Legal ex post facto (broken from Latin: ex postfacto , lit. ',' Out of the aftermath ') is a law that retroactively alters the legal consequences (or status) of actions taken, or existing relationships, prior to the enactment of the law. In criminal law, it can criminalize legitimate action when committed; it can exacerbate the crime by bringing it to a more severe category than when it was done; it can alter the prescribed penalty for a crime, such as by adding a new sentence or extending the sentence; or may change the rules of evidence to make beliefs for crimes more than they should be when the deed is committed. In contrast, the legal form of ex post facto commonly called the amnesty law can decriminalize certain actions. Forgiveness has the same effect, in certain cases, not the case class. Other legal changes may alleviate possible penalties (eg by altering the death penalty with life imprisonment) retroactively. Such legal changes are also known as Latin in mitius .
Some common-law jurisdictions do not allow retroactive criminal laws, although new precedents generally apply to events that occurred before a court decision. Ex post facto the law is expressly prohibited by the United States Constitution in Articles 1, Section 9, Clause 3 (with respect to federal law) and Article 1, Section 10 (in connection with state law). In some countries following the Westminster system of government, like England, the ex post facto law is technically possible, because the doctrine of parliamentary supremacy allows Parliament to pass the law it desires. In a country with written or written constitutional legislation, ex post facto legislation may be prohibited.
Although American jurisdiction generally prohibits ex post facto laws, European countries apply the principle of lex mitior ("lighter law"). This provides that, if the law has changed after the violation has been committed, the applicable legal version is the more favorable for the defendant. This means that the ex post facto law applies in European jurisdiction to the extent that they are a lighter law.
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Australia
Australia has no strong constitutional ban on ex post facto laws, although retroactive laws may have violated the constitution of the principle of separation of power. Australian courts usually interpret the law in the strongest sense that they do not apply retroactively.
Retroactive legislation designed to prosecute what was considered a highly unethical method of tax evasion was passed in the early 1980s by the Fraser government (see lower port tax evasion). Similarly, laws that criminalize certain war crimes are retroactively considered constitutional (see Polyukhovich v Commonwealth).
The government will sometimes make press releases intending to amend the tax law with effect from the date and time of press release, before the law is introduced to parliament.
Brazil
According to Article 5, section XXXVI of the Constitution of Brazil, the law shall not have any ex post facto effect affecting the rights acquired, resolving juridical action and
The same article in section XL prohibits ex post facto criminal law. Like France, there are exceptions when retroactive criminal law benefits the defendant.
Canada
In Canada, the ex post facto constitutional criminal law is prohibited by paragraph 11 (g) of the Charter of Rights and Freedoms. Also, under paragraph 11 (i) of the Charter, if the penalty for a crime varies between the time the crime is committed and the time after the conviction, the person convicted shall be entitled to a lesser sentence.
The Canadian sex offender registry, which came into effect on December 15, 2004, was somewhat retroactive. When the registry was created, all violators residing in the Toronto sex offender offender, created in 2001, were required to register in the national registry. In addition, sex offenders in all serving provinces (whether in prison or on probation or parole) on 15 December 2004 were required to register, irrespective of when violations and their beliefs occurred. However, the registry is not retroactive for anyone who has completed their sentence at the end of 2004 and is not registered in Ontario. The Canadian court has never decided on the somewhat receding nature of the list of sex offenders, as this seems to never be challenged.
Interestingly, the registration of sex offenders is not mandatory for sex offenders until 2011, and must be ordered by a judge.. Rather strange, the registration of sex offenders seems mandatory for people convicted before December 15, 2004 who are serving a sentence on that date, but only optionally for sex offenders who were convicted between 15 December 2004 and 1 January 2011.
Since article 11 of the Charter is one of the parts that can be set aside under article 33 (the clause is not clear), Parliament can theoretically enact an ex post facto law by applying for section 33. However, the federal Parliament (which has a single power to make laws punishable for violations by two years or more in prisons) never attempted to enforce the ex post facto law (or any other law) using article 33.
It should be emphasized that the Charter ban applies only to criminal law. Changes to civil law in Canada can, and sometimes, be enforced ex post facto . In one instance, the convicted killer Colin Thatcher was ordered to lose the proceeds of a book he had published (after being released from prison) under the laws of Saskatchewan. Although the law was passed long after the conviction of Thatcher's murder, the court has ruled that the law only regulates civil penalties (as opposed to additional criminal penalties) and is thus not subject to the Charter's restrictions.
Finnish
Generally, the Finnish legal system does not allow the law of ex post facto , especially the law that will expand criminal liability. They are not strictly forbidden; On the other hand, the ban comes from more general legal principles and basic rights. In civil matters, such as taxation, ex post facto the law may be made in some circumstances.
However, there are three remarkable examples when the ex post facto criminal law has been used in Finland.
After the Finnish Civil War of 1918, the Finnish Parliament passed a law regulating the courts to try suspected rebels. These trials issued the death penalty in most cases, although very few of those accused of committing crimes carrying the death penalty under Finnish law prevailed during the war. Several hundred people were executed under what was said to be an ex post facto legal arrangement. During the war, and before the trial was established, thousands of people had been executed without trial by both parties.
After World War II, Finland came under pressure to punish political leaders who considered Allied forces responsible for Finland's involvement in the war. The ex post facto law was passed in the fall of 1945 to allow prosecution for war responsibility, and eventually eight politicians were punished.
In other postwar cases, weapons cache cases, ex post facto laws were passed in 1947 so that military personnel could be prosecuted for illegally preparing guerrilla resistance in the event of a Soviet occupation.
French
In France, so-called " lois rÃÆ' Â © troactives " (retroactive law) is technically prohibited by Article 2 of the Civil Code, which states that: "Legislation only provides for the future; it has no retrospective operation". But in practice, since the Civil Code does not have constitutional constitutional status and can therefore be ruled out by subsequent legislation, Conseil Constitutionnel has determined that retroactive laws may be passed within certain limits - as in the case of financial or tax regulations -, especially if regarded as "public interest"; this has been proven by a series of decisions issued by Consel Conservator on retroactive tax laws.
However, in criminal law, ex post facto sanctions are effectively prohibited under Article 112-1 of the French Criminal Code, except in cases where retroactive applications benefit the accused (called retroactivity) in mitius "). constitutional, because the non-retroactive principle is contained in Article 8 of the Declaration of Human and Citizen Rights, which has a constitutional status under French law. [4] The experiment was held after the release of 1944 France introduced the status of indignitÃÆ' Â © nationale to Nazi collaborators as a way of avoiding legal ex post facto .
German
Article 103 of the basic law of Germany requires that an act be punishable only if it has been punished by law at the time it was committed (in particular: by written law, Germany following civil law).
Robert A. Taft, at the time of the US Senator from Ohio, asserted that the Nuremberg Trials after World War II were based on the ex post facto law because the Allies did not negotiate the London Charter, which defined the crime. against humanity and create an International Military Tribunal, until after the alleged action. Others, including the International Military Tribunal, argue that the London Charter is only restated and provides jurisdiction to prosecute unlawful offenses by the Kellogg-Briand Pact, the League Agreement, and the Hague Conventions.
The legal issue of ex post facto was also relevant in the 1990s because of discussions about trials of East German soldiers killing fugitives at the Inner-German border ( MauerschÃÆ'¼tzen-Prozesse - Wall-shooters/-guards experiment ). The German court in this case is repeated with the formula Radbruch.
Hungarian
In 2010, the parliament set a 98% punitive tax on the income of more than two million forint received either as a retirement package or as severance pay in the previous five years in the government sector.
India
In India, without using the expression "ex post facto law", the underlying principle has been adopted in article 20 (1) of the Indian Constitution in the following words:
No person shall be punished for any offense except the violation of the law applicable at the time of the commission of an alleged offense, or to be punished by a greater penalty than was alleged under the law applicable at the time of committing a breach.
Furthermore, what article 20 (1) prohibits are convictions and penalties under the law of ex post facto for the actions taken beforehand, but not enacted or invalidate the law. Thus, there is a difference between the position of India and America at this point; whereas in the United States, the ex post facto law itself is illegitimate, not so in India. The court may also interpret the law in such a way that any objections against it from retrospective operations may be removed.
An example for retrospective law in India is the Karnataka Schedule of Caste and Tribal Scheduling (Certain Transfer of Land) Act, 1978 in the state of Karnataka.
Indonesia
The Indonesian Constitution prohibits citizens from trying under retroactive laws under any circumstances. It was tested in 2004 when the belief of one of Bali bombers under a retroactive anti-terrorist law was canceled.
Iran
Ex post facto , in all contexts, is prohibited by Article 169 (Chapter 11) of the Iranian constitution.
Republic of Ireland
The imposition of retroactive criminal sanctions is prohibited by Article 15.5.1 Â ° Irish Constitution. Retroactive changes from civil law have also been found to be in violation of the Constitution when they will result in damages in the right to damage before the court, the Supreme Court of Ireland has found that the right is a constitutionally protected property.
Israel
Israel imposed "Nazi Nazi Nazi Nazi Law" (Punishment) "for the purpose of punishing the acts that occurred during the Second World War, when Israel was absent as a state.The law was used to punish Adolf Eichmann and others.
Italy
Article 25, paragraph 2, of the Italian Constitution, stipulates that "nothing can be punished but according to the law prevailing before the act is committed", prohibiting indictments under retroactive law. Article 11 of the preliminary provisions of the Civil Code of Italy and Article 3, paragraph 1, of the Statute of the right of taxpayers, prohibits the law from retroactive to the principle: the provision may be reduced, however, by acts of ordinary force; on the contrary, non-retroactivity in criminal law is considered absolute.
Japanese
Article 39 of the Japanese Constitution prohibits the application of retroactive laws. Article 6 of the Japanese Criminal Code further stipulates that if the new law came into force after the act was committed, a lesser sentence should be granted.
Lithuania
Lithuania has no constitutional prohibition on the law of ex post facto . Retroactive criminal sanctions are prohibited by Article 2, Section 1 (Chapter 1) of the Criminal Code of the Republic of Lithuania. Retroactive administrative sanctions are prohibited by Article 8 of the Republic of Lithuanian Administration Code.
Lithuanian lawyer Dainius? Alimas argues that there has been an application of retroactive law against genocide (and later articles adopted from the Criminal Code) against participants in Soviet repression against Lithuanian guerrilla warriors and their supporters, and provides examples of such decisions. Article 99 of the Criminal Code of the Republic of Lithuania was introduced only on 26 September 2000 and therefore can not be used in the events of 1944-1953.
Mexico
According to the first and second paragraphs of Article 14 of the Mexican Constitution, the application of retroactive law is prohibited if it harms a person's right. But the new law can be applied if it benefits the person.
Dutch
Article 4 of the General Provisions Act (effective since 1838) states that "The law has no retroactive effect".
Article 1 of the Criminal Law states that no action can be punished without pre-existing laws, and that in the case of an act punishable but the law is amended after the "most favorable" criminal act (for a suspect) of the two laws shall filed.
In the Civil Code there is no such provision.
New Zealand
Section 7 of the Interpretation Act of 1999 provides that enforcement has no retrospective effect. The New Zealand Law of Nations 1990 also affirms New Zealand's commitment to the International Covenant on Civil and Political Rights and the Universal Declaration of Human Rights, with section 26 preventing the application of retroactive penalties. This is further strengthened under section 6 (1) of the current Punishment Act 2002 which provides, "[p] enactments have no retrospective effect against the offender's losses" irrespective of any conflicting provisions.
Section 26 of the Bill of Rights and the previous penal code, the 1985 Criminal Justice Act, caused significant deviations among judges when the New Zealand Parliament introduced laws that had the effect of imposing retrospective penalties for crimes involving elements of home invasion. Ultimately, the difference is limited by what some labeled artificial logic in the case of R v Pora and R v Poumako .
Norwegian
Article 97 of the Norwegian constitution prohibits the law for a retroactive effect. The prohibition applies to both criminal and civil law, but in some civil cases, only unwarranted retroactive effects will be found unconstitutional.
Pakistan
Article 12 of the Constitution of Pakistan prohibits any law to be granted retroactive by stating:
- 12.1 - There is no law that would authorize a person: -
- 12.1.a - for any act or omission that can not be punished by law at the time of the act or disappearance; or 12.1.b - for offenses punishment greater than, or the like that differ from, the penalties prescribed by law for the offense at the time the offense is committed.
Philippines
The 1987 Constitution in the Philippines strictly prohibits the passage of the ex post facto law. Article III (Bill of Rights), Section 22 specifically states: "No ex post facto law or bill of attainder shall be applied."
However, the Mayan Crime Prevention Act, which came into effect on October 3, 2012, was criticized for being ex post facto .
Poland
The application of retroactive law is prohibited by Article 3 of Polish civil law, and the rule of law prohibiting such retroactive applications is generally memorized as the Latin Lexus retro non-agit ("non-retroactive law") sentence. The article, however, allows the application of the Parliament Law retroactively if it is clearly understood from the text or its purpose.
Portugal
Article 18 of the Portuguese Constitution prohibits the application of retroactive any laws that restrict the right; Article 29 of the Portuguese Constitution prohibits the application of retroactive criminal law; Article 103 prohibits the application of retroactive taxes.
Romanian
Article 15 (2) of the Constitution of Romania states that the law only acts for the future, except for a more favorable criminal or administrative law.
Russian
Ex post facto penalties in criminal and administrative law are prohibited by article 54 of the Constitution; ex post facto of the tax law under section 57 of the Constitution.
Spanish
Article 9.3 of the Spanish Constitution guarantees the non-retroactive principle of unfavorable penalty provisions or limits the rights of individuals. Therefore, "ex post facto" criminal laws or other retroactive penalty provisions are prohibited constitutionally.
As well as the Statute law mentioned above, this now also includes 'court-made law'. The Parot doctrine, in which the terrorists were denied the right (enshrined in the 1973 Statute) to obtain a reduction in their term of punishment by a Spanish court judgment in 2006 judged by the European Court of Human Rights contrary to the relevant article. on retroactivity & amp; freedom and security in 2013.
South Africa
Article 35 (3) The South African Rights Bill prohibits criminal law
In Sweden, retroactive criminal sanctions and other retroactive legal effects of criminal acts because the State is prohibited by chapter 2, section 10 of the Government Instrument (Regeringsformen ). Retroactive taxes or levies are not prohibited, but they can have retroactive effects that regain only when the new tax bill is proposed by the government. The retroactive effect of taxes or fees reaches from that time until the bill is passed by parliament.
When the Swedish Succession Act was changed in 1979, and the throne was inherited irrespective of gender, the right of inheritance was withdrawn from all the Charles XIV sons of John (king 1818-44) except for the current king of Carl XVI Gustaf. Thus, the heir's title was moved from the newly born Prince William to his older sister, Crown Princess Victoria.
The Swedish Parliament voted in 2004 to abolish the inheritance tax on January 1, 2005. However, in 2005 they retro-actively decided to move the date to December 17, 2004. The main reason was to abolish inheritance tax for many Swedish victims in 2004. The Indian Ocean Earthquake, which occurred on 26 December.
Turkish
Ex post facto penalties are prohibited by Article 38 of the Turkish Constitution. It states:
- c1. No one shall be liable for any act which is not a criminal offense under the law applicable at the time of its execution; no one will be awarded more severe penalties for offenses other than the penalties imposed at the time the violation was committed.
- c2. The provisions of the foregoing also apply to statutory restrictions on violations and penalties and the results of conviction.
Accordingly, the article does not prohibit in magazines laws, ie cases where retroactive applications benefit the defendant.
United Kingdom
In Britain, the law of ex post facto is underestimated, but permissible under the doctrine of parliamentary sovereignty. Historically, all Parliamentary acts before 1793 were ex post facto legislation, since the date of their effect was the first day of the session in which they were passed. This situation was corrected by the Acts of Parliament (Commencement) Act 1793.
Some laws are still retrospectively passed: for example, the Pakistan Act of 1990 (which England has changed its law as a result of the Commonwealth of Nations after re-admitting Pakistan as a member) is one of those laws; although enacted on June 29, 1990, section 2, paragraph 3 states that "this Act shall be deemed valid on October 1, 1989," nine months prior to effect.
Criminal retrospective laws are prohibited by Article 7 of the European Convention on Human Rights, in which the United Kingdom is a signatory, but some notable legal authorities have expressed their opinion that parliamentary sovereignty is a priority even above this. For example, the 1991 War Crimes Act created an ex post facto jurisdiction from British courts for war crimes committed during the Second World War. Another important example of a case showing the doctrine of parliamentary supremacy in action is Burmah Oil Co. Ltd. v Lord Advocate, who retrospectively amends the law on compensation resulting from the scorched earth action in Burma during the war. Recently, the Police (Detention and Bail) Act 2011 retroactively overrides a controversial court ruling resulting from a mistake in drafting the 1984 Criminal Policies and Criminal Procedures that could potentially undo thousands of criminal convictions.
One example of the ex post facto criminal law in Britain is the 2003 Criminal Justice Act. This law allows people to be released because the killings will be retried if there is "new, convincing, reliable and substantial evidence" that the freed person really guilty. This Justice Law is retroactive and can be used to reclaim those released before the Criminal Justice Act came into force in 2005, or even before the Criminal Justice Act was passed in 2003. As a result, the defendants released in Stephen Lawrence's murder were allowed to be tried again, although the killing occurred in 1993 and the defendants were released in 1996. Many people have criticized the Criminal Justice Act for the abolition of an important ban against both ex post facto and double-jeopardy law.
The tax laws have on several occasions been amended to retrospectively prohibit tax evasion schemes. The most significant example is known of the Arrangement of the Double Taxation Agreement under which the 2008 Financial Law with BN66 retrospectively amends the 1987 law that creates a large tax liability for 3,000 people in which there is no prior obligation.
United States
In the United States, Congress is prohibited from granting ex post facto laws by Article 3 of Article I, Section 9 of the Constitution of the United States of America. States are prohibited from passing the ex post facto law with article 1 of Article I, Section 10. This is one of the few restrictions the United States Constitution makes on federal and state powers. government before the Fourteenth Amendment. Thomas Jefferson described them as "equally unfair in civil cases as in criminal cases". However, over the years, when deciding cases of ex post facto, the United States Supreme Court has repeatedly referred to its verdict at Calder v. Bull, where Judge Samuel Chase held that the ban applies only to criminal matters, not civil matters, and sets out four categories of unconstitutional law ex post facto . This case relates to Article I, Section 10, the prohibition of law ex post facto , as it concerns the laws of the State of Connecticut.
Not all laws with retroactive effects are considered unconstitutional. One current US law that has a retroactive effect is the Child Safety and Protection Act of Adam Walsh in 2006. This law imposes new registration requirements on law-abused offenders and also applies to offenders whose crimes were committed before the law enacted. The US Supreme Court ruled at Smith v. Doe (2003) that forces sex offenders to register their presence on a regular basis, and posting personal information about them on the Internet, does not violate constitutional restrictions against ex post facto law, because this law not impose any penalties.
In Starkey v. The Oklahoma Improvement Department, Oklahoma State Supreme Court found the Oklahoma Sex Offenders Registration Act, or SORA, to be punished in nature, if not intend. While the law in question has been ruled out as retroactive, the Oklahoma Department of Corrections has implemented retroactive new laws, and "also found retroactive applications from the level of assignment provisions of 57 OS Supp 2007, 582.1 - 582.5, as amended, ex post facto clause. "
Controversy also arises in connection with the law of sexual predatory predator (SVP), which allows unlimited commitment of a person with a mental disorder that affects them to abuse children. This problem occurs in the case of Kansas v. Hendricks . In Hendricks , a man with a long history of sexually abused children is scheduled to be released from prison shortly after the enactment of the Kansas SVP act. Instead of being released, he is committed on the grounds that he has a mental disorder. Hendricks opposes the law of ex post facto and dual reasons. The Kansas Supreme Court overturned the Act, but the United States Supreme Court overturned the ruling and ruled that the law is constitutional on the grounds that the law does not impose criminal penalties.
Another example is the Violent Domestic Violence Detainee, Ban Ban, where gun bans are imposed on those convicted of minor violations of domestic violence and on the subject of arrest warrants (which do not require criminal convictions). These people can now be sentenced to up to ten years in federal jail for possession of firearms, regardless of whether the weapon is legally owned when the law is passed. The law has been enforced legally because it is considered a rule, not a punishment; it is a status violation.
Finally, at Calder v. Bull , the court explicitly states that the law that "eases" criminal acts is only retrospective, and not the ex post facto law. Experts argue that, as a matter of history, the expression ex post facto refers to civil and criminal law.
Under administrative law, federal agencies may apply their rules retroactively if Congress has given them authority; otherwise, retroactive applications are generally prohibited. The application of retroactive regulation is disliked by the court for several reasons. The courts enforce a retroactive regulation in which Congress has firmly given such retroactive powers to agents, as they did at Bowen v. Georgetown University Hospital .
Rules relating to ex post facto effects on the U.S. Federal Sentencing Guidelines can be found at U.S.S.G. Ã,§ 1B1.11 (2012).
Lihat juga Bouie v. Kota Columbia , Rogers v. Tennessee , Stogner v. California , Republik Austria v. Altmann , James Bamford dan Samuels v. McCurdy .
Maps Ex post facto law
Perlakuan oleh organisasi dan perjanjian internasional
Hukum pidana internasional
In international criminal law, Nuremberg courts demand war crimes and crimes against humanity committed in World War II. Although the Nuremberg Charter, the procedural law in which the proceedings are held, the date of VE Day, the court rejected the defense that the criminal law is ex post facto, for that reason derived from previous agreements such as the Hague Convention. 1899 and 1907. The International Criminal Court established in 2002 was unable to adjudicate crimes committed before 2002.
Article 11, paragraph 2 of the Universal Declaration of Human Rights provides that no person shall be found guilty of a criminal law that does not exist at the time of the offense or suffer more severe punishment than what was at the time of the offense. However this allows the application of domestic or international law.
A very similar provision is found in Article 15, paragraph 1 of the International Covenant on Civil and Political Rights, replacing the term "criminal offense" with "criminal offense". He also added that if a lighter sentence is awarded for after the offense occurs, a less severe sentence will be retroactive. Paragraph 2 adds the provision that paragraph 1 does not prevent trying and punishing for criminal acts in accordance with the general principles of law recognized by the community of nations. Specifically dealing with the use of the death penalty, article 6, paragraph 2 provides relevant sections that the death penalty can only be imposed "for the most serious crimes in accordance with the law applicable at the time of the crime".
African Charter of Human Rights and People
Article 2, paragraph 7 of the African Charter on Human and Peoples' Rights provides that "[a person] may be condemned for an act or omission which is not a lawful offense at the time it is committed." No punishment may be charged with a non- there is a provision made at the time it was done. "
American Declaration on the Rights and Obligations of Man
Article 25 of the American Declaration on the Rights and Duties of Man provides in part that "a person may be deprived of his liberty except in cases and in accordance with the procedure prescribed by the existing law." The right to be tried in accordance with the "pre-existing law" is reaffirmed in article 26.
Arab Charter on Human Rights
Article 15 of the Arab Charter on Human Rights states that "[n] crime and no punishment can be established without the provisions of the preceding law." In all circumstances, the law most favorable to the accused shall be applied. "
European Convention on Human Rights
Effectively all European countries (except Belarus), including all EU countries and the European Economic Area, are bound by the European Convention on Human Rights. Article 7 of the Convention shall reflect the language of both paragraphs of Article 15 of the International Covenant on Civil and Political Rights, with the exception that it does not include that subsequent light punishment shall apply.
Grammatical form and use
This phrase may not appear to be grammatically correct in Latin if it is interpreted to consist of prepositions ex , prepositions posts , and nouns with an incorrect grammatical case to agree with > post . Indeed, Digesta Iustiniani (15.3.10.8.3, 20.1.22.pr2, etc.) indicates a two-word phrase, ex postfacto : from postfactum (an action) , or more naturally, of the law enacted thereafter . This same work, however, also uses the three-word phrase ex post facto, (2.14.17.4.2, 4.6.17.1.1, passim ), suggesting that > posts may be best understood as an adverb. The adverbial use of posts is not at all unusual. For example, classical author/advocate/politician Marcus Tullius Cicero uses phrases like multis post annis ( De Re Publica 2.5.8 and elsewhere).
Therefore, ex post facto or ex postfacto is a native adverbial phrase, the use of which is indicated by the sentence "He is declared guilty (ex post facto) "The law itself will be the law of postfactum ( lex postfacta ); However, regardless of its excessive or circular nature, the phrase ex post facto is used.
In Poland the phrase lex retro non agit ("the law does not operate retroactively") is often used.
See also
- A priori and a posteriori
- Ex ante
- Nulla poena sine lege - the principle that no one can be punished for an unlawful act
- Richard Roose
- The case of Rokotov-Faibishenko
- The grandfather clause, which specifically allows it to be allowed before the law
References
External links
- Ã, "Ex Post Facto". New International Encyclopedia . 1905.
Source of the article : Wikipedia
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