technique was employed, use was made of ordinary weapons of the German Armed Forces.

From the evidence which I shall submit later on, you will see that the sites where the Germans buried their victims were opened up by Soviet doctors in the North and South of the country. These sites were separated from each other by thousands of kilometers and it is quite evident that the crimes were perpetrated by entirely different people. But the methods employed were absolutely identical. The wounds were invariably inflicted on the same parts of the body. Identical, too, were the preparations for camouflaging the gigantic graves as anti-tank ditches and trenches. Everywhere the unarmed and defenceless people, on their arrival at the execution ground, were ordered, in practically the same terms, to undress and lie, face downwards in previously prepared pits. As soon as the first batch

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This is testified to not only by the uniformity of instructions and orders received from high quarters, but by the similarity of the methods employed, which made it clear that execution squads were being trained in special schools which had systematised and provided for every eventuality, from the order to undress prior to the shooting, right down to the shooting itself. These conclusions, based on an analysis of assembled facts, were later confirmed by documents captured by the Red Army and by the testimony of prisoners of war.

From the very first months of the war it became clear to the Soviet Government that the innumerable crimes of the German fascist aggressors against the peaceful citizens of my Motherland represented, not the excesses of undisciplined military units, or the isolated crimes of individual officers and soldiers, but a system prepared in advance, not merely sanctioned by the criminal Nazi Government, but consciously planned and encouraged by this Government.

I submit to the Tribunal in evidence, according to Article 21 of the Charter, one of the official notes of V. M. Molotov, National Commissar for Foreign Affairs in the USSR, dated as early as 6th January, 1942. This document is registered as Exhibit USSR 51. It is on the first page of your document book, beginning at the third paragraph after the heading:-

"As and when the Red Army, in the course of its continued and victorious counter-offensive, liberated numerous cities and rural communities which had, for a certain time, been in the hands of the German invader, an incredible picture emerged more clearly with every passing day - a picture of the looting which took place in every community, of general devastation, of revolting acts of rape, ill-treatment, and mass murder, all committed against peaceful citizens by the fascist German occupational forces during their advance, during the occupation and during their withdrawal. The great amount of documentary material which the Soviet Government has at its disposal testifies to the plundering and despoiling of the population, accompanied by bestial acts of violence and mass murders, carried out in all territories which came under the heel of the German invader.

Unquestionable facts prove that the regimes of robbery and of bloody terror inflicted on the peaceful population of the occupied villages and cities did not consist of certain excesses of individual undisciplined military units, or individual German officers and soldiers. Rather does it point to a definite system, planned far in advance and encouraged by the German Government and the German Army Command, a system which intentionally unleashed within their army the lowest animal instincts among the officers and men.

Every step of the German fascist army and its allies in the invaded Soviet territories of the Ukraine and Moldavia, of Bielorussia and Lithuania, Latvia, and Estonia, in the Karelian- Finnish lands, in the Russian zones and regions, led to annihilation and to the destruction of priceless material and cultural treasures - the property of the nation; for the civilian population it led to the loss of hard-won property, famine, and bloody massacre before whose horror the most savage crimes in history have paled.

The Soviet Government and its organisations record all these 11 infamous crimes of the Hitler army for which the indignant Soviet people justifiably demand and will obtain retribution."

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I now proceed to read into the record Paragraphs 2, 4 and 5 of the concluding statement of this note. Your Honours will find the place in question on the reverse side of Page 4 of the document quoted, Paragraph 5:-

"The Hitlerite Government in Germany which had so treacherously attacked the Soviet Union, pays no heed, in warfare, to any standards of International Law or to any of its moral requirements. It wages war primarily against the peaceful and unarmed populations, against women, children and old men, thereby revealing its own essential vileness. This government of robbers, which recognizes only violence and rapine, must be crushed by the all-powerful strength of the freedom loving peoples, in whose ranks the Soviet nation will carry out its mighty task of liberation to the end.

In bringing all the atrocities committed by the German invaders to the knowledge of all the governments with which the Soviet Union maintains diplomatic relations, the Soviet Government announces that it holds Germany's criminal Hitlerite Government responsible for all the inhuman and rapacious acts perpetrated by the German Armed Forces.

At the same time the Government of the Soviet Union declares with unshakable conviction that the Soviet Union's fight for liberation is a fight for the rights and liberty not only of the peoples of the Soviet Union, but also for the rights and liberty of all freedom-loving peoples of the world, and that this war can only end with the complete destruction of the Hitler armies and with complete victory over the Hitlerite tyranny."

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