Government of Vichy France

The Government of Vichy France was the collaborationist ruling regime or government in Nazi-occupied France during the Second World War. Of contested legitimacy, it was finally headquartered in the town of Vichy in occupied France, but it initially took shape in Bordeaux under Marshal Philippe Pétain as the successor to the French Third Republic in June 1940. The government remained in Vichy for four years, but was escorted to Germany in September 1944 after the Allied invasion of France. It then operated as a government-in-exile until April 1945, when the Sigmaringen enclave was taken by so-called Free French forces. Pétain was permitted to travel back to France (through Switzerland), by then under control of the technically illegal Provisional French Republic, and subsequently put on trial for treason.
Philippe Pétain, a hero of World War I, known for applying the lessons of the Second Battle of Champagne to minimize casualties in the Battle of Verdun, became commander of French forces in 1917. He came to power in World War II as a reaction to the stunning defeat of France in early 1940. Pétain blamed a lack of men and material for the defeat, but had himself participated in the egregious miscalculations that led to the Maginot Line, and the belief that the Ardennes were impenetrable. Nonetheless, Pétain's cautious and defensive tactics at Verdun had won him acclaim from a devastated military, and poet Paul Valéry called him "the champion of France".
Recalled by Paul Reynard from his post as Ambassador to Spain, Pétain became Vice-Premier in May 1940, when the only question was whether the French Army should surrender or the French government should sue for an armistice. Reynard's Cabinet were against him and he resigned, recommending President Albert Lebrun appoint Pétain the Premier, which he did on 16 June. The Cabinet voted overwhelmingly for an Armistice and the government's representatives signed one with Germany on 22 June 1940.
With France fallen to the Germans, the British judged the risk was too high of the French Navy falling into German hands, despite French assurances to the contrary, and twelve days later, in the attack on Mers-el-Kébir on 3 July 1940, they sank one battleship and damaged five others, also killing 1,297 French servicemen. The French Government were furious. Pétain severed diplomatic relations with the United Kingdom on 8 July. The next day the National Assembly voted to revise the constitution, and the following day, 10 July, the National Assembly voted absolute power to Pétain, thus ending the French Third Republic. In retaliation for the attack at Mers el Kébir, French aircraft raided Gibraltar on 18 July but did little damage.
Pétain moved the Government from Bordeaux and established the French State, an authoritarian government, at Vichy, with central planning a key feature, as well as tight government control. French conventional wisdom, particularly in the administration of François Mitterrand, long held that the French government under Petain had merely sought to make the best of a bad situation. Vichy policy towards the Germans was at least in part founded on concern for the 1.8 million French prisoners of war. As President Jacques Chirac subsequently acknowledged, even Mussolini stood up to Hitler and in so doing saved the lives of thousands of Jews, many of them French. Antisemitism in France began before Pétain, but became a key characteristic of his time in power, as manifested in Vichy anti-Jewish legislation.
Until the invasion, the French Third Republic had been the government of France since the defeat of Napoleon III and the end of the Franco-Prussian War in 1870. It was dissolved by the French Constitutional Law of 1940, which gave Pétain and his Cabinet the power to write a new constitution. This meant that the previous French Constitutional Laws of 1875, no longer applied.
In the wake of the Battle of France that culminated in the disaster at Dunkirk, the French government declared Paris an open city and relocated firstly to Tours, then to Bordeaux on 10 June 1940 to avoid capture. On 22 June, France and Germany signed the Second Armistice at Compiègne. The government again relocated, this time to Vichy. Still led by Pétain, it replaced the Third Republic. It administered the zone libre in the south of France until November 1942, when Germans and Italians occupied the zone under Case Anton following the Allied landings in North Africa under Operation Torch. Germany occupied northern France and the Atlantic coast, and the Italians occupied a small territory in the southeast. The French Government continued the civil administration of France.
At the time of the armistice, the French and the Germans both thought Britain would come to terms any day, so it included only temporary arrangements. France agreed to its soldiers remaining prisoners of war until hostilities ceased. The terms of the armistice sketch out a "French State" (État français), whose sovereignty and authority in practice were limited to the zone libre, although in theory it administered all of France. However, the fiction of French independence was so important to Laval, in particular, that he agreed to requisition French workers for Germany to prevent the Germans from doing it unilaterally for the zone occupée alone.
The legitimate government of France eventually relocated to Vichy, but Charles de Gaulle, who had fled to England, declared an illegal government in exile in London, and broadcast appeals to French citizens to resist the occupying forces. Britain shortly thereafter recognized his Empire Defence Council as the legitimate French government. Under the terms of the armistice the French State was allowed an army of 100,000 to defend itself and to administer its colonies. Most of these colonies simply recognized the shift in power, but their allegiance to Vichy shifted once the Allies invaded French North Africa in Operation Torch. Britain however outraged the French by attacking part of their moored fleet because the British were unwilling to risk it falling into Axis hands, despite French Government promises this would never happen.
Alsace-Lorraine, which France and Germany had long disputed, was simply annexed. When Allied forces landed in French North Africa under Operation Torch, Germany's response was to send troops into the militarily unoccupied zone in Case Anton.
The Philippe Pétain administration was the last administration of the French Third Republic, succeeding on 16 June 1940 to Paul Reynaud's cabinet. It formed in the middle of the Battle of France debacle, when Nazi Germany invaded France at the beginning of the Second World War. It was led until 10 July 1940 by Philippe Pétain, and was responsible for the armistice. Charles de Gaulle, favored fighting on in the Empire Defense Council and fled to England. On 23 June 1940 the French Cabinet struck de Gaulle's name from the Army List for treason. It was followed by the fifth administration of Pierre Laval, the first administration of the Vichy France regime.
Paul Reynaud, who had been the French President of the Council since 22 March 1940, resigned early on the evening of 16 June, and President Albert Lebrun called for Pétain to form a new government.
Pétain recruited Adrien Marquet for Interior and Pierre Laval for Justice. Laval wanted an offer of Justice. On the advice of François Charles-Roux, the Secretary-General for Foreign Affairs, and with the support of Maxime Weygand and Lebrun, Pétain stood firm, which led Laval to withdraw, followed by Marquet in solidarity. After the armistice, Raphaël Alibert convinced Pétain of the need to rely on Laval, and the two rejoined the government.
Pétain obtained the participation of the SFIO by bringing back Albert Rivière and André Février [fr] with the agreement of Léon Blum.
The following is a list of the French government ministers in the administration of Pétain under the Third Republic.
On 10 July 1940, the French National Assembly Assemblée nationale met in Vichy and voted to give absolute power to Pétain in the Constitutional Law of 1940, effectively dissolving itself, and ending the Third Republic. The Vichy regime began.
In the French State under Pétain, French authorities willingly enacted and enforced antisemitic laws, unprompted by Berlin. His collaborationist government helped send 75,721 Jewish refugees and French citizens to Nazi death camps.
The fifth government formed by Pierre Laval was the first administration formed by Pétain under the Vichy regime after the vote of 10 July 1940 ceded full constituent powers to Pétain. The government ended on 13 December 1940 with Laval's dismissal. This administration was not recognized as legitimate by the Empire Defense Council of the government of Free France, which the British Government had quickly recognized as the legitimate government of France following De Gaulle's radio appeals to the French public.
The government of Philippe Pétain signed the armistice with Germany on 22 June 1940, put an end to the Third Republic on 10 July 1940 by a vote conveying full powers to Pétain and followed up with three Vichy Constitutional Acts on 11 July. Meanwhile, on 11 July General de Gaulle created the Empire Defense Council, which was recognized by the British Government as the legitimate successor of the Third Republic, which had allied itself with Great Britain in the war against the Nazis.
On 12 July 1940 Pétain named Pierre Laval, second Minister of State of the last government of the Third Republic under Philippe Pétain as vice-president of the Council, while Pétain remained simultaneously head of state and head of government. Constitutional Act #4 made Laval next in the line of succession should something happen to Pétain. On 16 July, Pétain formed the first government of the Vichy régime and kept Pierre Laval on as vice-president of the Council.
Laval's administration more or less coincides with the arrival in France of Fritz Sauckel, tasked by Hitler with procuring qualified manpower. Until then, fewer than 100 000 French workers had voluntarily travelled to Germany to work Refusal to send 150 000 skilled workers had been one of the causes of the fall of Darlan. Sauckel demanded 250,000 additional workers before the end of July 1942.
Laval fell back on his favorite tactic of negotiating, stalling for time, and seeking reciprocation. He proposed the relève, in which a prisoner of war would be freed for every three workers sent to Germany, and announced it 22 June 1942, after the same day, in a letter to Joachim von Ribbentrop, the German minister of foreign affairs, Laval framing the relève policy as French participation, by providing workers, in the German war effort.
"They give their blood. Give your labour to save Europe from Bolshevism". Nazi propaganda leaflet suggesting French workers travel to Germany to support the war effort on the eastern front (1943)
The voluntary relève, was replaced by the Service du travail obligatoire (STO) which began in August 1942 throughout occupied Europe. To Sauckel, the relève had failed, since fewer than 60 000 French workers had gone to Germany by the end of August. He threatened to issue an ordonnance to requisition male and female manpower. This ordonnance would only have had effect in the occupied zone. Laval negotiated a French law covering both zones instead. Laval put workplace inspection, the police and the gendarmerie at the service of forced impressments of labor, and tracking Service du travail obligatoire scofflaws. Forced impressments of workers, guarded by gendarmes until they boarded a train, drew hostile reactions. On 13 October 1942 the Oullins incidents broke out in the suburbs of Lyon, where workers at the railway station went on strike. Someone wrote "Laval assassin!" (Laval murderer) on the trains. The government was forced to back away; on 1 December 1942 only 2,500 requisitioned workers had left the southern zone. On 1 January 1943, Sauckel demanded, in addition to the 240,000 workers already sent to Germany, a new contingent of 250,000 men, before mid-March To meet these objectives, German forces organised ineffectively brutal raids, which led Laval to propose to the Council of Ministers on 5 February 1943 legislation creating the STO, under which youth born in 1920-1922 were requisitioned for work service in Germany Laval mitigated his legislation with many exceptions.
In all, 600 000 men left between June 1942 and August 1943 despite what Sauckel denounced in a letter to Hitler as "pure and simple sabotage", after meeting more than seven hours on 6 August 1943 with Laval, who again attempted to minimize the number of requisitioned workers and refused to his demand for 50 000 workers for Germany before the end of 1943.
On 15 September 1943, Reich minister for Armament and War Production Albert Speer reached an agreement with Laval minister Jean Bichelonne — an agreement Laval was counting on to "block the deportation machine". Many businesses working for Germany were removed from Sauckel's requisition. Individuals were protected but the French economy as a whole was integrated into that of Germany. In November 1943, Sauckel demanded, without much success, 900 000 additional workers. On orders from Berlin, French workers stopped leaving for Germany on 7 June 1944, after Allied landings in Normandy.
In the end, the STO caused thousands of young réfractaires to embrace the Resistance, which created the maquis. In the eyes of the French, Laval took ownership of the measures imposed by Sauckel and became the French minister who sent French workers to Germany.
The following joined on 16 July 1940:
The following joined in September 1940, replacing eight dismissed ministers:
The following were appointed on 18 November 1940:
Laval was sacked by Pétain on 13 December 1940. This came as a surprise to Laval. He was replaced by a triumvirate of Flandin, Darlan, and General Charles Huntziger. This caused friction with Hitler's representative Otto Abetz, who was furious about Vichy's insufficient collaboration, and closed the demarcation line in response.
The second government of Pierre-Étienne Flandin was the second government of the Vichy regime in France, formed by Philippe Pétain. It succeeded the first Pierre Laval government on 14 December 1940 and ended on 9 February 1941.
The Germans were unhappy after the sacking of Laval on 13 December, and suspicious of Flandin and whether he was sufficiently collaborationist. Darlan met with Hitler on 25 December and endured his anger, assuring Hitler that Vichy was still committed to collaboration. There followed several months of intrigue while Flandin was in power, during which Pétain even considered taking Laval back, however Laval was now no longer interested in anything other than supreme power. The impasse was lifted after the Germans had a change of heart with respect to Darlan, although not toward Flandin who they considered insufficiently collaborationist, and this led to Flandin's resignation on 9 February 1941, and Darlan's accession.
The majority of ministers, secretaries, and delegates were carried over from the Laval government that ended 13 December 1940.
Flandin's short period in power was marked by intrigue and Hitler's suspicions about Vichy's level of collaboration with Germany. When it was clear that Darlan had more confidence in Berlin than Flandin did, Flandin resigned on 9 February 1941, leaving the way clear for Darlan.
After two years at the head of the Vichy government, Admiral Darlan was unpopular and had strengthened ties with Vichy forces, in an expanded collaboration with Germany which seemed to him the least bad solution, and had conceded a great deal, turning over the naval bases at Bizerte and Dakar, an air base in Aleppo in Syria, as well as vehicles, artillery and ammunition in North Africa and Tunisia, in addition to arming the Iraqis. In exchange Darlan wanted the Germans to reduce the constraints under the armistice, free French prisoners, and eliminate the ligne de démarcation. This irritated the Germans. On 9 March 1942, Hitler signed a decree giving France a chief of the SS and police leader (HSSPF) tasked with organizing the "Final Solution", following the Wannsee Conference with the French police. The Germans demanded the return of Laval to power, and broke off contact. The Americans intervened on 30 March to prevent another Laval administration.
After two years at the head of the Vichy regime, François Darlan's government was unpopular, a victim of the fool's bargain he had made with the Germans. Darlan committed Vichy into further collaboration with Germany as the least bad solution for him, giving up much ground: handover of the naval bases at Bizerte and Dakar, an air base in Aleppo (Syria), vehicles, artillery and ammunition in North Africa, Tunisia, not to mention the delivery of arms to Iraq.
In exchange, Darlan asked the Germans for a quid pro quo (reduction of the constraints of the armistice: release of French prisoners, elimination of the demarcation line and fuel oil for the French fleet), which irritated them.
On 9 March 1942, Hitler signed the decree endowing France with a "Higher SS and police leader" (HSSPf) responsible for organizing the Final Solution after the Wannsee Conference with the French Police. The Germans then demanded that Pierre Laval return to power, and in the meantime they broke off all contact.
On 30 March 1942, the Americans intervened in Vichy against Laval's return to power.
On 17 August 1944, Pierre Laval, head of government and minister of foreign affairs, held his last council of government with five ministers. With permission from the Germans, he attempted to call back the prior National Assembly with the goal of giving it power and thus impeding the communists and de Gaulle. So he obtained the agreement of German ambassador Otto Abetz to bring Édouard Herriot, (President of the Chamber of Deputies) back to Paris. But ultra-collaborationists Marcel Déat and Fernand de Brinon protested against this to the Germans, who changed their minds and took Laval to Belfort along with the remains of his government, "to assure its legitimate security", and arrested Herriot.
On 20 August 1944 Pierre Laval was taken to Belfort by the Germans along with the remains of his government, "to assure its legitimate security". Vichy head of state Marshal Philippe Pétain was conducted against his will to Belfort on 20 August 1944. A governmental commission directed by Fernand de Brinon was proclaimed on 6 September. On 7 September, they were taken ahead of the advancing Allied Forces out of France to the town of Sigmaringen, where they arrived on the 8th, where other Vichy officials were already present.
Hitler requisitioned the Sigmaringen Castle for use by top officials. This was then occupied and used by the Vichy government-in-exile from September 1944 to April 1945. Pétain resided at the Castle, but refused to cooperate, and kept mostly to himself, and ex-Prime Minister Pierre Laval also refused. Despite the efforts of the collaborationists and the Germans, Pétain never recognized the Sigmaringen Commission. The Germans, wanting to present a facade of legality, enlisted other Vichy officials such as Fernand de Brinon as president, along with Joseph Darnand, Jean Luchaire, Eugène Bridoux, and Marcel Déat.
On 7 September 1944, fleeing the advance of Allied troops into France, while Germany was in flames and the Vichy regime ceased to exist, a thousand French collaborators (including a hundred officials of the Vichy regime, a few hundred members of the French Militia, collaborationist party militants, and the editorial staff of the newspaper Je suis partout) but also waiting-game opportunists also went into exile in Sigmaringen.
The commission had its own radio station (Radio-patrie, Ici la France) and official press (La France, Le Petit Parisien), and hosted the embassies of the Axis powers: Germany, Italy and Japan. The population of the enclave was about 6,000, including known collaborationist journalists, the writers Louis-Ferdinand Céline and Lucien Rebatet, the actor Robert Le Vigan, and their families, as well as 500 soldiers, 700 French SS, prisoners of war and French civilian forced laborers. Inadequate housing, insufficient food, promiscuity among the paramilitaries, and lack of hygiene facilitated the spread of numerous illnesses including flu and tuberculosis) and a high mortality rate among children, ailments that were treated as best they could by the only two French doctors, Doctor Destouches, alias Louis-Ferdinand Céline and Bernard Ménétrel.
On 21 April 1945 General de Lattre ordered his forces to take Sigmaringen. The end came within days. By the 26th, Pétain was in the hands of French authorities in Switzerland, and Laval had fled to Spain. Brinon, Luchaire, and Darnand were captured, tried, and executed by 1947. Other members escaped to Italy or Spain.
The liberation of France in 1944 dissolved the Vichy government. The Provisional Consultative Assembly requested representation, leading to the Provisional Government of the French Republic (French: Gouvernement provisoire de la République française, GPRF), also known as the French Committee of National Liberation. Past collaborators were discredited and Gaullism and communism became political forces.
De Gaulle led the GPRF 1944-1946 while negotiations took place for a new constitution, to be put to a referendum. De Gaulle advocated a presidential system of government, and criticized the reinstatement of what he pejoratively called "the parties system". He resigned in January 1946 and was replaced by Felix Gouin of the French Section of the Workers' International (Section française de l'Internationale ouvrière, SFIO). Only the French Communist Party (Parti communiste français, PCF) and the socialist SFIO supported the draft constitution, which envisaged a form of unicameralism. This constitution was rejected in the 5 May 1946 referendum.
French voters adopted the constitution of the Fourth Republic on 13 October 1946.
After the fall of France on 25 June 1940 many French colonies were initially loyal to Vichy. But eventually the overseas empire helped liberate France; 300,000 North African Arabs fought in the ranks of the Free French. French Somaliland, an exception, got a governor loyal to Vichy on 25 July. It surrendered to Free French forces on 26 December 1942. The length and extent of each colony's collaboration with Vichy ran a gamut however; antisemitic measures met an enthusiastic reception in Algeria, for example.
Operation Torch on 8 November landed Allied troops at Oran and Algiers (Operation Terminal) as well as at Casablanca in Morocco, to attack Vichy territories in North Africa—Morocco, Algeria and Tunisia—then take Axis forces in the Western Desert in their rear from the east. Allied shipping had needed to supply troops in Africa via the Cape of Good Hope, so the Mediterranean ports were strategically valuable.
The Battle of Dakar against the Free French Forces in September 1940 followed the Fall of France. Authorities in West Africa declared allegiance to the Vichy regime, as did the colony of French Gabon in French Equatorial Africa (AEF). Gabon fell to Free France after the Battle of Gabon in November 1940, but West Africa remained under Vichy control until the Allied landings in North Africa in November 1942.
The German military administration cooperated closely with the Gestapo, the Sicherheitsdienst (SD), the intelligence service of the SS, and the Sicherheitspolizei (Sipo), its security police. It also drew support from the French authorities and police, who had to cooperate under the armistice, to round up Jews, anti-fascists and other dissidents, and from collaborationist auxiliaries like the Milice, the Franc-Gardes and the Groupe mobile de réserve. The Milice helped Klaus Barbie seize members of the resistance and minorities including Jews for detention.
The two main collaborationist political parties, the French Popular Party (PPF) and the National Popular Rally (RNP), each had 20,000 to 30,000 members. Collaborationists were fascists and Nazi sympathisers who collaborated for ideological reasons, unlike "collaborators", people who cooperated out of self-interest. A principal motivation and ideological foundation among collaborationists was anti-communism. Examples of these are PPF leader Jacques Doriot, writer Robert Brasillach and Marcel Déat (founder of the RNP).
Some Frenchmen also volunteered to fight for Germany or against Bolsheviks, such as the Legion of French Volunteers Against Bolshevism. Volunteers from this and other outfits later constituted the cadre of the 33rd Waffen Grenadier Division of the SS Charlemagne (1st French).
The French State was quickly recognized by the Allies, as well as by the Soviet Union, until 30 June 1941 and Operation Barbarossa. However France broke with the United Kingdom after the destruction of the French Fleet at Mers-el-Kebir. The United States took the position that Vichy should do nothing adverse to US interests that was not specifically required by the terms of the armistice. Canada maintained diplomatic relations with Vichy until the occupation of southern France in Case Anton by Germany and Italy in November 1942.
In 1941, the Free French Forces fought with British troops against the Italians in Italian East Africa during the East African Campaign, and expanded operations north into Italian Libya. In February 1941, Free French Forces invaded Cyrenaica, led by Leclerc, and captured the Italian fort at the oasis of Kufra. In 1942, Leclerc's forces and soldiers from the British Long Range Desert Group captured parts of the province of Fezzan. At the end of 1942, Leclerc moved his forces into Tripolitania to join British Commonwealth and other FFF forces in the Run for Tunis.
French India under Louis Bonvin announced after the fall of France that they would join the British and the French under Charles de Gaulle.
Nearly 300,000 French Jews, 80% of those remaining, moved to the Italian zone of occupation to escape the Nazis. The Italian Jewish banker Angelo Donati had convinced the Italian civil and military authorities to protect the Jews from French persecution.
In January 1943 the Italians refused to cooperate with Nazi roundups of Jews living under their control and in March prevented them from deporting Jews from their zone. German foreign minister Joachim von Ribbentrop complained to Mussolini that "Italian military circles ... lack a proper understanding of the Jewish question." However, when the Italians signed the armistice with the Allies, German troops invaded the former Italian zone on 8 September 1943 and Alois Brunner, the SS official for Jewish affairs, formed units to search out Jews. Within five months, 5,000 Jews were caught and deported.
Given full constituent powers in the law of 10 July 1940, Pétain never promulgated a new constitution. A draft was written in 1941 and signed by Pétain in 1944, but never submitted nor ratified.
The United States gave Vichy full diplomatic recognition, and sent Admiral William D. Leahy as ambassador. President Roosevelt and Secretary of State Cordell Hull hoped to encourage elements in the Vichy government opposed to military collaboration with Germany. The Americans also wanted Vichy to resist German demands for its naval fleet or air bases in French-mandated Syria or to move war supplies through French territories in North Africa. Americans held that France should take no action not explicitly required by the terms of the armistice that could adversely affect Allied efforts in the war. The Americans ended relations with Vichy when Germany occupied the zone libre of France in late 1942.
The USSR maintained relations with Vichy until 30 June 1941, after the Nazis invaded Russia in Operation Barbarossa.
France for a long time took the position that the republic had been disbanded when power was turned over to Pétain, but officially admitted in 1995 complicity in the deportation of 76,000 Jews during WW II. President Jacques Chirac, speaking at the site of the Vélodrome d'Hiver, where 13,000 Jews were rounded up for deportation to death camps in July 1942, said: "France, on that day [16 July 1942], committed the irreparable. Breaking its word, it handed those who were under its protection over to their executioners", he said. Those responsible for the roundup were "450 policemen and gendarmes, French, under the authority of their leaders [who] obeyed the demands of the Nazis. .... the criminal folly of the occupiers was seconded by the French, by the French state".
The police under Bousquet collaborated to the point where they themselves compiled the lists of Jewish residents, gave them yellow stars, and even requisitioned buses and SNCF trains to transport them to camps such as Drancy.
The French themselves distinguish between collaborators, and collaborationists, who agreed with Nazi ideology and actively worked to further their domestic policies, as opposed to the majority of collaborators who worked with the Nazis reluctantly, and in order to avoid consequences to themselves.
The international tribunal at Nuremberg called Vichy régime agreements with the Nazis for deportation of citizens and residents void ab initio due to their "immoral content".
Notes
Citations
"Ordonnance du 9 août 1944 relative au rétablissement de la légalité républicaine sur le territoire continental – Version consolidée au 10 août 1944" [Law of 9 August 1944 Concerning the reestablishment of the legally constituted Republic on the mainland – consolidated version of 10 August 1944]. gouv.fr. Legifrance. 9 August 1944. Archived from the original on 16 July 2009. Retrieved 21 October 2015. Article 1: The form of the government of France is and remains the Republic. By law, it has not ceased to exist. Article 2: The following are therefore null and void: all legislative or regulatory acts as well as all actions of any description whatsoever taken to execute them, promulgated in Metropolitan France after 16 June 1940 and until the restoration of the Provisional Government of the French Republic. This nullification is hereby expressly declared and must be noted.Article 3. The following acts are hereby expressly nullified and held invalid: The so-called "Constitutional Law of 10 July 1940; as well as any laws called 'Constitutional Law';