Events occurring during its nineteenth year created grave problems for the Permanent Court of International Justice, and the Court survived the year with uncertain prospects for the future.

The Court held a series of meetings at The Hague from February 19 to February 26, and an order in the case of the Electricity Company of Sofia and Bulgaria between Belgium and Bulgaria was handed down on February 26, 1940.

The Inter-American Neutrality Committee now in session at Rio de Janeiro owes its creation to the spirit of “ continental solidarity” which has developed among the 21 American Republics during recent years. At the Inter-American Conference for Maintenance of Peace, held at Buenos Aires in 1936, the 21 American Republics adopted a Convention for the Maintenance, Preservation and Reëstablishment of Peace, in which it was provided that in the event that the peace of the American Republics should be menaced, there should be consultation for the purpose of finding and adopting methods of peaceful coöperation; and it was further provided that, in the event of an international war outside America which might menace the peace of the American Republics, such consultation should also take place to determine in what way the American Republics might cooperate in order to preserve the peace of the American continents.

The recent decision of the United States Court of Customs and Patent Appeals in the case of John T. Bill Co. Inc. v. United States, C.A.D. 57, 27 C.C.P.A. (Customs) 26,104 F. (2d) 67 (decided May 29, 1939), is of distinct importance in its bearing on the foreign commercial policy of the United States. In this case, an appellate court, for the first time, had squarely presented to it the question of giving effect to the unconditional mostfavored- nation provisions of an American commercial treaty as against a later statute containing no express reservation respecting treaty provisions. This decision may well be regarded as the turning-point in the construction given to the most-favored-nation clause by the American courts.

The Panama Canal was originally conceived as a highway for peaceful commerce between nations. The extensive use of the Canal by the vessels of many countries indicates that it has fulfilled such a function. At the same time the Canal has played a part in non-peaceful intercourse. It has facilitated the transportation of materials of war and of troops. It has enabled "vessels of war to move rapidly from ocean to ocean, thus affecting naval strategy. From the commencement of its undertaking the United States Government has regarded the Panama Canal as an instrument of national defense. These facts serve to underline the importance of the Canal to all maritime states in war as well as in peace.

Prior to the outbreak of the European war on September 3, 1939, progress had been made, by means of international agreements for the conservation of whales, toward the creation of what M. Suarez in 1925 characterized as a new jurisprudence “ of which today we have no inkling, owing to the fact that the necessity which now arouses our legitimate apprehensions was never contemplated.” In 1931, due to the efforts of the League of Nations, a Convention for the Regulation of Whaling was opened for signature at Geneva; in 1937, an International Agreement for the Regulation of Whaling was signed at London; in 1938, a Protocol Amending the International Agreement was signed at London.