title: Battle of the Imjin River

text: At around 20:30 on 23 April, the Glosters' A Company, now at less than half strength and with all officers killed or wounded, fell back to Hill 235. The withdrawal left D Company's position exposed, and with one of its platoons badly mauled in the overnight fighting, it too withdrew to the hill. B Company had not been pressed during the night, but the withdrawal of D Company on their left and the Fusiliers on their right left them exposed, and they were withdrawn to Hill 316, east of C Company.


title: Battle of the Imjin River

text: During the night of 23/24 April, the Glosters' B Company, outnumbered 18:1, endured six assaults, calling in artillery on their own position to break up the last of them. Low on ammunition and having taken many casualties, the seventh assault at 08:10 forced them to abandon their position, and just 20 survivors made it to Hill 235, to which battalion HQ, the Support Company and C Company had already withdrawn. As B Company fought for its life, the PVA 188th Division crossed the Imjin and attacked the Fusiliers and the Royal Ulster Rifles on the right of the brigade's line. The 187th Division also engaged the brigade's battalions on the right, while the 189th Division kept up the pressure on the left.


title: Battle of the Imjin River

text: Most dangerous for the integrity of the 29th Brigade was the deep penetration of the line between the Glosters and the Fusiliers which had cut off the former. To counter the PVA attack and protect the Glosters from being completely surrounded, the Philippine 10th Battalion Combat Team (BCT) was temporarily attached to the 29th Brigade. A combined force of M24 tanks of the 10th BCT and Centurions of the 8th Hussars supported by infantry reached a point from Hill 235 on 24 April. However, the column failed to make contact as the lead tank was hit by PVA fire and knocked out, blocking the route and making any further advance against heavy resistance impossible. At this point, according to an official American narrative of operations, "the brigade commander considered it unwise to continue the effort to relieve the Gloucester Battalion and withdrew the relief force".


title: Battle of the Imjin River

text: Continued PVA pressure on the UN forces along the Imjin prevented a planned attack by the US 1st and 3rd Battalions, 65th Infantry, to relieve the Glosters. When two further attempts by a tank troop to link up with the Glosters failed, Brigadier Brodie left the decision to Lieutenant-Colonel Carne whether to attempt a break-out or surrender. No further attempts to relieve the Glosters were undertaken because, at 08:00 on 25 April, US I Corps issued the order to execute Plan Golden A, which called for a withdrawal of all forces to a new defensive position further south.


title: Battle of the Imjin River

text: In accordance with orders issued by I Corps, the Fusiliers, Rifles and Belgians, supported by the tanks of the 8th Hussars and the Royal Engineers of 55 Squadron, withdrew to the safety of the next UN position. The Belgians occupied blocking positions west and southwest of the 29th Brigade's command post in order to allow the other units of the brigade to fall back through the battalion's positions. The withdrawal under intense enemy pressure was made even more difficult by the fact that PVA forces dominated parts of the high ground along the line of retreat; they were able not only to observe any movements by the 29th Brigade, but also to inflict heavy casualties on the retreating units. Among those killed was the commanding officer of the Fusiliers, Lieutenant-Colonel Foster, who died when his jeep was hit by PVA mortar fire. In the words of Major Henry Huth of the 8th Hussars, the retreat was "one long bloody ambush". When B Company of the Ulsters, which had acted as rearguard during the retreat, reached the safety of the next UN line, all elements of the 29th Brigade except for the Glosters had completed the withdrawal.


title: Battle of the Imjin River

text: The Glosters' situation on Hill 235 made it impossible for them to join the rest of the 29th Brigade after it had received the order to retreat. Even before the failed attempts to relieve the battalion on 24 April, B and C Companies had already suffered such heavy casualties that they were merged to form one company. Attempts to supply the battalion by air drop were unsuccessful. Despite their difficult situation, the Glosters held their positions on Hill 235 throughout 24 April and the night of 24/25 April. In the morning of 25 April, 45 Field Regiment could no longer provide artillery support. Since Brigadier Brodie had left the final decision to Lieutenant-Colonel Carne, the Glosters' CO "gave the order to his company commanders to make for the British lines as best as they could" on the morning of 25 April. Only the remains of D Company, under the command of Major Mike Harvey, reached the UN lines after several days. The rest of the battalion surrendered and 459 of them were taken prisoner, including Lieutenant-Colonel Carne.


title: Battle of the Imjin River

text: Had the PVA achieved a breakthrough in the initial stages of their assault, they would have been able to outflank the ROK 1st Division to the west and the US 3rd Infantry Division to the east of the 29th Brigade. Such a development would have threatened the stability of the UN line and increased the likelihood of success for a PVA advance on Seoul. Although the PVA benefited from the brigade's scattered deployment and lack of defensive preparations, they were nevertheless unable to take the positions before UN forces could check further advances. In three days of fighting, the determined resistance of the 29th Brigade severely disrupted the PVA offensive, causing it to lose momentum, and allowed UN forces in the area to withdraw to the "No-Name Line", a defensive position north of Seoul, where the PVA/KPA were halted.


title: Battle of the Imjin River

text: The scope and the outcome of the Imjin River engagement have been subjected to several interpretations according to different historiography traditions. According to official Chinese history, the elimination of the 1st Battalion, Gloucestershire Regiment by the Chinese 63rd Army is considered to be an important victory, although the failure of the 64th and the 65th Army to eliminate the entire British 29th Independent Infantry Brigade and capture Seoul due to the defense of ROK 1st Infantry Division was a serious setback. On the other hand, the South Korean contributions to the Imjin River battle are only recorded in sparse detail by the official South Korean history, but historian Allan R. Millet has argued that the ROK 1st Infantry Division's performance in battle demonstrated the potential of South Korean armed forces, in the wake of serious failures during the period of 1950–51. In British Empire countries, the engagement has been interpreted as the 29th Brigade's sacrifice, against impossible odds when facing the Chinese 63rd Army, which ultimately prevented the Chinese from capturing Seoul. Regardless of the interpretations, independent research from historians Zhang Shu Guang and Andrew Salmon concluded that the actions of the 29th Brigade had disrupted the Chinese advance sufficiently to affect the outcome of the First Chinese Spring Offensive.


title: Battle of the Imjin River

text: According to a memorandum presented to the British cabinet on 26 June 1951, 29th Brigade suffered 1,091 casualties, including 34 officers and 808 other ranks missing. These casualties represented 20 to 25 per cent of the brigade's strength on the eve of battle. Of the 1,091 soldiers killed, wounded or missing, 620 were from the Gloucestershire Regiment, which could muster only 217 men on 27 April. 522 soldiers of the Gloucestershire Regiment became prisoners of war. Of those taken prisoner, 180 were wounded and a further 34 died while in captivity. 59 soldiers of the Gloucestershire Regiment were killed in action. Based on estimates, PVA casualties in the Battle of the Imjin River can be put at around 10,000. As a result of the casualties suffered during the battle, the PVA 63rd Army, which had begun the offensive with three divisions and approximately 27,000 men, had lost over a third of its strength and was pulled out of the front line.


title: Battle of the Imjin River

text: The Gloucester Valley Battle Monument was later built at Gloster Hill , beside the Seolmacheon stream.


title: Battle of the Imjin River

text: The British Embassy in Seoul organises a service, officially called the Gloster Valley Memorial Service, for veterans on every anniversary of the battle. In 2008, it took place on 19 April as part of formal commemoration ceremonies that were held during 14–20 April. The outline of the commemorations in 2008 encompassed a service of commemoration, including the laying of wreaths and the presentations of Gloster Valley Scholarships – financial assistance to deserving children in the area where the battle took place – as well as a picnic lunch that offered visitors the opportunity to mingle with veterans. About 70 British veterans and the British ambassador to South Korea took part in the event.


title: Battle of the Imjin River

text: In the Battle of the Imjin River two Victoria Crosses and one George Cross were awarded to soldiers of the Gloucestershire Regiment:


title: Battle of the Imjin River

text: Lieutenant-Colonel Crahay received the U.S. Army's Distinguished Service Cross for his leadership of the Belgian battalion during the battle.


title: Battle of the Imjin River

text: Three units were awarded the US Presidential Unit Citation for their part in the Battle of the Imjin River:


title: Battle of the Imjin River

text: On 8 May 1951, by the command of U.S. President Harry S. Truman, General James Van Fleet presented the President's Distinguished Unit Citation to the Glosters, together with C Troop, 170 Heavy Mortar Battery, which had given invaluable support throughout the battle. The citation says:


title: Battle of the Imjin River

text: The Belgian United Nations Command, which was attached to the British 29th Brigade and replaced the 900 men of the Royal Ulster Rifles on 20 April 1951, initially held the brigade's right flank on the north bank of the river. It also included a Luxembourg platoon. It fought the Chinese there and then conducted a fighting withdrawal, supported by U.S. forces, before taking position in the center of the brigade's line, ahead of brigade headquarters, for the attempts to relieve the Glosters. The Belgian battalion was awarded the United States Distinguished Unit Citation and the Republic of Korea Presidential Unit Citation for their conduct during the battle.


title: Dharala Prabhu

text: Dharala Prabhu () is a 2020 Indian Tamil-language romantic comedy film written and directed by Krishna Marimuthu in his directorial debut. A remake of the 2012 Hindi film "Vicky Donor", the film stars Harish Kalyan, Tanya Hope and Vivek. The film's concept is set against the backdrop of sperm donation and infertility, with Prabhu (Harish Kalyan) approached by Dr. Kannadasan (Vivek), the owner of a fertility clinic, to become a sperm donor for which he eventually agrees.


title: Dharala Prabhu

text: The film was initially reported for a Tamil remake in early 2012, with a project starring Siddharth in the lead role eventually fails to materialise despite its announcements. Eight years later in May 2019, Screen Scene Media Entertainment acquired the remake rights with Harish Kalyan being hired for the film and the project started the following month. The cinematography was handled by Selvakumar S. K. and edited by Kripakaran, the film features a soundtrack album composed by Anirudh Ravichander, Sean Roldan, Vivek-Mervin, Inno Genga, Madley Blues, Bharath Shankar, Kaber Vasuki and Oorka.


title: Dharala Prabhu

text: Dharala Prabhu was released theatrically on 13 March 2020. With theatres being shut down due to the COVID-19 pandemic, affecting its collections, the film was made available in digital platform Amazon Prime Video, less than a month after its release. Nevertheless, the film opened to positive reviews from critics and became a breakthrough film for Harish Kalyan and ended up as a decent hit by its other revenue. The film also marked Vivek's final release before his death.


title: Dharala Prabhu

text: Dr. Kannadasan MBBS is a fertility doctor who runs and manages a fertility clinic in Chennai with the help of his assistant, Kaamu. He promises high-quality sperm for his patients but is frustrated at his lack of success due to his inability to find a healthy sperm donor. Through his contact at the Employment Exchange Department, he reviews the employment applications filed under the sports category, finding a suitable person in the name of Prabhu Govind.


title: Dharala Prabhu

text: Prabhu, a happy-go-lucky young man with an outstanding flair for playing football, aspires to gain his dream job under the sports quota in order to support his mother Vaanathi and his grandmother, both of whom run a beauty spa. One day, while making a delivery at a mall on the behest of his mother, Prabhu meets Nidhi Mandhana, an employee and divorcee, and is instantly smitten by her. He later notices Kannadasan following him and corners him. Kannadasan, in a friendly manner, requests Prabhu to make a sperm donation, to which the latter rejects outright, out of disgust. Undeterred, Kannadasan follows Prabhu everywhere, determined to gain his sperm. Meanwhile, Prabhu regularly visits Nidhi at the mall and the two grow close.


title: Dharala Prabhu

text: Later, after witnessing his football coach lamenting about his inability to have a child with his late wife, Prabhu has a change of heart and approaches Kannadasan. He regularly makes donations to Kannadasan, who in turn pays him for every donation he makes. Prabhu lavishly spends the money and lives happily. He maintains his donations a secret from his family. However, upon discovering that Kannadasan had repeatedly sabotaged his numerous attempts at gaining employment in order to remain in business, Prabhu leaves him and decides to marry Nidhi. Guilty, Kannadasan makes up for Prabhu by securing him his dream job and settling the rift between his family and Nidhi's, resulting in them getting happily married. Prabhu, now reconciled with Kannadasan, makes one final donation to him (albeit at his nudging). Kannadasan uses Prabu's sperm to covertly provide a Kid for a State minister, and gets a huge amount as settlement.


title: Dharala Prabhu

text: Nidhi yearns to have a child with Prabhu but is unable to have one. Three years pass, but the couple is unable to bear a child. Kannadasan later explains that Nidhi is infertile, leaving Prabhu devastated. Despite Kannadasan's request to conceive a child through surrogacy, Prabhu and Nidhi decide to adopt a child. They adopt Kavya, a three-year-old girl, whose parents had died in a car accident. Later, at home, Prabhu discovers that Kavya is actually his biological child, conceived through one of his donations, leaving him horrified. He confronts Kannadasan, who admits the truth. He urges Prabhu to raise Kavya with love and care. Despite this shock, Prabhu softens up to Kavya and raises her as his own child, also maintaining her true origins as a secret from his family. Prabhu's family grows close to Kavya, but are unaware of her true origins.


title: Dharala Prabhu

text: Later, the Income Tax Department arrests Prabhu on the charges of handling black money, and Kannadasan comes to his aid. With no other record, Kannadasan is forced to reveal the truth to the police, and they both escape prosecution using the influence of the Minister. Disgusted with the truth, Nidhi leaves Prabhu. Prabhu reconciles with Kannadasan and begs to Nidhi for forgiveness. Kannadasan later invites Prabhu, Nidhi, and Kavya to a function held at an orphanage. He explains to Nidhi that although Prabhu keeping his actions a secret from her was wrong, he urges her to look at the good intentions behind them and reveals to her the happiness that Prabhu gave to numerous families through his donations. He further reveals that 49 children were conceived through Prabhu's donations. With a change of heart, Nidhi reconciles with Prabhu. Prabhu, Nidhi, Kavya, Kannadasan, and other families (whose children were conceived via Prabhu) celebrate.


title: Dharala Prabhu

text: After the overwhelming success of "Vicky Donor", a Tamil remake of the film was reported to be produced by Siddharth who acquired the remake rights of the film under his banner Etaki Entertainment. Later YNOT Studios also interested in the film's production, collaborating with the actor for the second time after "Kadhalil Sodhappuvadhu Yeppadi", and was reported to be made as a bilingual in Tamil and Telugu. But no developments had been made further despite its initial announcement. The same year, another Telugu film titled "Eenade Edho Ayyindi", starring Brahmanandam's son Raja Gautham in the lead role was reported to be the remake film, but the claims were refuted by its director Madhura Sreedhar. The film which was later made in Telugu as "Naruda Donoruda" was released in November 2016.


title: Dharala Prabhu

text: In May 2019, Screen Scene Media Entertainment which acquired the remake rights of the film announced that Harish Kalyan will play the lead role reprising Ayushmann Khurrana's character in the original version. At the end of the month, it was reported that Krishna Marimuthu who helmed the 2017 Telugu film "Yuddham Sharanam" was brought on board as the director, and the film's tentative title "Dharala Prabhu" was also announced. In June 2019, Tanya Hope and Vivek were brought on to the film's cast essaying pivotal roles. Principal shooting of the film began the same month with filming took place across the suburbs of Chennai. The first look of the film was released in January 2020, with the film's tentative title "Dharala Prabhu" was finalised as the official title.


title: Dharala Prabhu

text: The soundtrack album of "Dharala Prabhu", features eight songs composed by eight different composers, which includes Anirudh Ravichander, Sean Roldan, Vivek-Mervin, Inno Genga, Madley Blues, Bharath Shankar, Kaber Vasuki and Oorka. The background score is composed by Bharath Shankar. Lyrics for the songs were written by Vignesh Shivan, Subu, Nixy, Bharath Shankar and Kaber Vasuki. The audio rights were acquired by Sony Music India. Before the album released, five out of eight songs were been released as singles.


title: Dharala Prabhu

text: The first single "Aaha Ooho" composed by the Oorka band, was released on 5 February 2020. The second single "Unnaal Penne" composed and sung by Inno Genga, with lyrics written by Vignesh Shivan, was released on 17 February 2020. The third single track "Rasa Mavan" sung by stand-up comedian Alexander Babu and Harish Venkat, with the former making his singing debut, was released on 28 February 2020. The fourth single "Kaadhal Theevey", composed by Sean Roldan and sung by Sid Sriram, was released on 1 March 2020. The fifth single "Dharala Prabhu Title Track" sung and composed by Anirudh, was released on 4 March 2020. The title track was re-used from "Nani's Gang Leader" (2019). The remaining songs were released on 6 March 2020. Post release a bonus track "Maatra Thendral" was released on 3 June 2020.


title: Dharala Prabhu

text: The film's official teaser was released on 29 January 2020, and the trailer was released on 21 February. "Dharala Prabhu" was theatrically released on 13 March 2020. The film was made available through the digital platform Amazon Prime Video in April 2020. The film was later re-released in theatres, post Tamil Nadu government granted permission for its reopening with 50% occupancy on 10 November 2020.


title: Dharala Prabhu

text: Thinkal Menon of "The Times of India" gave 3 stars out of 5 and wrote, "A better background score and more effort on the emotional scenes would have made the movie a perfect remake." Pradeep Kumar of "The Hindu" wrote "Harish Kalyan’s film takes aim, but misses its objective of sensitising the Tamil audience to the concept of sperm donation, by quite some distance." S. Subhakeerthana of "The Indian Express" gave 3 out of 5 and stated "Though Dharala Prabhu ends on a sentimental note, it is fairly entertaining." Sreedhar Pillai, for "Firstpost", gave 3 out of 5 stating ""Dharala Prabhu" is an engaging, breezy entertainer which has the perfect blend of comedy and emotions, along with solid performances from its lead actors." Janani K of "India Today" gave 2.5 out of 5 and wrote "Dharala Prabhu is a remake with Tamil sentiments. It’s good that the film does not dilute the concept of sperm donation." Karthik Kumar of "Hindustan Times" wrote "Dharala Prabhu is not one of those remakes that blindly recreate the original scene by scene. It’s evident from the little but crucial changes made to suit Tamil sensibilities that effort has gone into the project to make it appealing."


title: Dharala Prabhu

text: "Sify" gave 3.5 out of 5 and wrote: "The film takes a light-hearted, optimistic look at infertility and artificial insemination that entertains and enlightens the audiences". "Behindwoods" gave the film 3 out of 5 and stated "The film takes up a noble subject at its core and despite being a remake that comes after eight years, the fresh treatment and good performances keep us invested in the movie. On the whole, Dharala Prabhu is a faithful remake that tickles you throughout, while still touching your sensitive nerves." "Indiaglitz" gave the film a rating of 3.25 out of 5 stating "Go for this breezy entertainer that mixes strong humane messages coated with fun." Baradwaj Rangan of "Film Companion" wrote, "Very deceptively, very casually, Dharala Prabhu addresses a number of issues without making them feel like “issues” (i.e. there are no lectures)... even the central issue is treated with lightness."


title: Dharala Prabhu

text: "Dharala Prabhu" had a strong opening weekend collecting ₹35.03 lakhs from 123 shows in Chennai box office. However the film had a receding occupancy due to the fear of coronavirus pandemic, as well as theatres being shut down from 16 March 2020 (three days after the film's release) as a precautionary measure in order to control the pandemic situation. The film collected ₹3.2 crores from its theatrical premiere across India and ₹3.4 crores worldwide. The film was made available for viewing on OTT platforms less than a month after its theatrical release due to the COVID-19 lockdown in India.


title: 1981 French presidential election

text: Presidential elections were held in France on 26 April 1981, with a second round on 10 May. François Mitterrand defeated incumbent president, Valery Giscard d'Estaing to become the first Socialist president of the Fifth Republic.


title: 1981 French presidential election

text: In the first round of voting on 26 April 1981, a political spectrum of ten candidates stood for election, and the leading two candidates – Mitterrand and Giscard d'Estaing – advanced to a second round. Mitterrand and his Socialist Party received 51.76% of the vote, while Giscard and his Union for French Democracy trailed with about 48.24%, a margin of 1,065,956 votes.


title: 1981 French presidential election

text: The Socialist Party's electoral program was called 110 Propositions for France. Mitterrand served as President of France for the full seven-year term (1981–1988) and won re-election in 1988.


title: 1981 French presidential election

text: If Giscard's internal political handicaps had effectively "crippled" him in the initial race, the external factors that decided the 1981 election were a deadly blow. Neatly summarized in an article by Hugh Dauncey: "It was Giscard's double misfortune that his presidency should be blighted both by unprecedented economic difficulties, and by a political system which was stubbornly unreceptive to the ouverture and centralist compromise that he required for his reforms to fully succeed". The electoral and party system (political system) in France had, indeed, undergone many critical changes during the previous years. In particular the introduction of the two-round, majority vote requirement played a large role in the election of 1981. The new electoral system divided the various right and left factions within themselves during the first round, but led to right and left polarization during the second round. That forced the right and the left to strategize for both the first and second parts of the election.


title: 1981 French presidential election

text: In the first round, candidates must present themselves as the better candidate while being careful not to remove all credibility of his/her fellow right or left candidates, as their opponents may have to run again in the next round against the opposing right or left candidate. (It is much the same in US primary elections.)


title: 1981 French presidential election

text: In the second round, however, total unity must be achieved. That leads to the movement of both groups toward the center, with coalitions between center groups and extremists within the right and left.


title: 1981 French presidential election

text: The new electoral "rules of the game," was one of the most notable factors that decided the 1981 election. The division within the right between the two main factions, Giscard's Union pour la démocratie française (UDF) and Chirac's neo-Gaullist Rassemblement pour la République (RPR), proved to be the final blow to Giscard (Painton, par. 12). When Chirac lost the "primary," he refused to advise his supporters to back Giscard in the runoff though he stated that he would vote for Giscard. In effect, Chirac refused to endorse Giscard as the sole candidate of the centre-right.


title: 1981 French presidential election

text: There was also the tactical ingenuity on the part of the Left that brought about Mitterrand's victory. As author Penniman points out, in a shrewd move, the left gained "strength through disunity." The right's disunity between the UDF and RPR factions brought about the downfall of their major candidate. The split between the left's Socialist and Communist Parties, however, allowed the electorate to be more comfortable voting for the Socialists while it gained Communist votes, which were roughly 20% of the electorate.


title: Nullification (U.S. Constitution)

text: Nullification, in United States constitutional history, is a legal theory that a state has the right to nullify, or invalidate, any federal laws which they deem unconstitutional with respect to the United States Constitution (as opposed to the state's own constitution). There are similar theories that any officer, jury, or individual may do the same. The theory of state nullification has never been legally upheld by federal courts, although jury nullification has.


title: Nullification (U.S. Constitution)

text: The theory of nullification is based on a view that the states formed the Union by an agreement (or "compact") among the states, and that as creators of the federal government, the states have the final authority to determine the limits of the power of that government. Under this, the compact theory, the states and not the federal courts are the ultimate interpreters of the extent of the federal government's power. Under this theory, the states therefore may reject, or nullify, federal laws that the states believe are beyond the federal government's constitutional powers. The related idea of interposition is a theory that a state has the right and the duty to "interpose" itself when the federal government enacts laws that the state believes to be unconstitutional. Thomas Jefferson and James Madison set forth the theories of nullification and interposition in the Kentucky and Virginia Resolutions in 1798.


title: Nullification (U.S. Constitution)

text: Courts at the state and federal level, including the U.S. Supreme Court, repeatedly have rejected the theory of nullification. The courts have decided that under the Supremacy Clause of the Constitution, federal law is superior to state law, and that under Article III of the Constitution, the federal judiciary has the final power to interpret the Constitution. Therefore, the power to make final decisions about the constitutionality of federal laws lies with the federal courts, not the states, and the states do not have the power to nullify federal laws.


title: Nullification (U.S. Constitution)

text: Between 1798 and the beginning of the Civil War in 1861, several states threatened or attempted nullification of various federal laws. None of these efforts were legally upheld. The Kentucky and Virginia Resolutions were rejected by the other states. The Supreme Court rejected nullification attempts in a series of decisions in the 19th century, including "Ableman v. Booth", which rejected Wisconsin's attempt to nullify the Fugitive Slave Act. The Civil War ended most nullification efforts.


title: Nullification (U.S. Constitution)

text: In the 1950s, southern states attempted to use nullification and interposition to prevent integration of their schools. These attempts failed when the Supreme Court again rejected nullification in "Cooper v. Aaron", explicitly holding that the states may not nullify federal law.


title: Nullification (U.S. Constitution)

text: The Constitution does not contain any clause expressly providing that the states have the power to declare federal laws unconstitutional.


title: Nullification (U.S. Constitution)

text: Supporters of nullification have argued that the states' power of nullification is inherent in the nature of the federal system. They have argued that before the Constitution was ratified, the states essentially were separate nations. Under this theory, the Constitution is a contract, or "compact", among the states by which the states delegated certain powers to the federal government while reserving all other powers to themselves. The states, as parties to the compact, retained the inherent right to judge compliance with the compact. According to supporters of nullification, if the states determine that the federal government has exceeded its delegated powers, the states may declare federal laws unconstitutional. Nullification supporters argue that the power to declare federal laws unconstitutional not only is inherent in the concept of state sovereignty but also is one of the powers reserved to the states by the Tenth Amendment.


title: Nullification (U.S. Constitution)

text: This view of the Constitution has been rejected by the federal courts, which consistently have held that under the Constitution, the states do not have the power to nullify federal laws. The courts have rejected the compact theory, finding that the Constitution was not a contract among the states. Rather, the Constitution was established directly by the people, as stated in the preamble: "We the people of the United States ..." The people made the federal government superior to the states in certain ways. Under the Supremacy Clause of Article VI, the Constitution and federal laws made in pursuance thereof are "the supreme law of the land ... anything in the constitution or laws of any state to the contrary notwithstanding." The courts have held that federal laws are therefore superior to state laws and cannot be negated by the states. Federal laws are valid and are controlling, so long as those laws were adopted in pursuance of—that is, consistent with—the Constitution. Determining whether a federal law is consistent with the Constitution requires interpretation of the law, which is inherently a judicial function. The federal judicial power granted by Article III of the Constitution gives the federal courts authority over all cases "arising under this Constitution [or] the laws of the United States". The federal courts, therefore, have been given the power to determine whether federal laws are consistent with the Constitution, with the Supreme Court having final authority.


title: Nullification (U.S. Constitution)

text: Thus, the federal courts have held that under the Constitution, federal law is controlling over state law, and the final power to determine whether federal laws are unconstitutional has been delegated to the federal courts. The courts therefore have held that the states do not have the power to nullify federal law.


title: Nullification (U.S. Constitution)

text: The concept of nullification of federal law by the states was not discussed at the Constitutional Convention. The records of the Constitutional Convention therefore do not provide support for the theory of nullification.


title: Nullification (U.S. Constitution)

text: On the other hand, the records of the Convention support the idea that the power to declare federal laws unconstitutional lies in the federal courts. At least fifteen Constitutional Convention delegates from nine states spoke about the power of the federal courts to declare federal laws unconstitutional. For example, George Mason said that under the Constitution, federal judges "could declare an unconstitutional law void". James Madison said: "A law violating a constitution established by the people themselves, would be considered by the Judges as null & void." Elbridge Gerry said that the power of federal judges to interpret federal laws includes "a power of deciding on their constitutionality".


title: Nullification (U.S. Constitution)

text: Several of the Convention delegates said that the federal courts would have the power to determine disputes between the federal government and the states. Charles Pinckney referred to federal judges as "Umpires between the U. States and the individual States". John Rutledge indicated that the Supreme Court would "judge between the U.S. and particular states". These statements indicated that the Supreme Court would have final authority in constitutional disputes between the federal government and the states.


title: Nullification (U.S. Constitution)

text: The records of the state ratifying conventions do not include any assertions that the states would have the power to nullify federal laws. It has been argued that certain statements in the Virginia ratifying convention, although not asserting a right of nullification, articulated a basis for the compact theory. Edmund Randolph and George Nicholas stated that Virginia's ratification of the Constitution would constitute its agreement to a contract, and that if Virginia were to state its understanding at the time of ratification that the federal government could exercise only its delegated powers, this understanding would become part of the contract and would be binding on the federal government. These statements implied a belief that Virginia, as a party to the contract, would have a right to judge the constitutional limits of federal power.


title: Nullification (U.S. Constitution)

text: The records of the state ratifying conventions include over three dozen statements in more than half the states asserting that the federal courts would have the power to declare laws unconstitutional. For example, Luther Martin's letter to the Maryland ratifying convention asserted that the power to declare laws unconstitutional could be exercised solely by the federal courts, and that the states would be bound by federal court decisions: "Whether, therefore, any laws or regulations of the Congress, any acts of its President or other officers, are contrary to, or not warranted by, the Constitution, rests only with the judges, who are appointed by Congress, to determine; by whose determinations every state must be bound." John Marshall said in the Virginia convention that protection against infringement of the Constitution would be provided by the federal courts: "If [Congress] were to make a law not warranted by any of the powers enumerated, it would be considered by the [federal] judges as an infringement of the Constitution which they are to guard. ... They would declare it void. ... To what quarter will you look for protection from an infringement on the Constitution, if you will not give the power to the judiciary? There is no other body that can afford such a protection."


title: Nullification (U.S. Constitution)

text: In short, there were no statements in the Constitutional Convention or the state ratifying conventions asserting that the states would have the power to nullify federal laws. On the other hand, the records of these conventions support the idea that the power to declare federal laws unconstitutional lies in the federal courts.


title: Nullification (U.S. Constitution)

text: "The Federalist Papers" do not say that the states have the power to nullify federal law. On the contrary, they say that the power to declare laws unconstitutional is delegated to federal courts, not the states.


title: Nullification (U.S. Constitution)

text: Federalist No. 33 states that federal laws are supreme over the states, so long as those laws are within the federal government's delegated powers.


title: Nullification (U.S. Constitution)

text: Federalist No. 39 directly addresses the question of who is to decide whether the federal government has exceeded its delegated powers and has infringed on the states' reserved powers. It explains that under the Constitution, this issue is to be decided by the Supreme Court, not the states: "[The federal government's] jurisdiction extends to certain enumerated objects only, and leaves to the several States a residuary and inviolable sovereignty over all other objects. It is true that in controversies relating to the boundary between the two jurisdictions, the tribunal which is ultimately to decide, is to be established under the general [i.e. federal] government. ... Some such tribunal is clearly essential to prevent an appeal to the sword and a dissolution of the compact; and that it ought to be established under the general rather than under the local governments, or, to speak more properly, that it could be safely established under the first alone, is a position not likely to be combated."


title: Nullification (U.S. Constitution)

text: Federalist No. 44 discusses the role of the states in checking actions of Congress that exceed its delegated powers. According to Federalist No. 44, the role of the states is to "sound the alarm" regarding any unconstitutional exercise of power by Congress, and to assist in electing new representatives to Congress. Federalist No. 44 does not imply that the states have the power to legally nullify federal law, although this would have been an appropriate context in which to mention it if such a power were thought to exist.


title: Nullification (U.S. Constitution)

text: Federalist No. 78 says that the federal courts have the power "to pronounce legislative acts void, because contrary to the Constitution".


title: Nullification (U.S. Constitution)

text: Federalist No. 80 asserts that the final authority to interpret the Constitution and federal law lies in the federal courts, not the states, because of the need for uniformity. Likewise, Federalist No. 22 says that the federal courts should interpret federal law due to the need for uniformity.


title: Nullification (U.S. Constitution)

text: Federalist No. 82 says that because of the need for uniformity and the federal government's need to effectively enforce its laws, the Constitution gives the Supreme Court the power to review decisions of state courts in cases arising under the Constitution or federal law.


title: Nullification (U.S. Constitution)

text: "The Federalist Papers" therefore indicate that the power to declare federal laws unconstitutional lies in the federal courts, not in the states.


title: Nullification (U.S. Constitution)

text: The earliest assertion of the theories of nullification and interposition is found in the Kentucky and Virginia Resolutions of 1798, which were a protest against the Alien and Sedition Acts. In these resolutions, authors Thomas Jefferson and James Madison argued that "the states" have the right to interpret the Constitution and can declare federal laws unconstitutional when the federal government exceeds its delegated powers. These resolutions are considered the foundational documents of the theories of nullification and interposition.


title: Nullification (U.S. Constitution)

text: The Kentucky Resolutions of 1798, written by Jefferson, asserted that the states formed the Constitution as a compact, delegating certain specified powers to the federal government and reserving all other powers to themselves. Each state, as a party to the compact, has a "right to judge for itself" the extent of the federal government's powers. When the federal government acts beyond the scope of its delegated powers, a state may determine that the federal government's "acts are unauthoritative, void, and of no force". The Kentucky Resolutions of 1798 called on the other states to join Kentucky "in declaring these acts void and of no force" and "in requesting their repeal at the next session of Congress".


title: Nullification (U.S. Constitution)

text: The Kentucky Resolutions of 1799 added the assertion that when a federal law is unconstitutional, the remedy is "nullification" of the law by "the several states". The Kentucky Resolutions of 1799 did not assert that Kentucky would unilaterally refuse to enforce, or prevent enforcement of, the Alien and Sedition Acts. Rather, these resolutions declared that Kentucky "will bow to the laws of the Union" but would continue "to oppose in a constitutional manner" the Alien and Sedition Acts. The resolutions stated that Kentucky was entering its "solemn protest" against those Acts. The author of the Kentucky Resolutions of 1799 is not known with certainty.


title: Nullification (U.S. Constitution)

text: The Virginia Resolutions of 1798, written by Madison, did not mention nullification. Rather, they introduced the idea of "interposition". The Virginia Resolutions asserted that when the federal government engages in "a deliberate, palpable, and dangerous exercise" of powers not granted by the Constitution, "the states, who are parties thereto, have the right, and are in duty bound, to interpose, for arresting the progress of the evil, and for maintaining, within their respective limits, the authorities, rights and liberties, appertaining to them". The Virginia Resolutions did not explain what form this "interposition" might take. The Virginia Resolutions appealed to the other states for agreement and cooperation in opposing the Alien and Sedition Acts.


title: Nullification (U.S. Constitution)

text: The Kentucky and Virginia Resolutions did not attempt to prohibit enforcement of the Alien and Sedition Acts within the borders of those states. Rather, these resolutions declared that the legislatures of these states viewed the Alien and Sedition Acts as unconstitutional, called for the repeal of these Acts, and requested the support and cooperation of the other states.


title: Nullification (U.S. Constitution)

text: The Kentucky and Virginia Resolutions were not accepted by any of the other states. Rather, ten states rejected the Resolutions, with seven states formally transmitting their rejections to Kentucky and Virginia and three other states passing resolutions expressing disapproval. At least six states responded to the Resolutions by taking the position that the constitutionality of acts of Congress is a question for the federal courts, not the state legislatures. For example, Vermont's resolution stated: "That the General Assembly of the state of Vermont do highly disapprove of the resolutions of the General Assembly of Virginia, as being unconstitutional in their nature, and dangerous in their tendency. It belongs not to state legislatures to decide on the constitutionality of laws made by the general government; this power being exclusively vested in the judiciary courts of the Union."


title: Nullification (U.S. Constitution)

text: Virginia responded to the criticism of the other states by issuing the Report of 1800, written by Madison. The Report of 1800 affirmed and defended the Virginia Resolutions. The Report of 1800 also said that a declaration of unconstitutionality by the states would be only an expression of opinion designed to spur debate, rather than having the authoritative effect of a federal court decision. During the Nullification Crisis of the 1830s, Madison denounced as unconstitutional the concept of nullification of federal law by a state. Madison wrote, "But it follows, from no view of the subject, that a nullification of a law of the U.S. can as is now contended, belong rightfully to a single State, as one of the parties to the Constitution; the State not ceasing to avow its adherence to the Constitution. A plainer contradiction in terms, or a more fatal inlet to anarchy, cannot be imagined."


title: Nullification (U.S. Constitution)

text: The Supreme Court first dealt with nullification in 1809 in the case of "United States v. Peters", 9 U.S. (5 Cranch) 115 (1809). The Court rejected the idea of nullification. The Pennsylvania legislature had passed an act purporting to nullify a federal court's decision. The Pennsylvania statute stated that the federal court had acted unconstitutionally because it did not have jurisdiction, and that the federal court's judgment "was null and void". The Supreme Court held that the Pennsylvania legislature did not have the power to nullify the federal court's judgment, stating: "If the legislatures of the several States may, at will, annul the judgments of the courts of the United States, and destroy the rights acquired under those judgments, the Constitution itself becomes a solemn mockery, and the nation is deprived of the means of enforcing its laws by the instrumentality of its own tribunals."


title: Nullification (U.S. Constitution)

text: In response, the Governor of Pennsylvania called out the state militia to prevent enforcement of the Supreme Court's judgment. However, the U.S. Marshal summoned a posse, carried out the Supreme Court's order, and arrested the leaders of the state militia. The Pennsylvania legislature passed a resolution declaring the action of the Supreme Court unconstitutional, invoking states' rights, and appealing to the other states for support. Eleven states responded by disapproving Pennsylvania's attempted nullification. No state supported Pennsylvania. The Governor of Pennsylvania made a plea to President James Madison to intervene, but Madison affirmed the authority of the Supreme Court. The Pennsylvania legislature backed down and withdrew the militia. Thus, Pennsylvania's attempt to nullify the federal court judgment failed.


title: Nullification (U.S. Constitution)

text: Several New England states objected to the Embargo Act of 1807, which restricted foreign trade. The Massachusetts legislature passed a resolution stating that the embargo "is, in the opinion of the legislature, in many respects, unjust, oppressive and unconstitutional, and not legally binding on the citizens of this state". The Massachusetts resolution did not purport to nullify the Embargo Act, but instead stated that "the judicial courts are competent to decide this question, and to them every citizen, when aggrieved, ought to apply for redress". Massachusetts called on Congress to repeal the act, and proposed several constitutional amendments. Connecticut passed a resolution declaring that the act was unconstitutional and declaring that state officials would not "assist, or concur in giving effect to the aforesaid unconstitutional act". Connecticut joined in the call for constitutional amendments. Neither Massachusetts nor Connecticut attempted to ban enforcement of the act within the state. A federal district court ruled in 1808 that the Embargo Act was constitutional. Congress repealed the Embargo Act in 1809 because it had been ineffective in achieving its goal of bringing economic pressure on England and France. Neither state attempted to block enforcement of the Embargo Act, so nullification did not come to a legal test.


title: Nullification (U.S. Constitution)

text: The War of 1812 was harmful to New England's commercial interests and was unpopular in New England. The New England states objected to putting their state militias under federal control, arguing that the Constitution did not give the federal government authority over state militias in those circumstances. There was some discussion in New England about making a separate peace with Britain or even seceding from the Union. At the Hartford Convention of 1814, delegates from several New England states met to discuss their disagreements with the federal government's policies. The final report and resolutions from the Hartford Convention asserted that "acts of Congress in violation of the Constitution are absolutely void" and asserted the right of a state "to interpose its authority" to protect against unconstitutional government action. The final resolutions did not attempt to ban enforcement of any act of Congress. Rather, the resolutions recommended to state legislatures that they protect their citizens from unconstitutional federal action, called on the federal government to fund the defense of New England, and proposed a series of amendments to the Constitution. No state legislature followed up by attempting to nullify a federal act. The end of the war made the issue moot.


title: Nullification (U.S. Constitution)

text: In 1813, the Supreme Court reversed a decision of the Virginia Court of Appeals, basing its decision on the terms of a federal treaty. The Virginia Court of Appeals refused to accept the Supreme Court's decision, stating that under the Constitution, the Supreme Court did not have authority over state courts. The Virginia court held that as a matter of state sovereignty, its decisions were final and could not be appealed to the U.S. Supreme Court. The Virginia court found unconstitutional the federal statute providing for Supreme Court review of state court judgments. This decision would have allowed each state's courts to decide for themselves whether federal actions were unconstitutional, effectively giving state courts the right to nullify federal law. In "Martin v. Hunter's Lessee", 14 U.S. (1 Wheat.) 304 (1816), the Supreme Court rejected this view. The Supreme Court held that Article III of the Constitution gives the federal courts jurisdiction in all cases arising under the Constitution or federal law, and gives the Supreme Court final authority in such cases. The Supreme Court stated that the people, by providing in the Constitution that the Supreme Court has final authority in such cases, had chosen to limit the sovereignty of the states. The Supreme Court therefore found that the federal courts, not the states, have the final power to interpret the Constitution.


title: Nullification (U.S. Constitution)

text: Virginia again challenged the Supreme Court's authority in "Cohens v. Virginia", 19 U.S. (6 Wheat.) 264 (1821). The question was whether the Supreme Court had authority to hear an appeal in a criminal case decided by a state court based on violation of a state law, where the defense was based on federal law. The Virginia legislature passed resolutions declaring that the Supreme Court had no authority over it due to principles of state sovereignty. The Supreme Court held that under Article III of the Constitution, the federal courts have jurisdiction over all cases involving the Constitution or federal law, including state cases in which a federal defense arises. Because the defendants in the case claimed that their actions were authorized by a federal statute, there was a disputed issue of federal law and the Supreme Court had authority to review the state court's judgment. Thus, the Supreme Court again found that the final power to interpret federal law lies in the federal courts, not the states.


title: Nullification (U.S. Constitution)

text: These two cases established the principle that the federal courts, not the states, have the final power to interpret the Constitution and to determine the Constitutional limits of federal power. These cases rejected the state's attempt to determine the limits of federal power.


title: Nullification (U.S. Constitution)

text: In 1819, Ohio imposed a tax on the federally chartered Bank of the United States. The Supreme Court already had ruled that such taxes were unconstitutional in "McCulloch v. Maryland", 17 U.S. (4 Wheat.) 316 (1819). Despite the Supreme Court's ruling, Ohio seized $100,000 from the Bank to satisfy the tax. Ohio passed resolutions declaring that it did not accept the result of the "McCulloch" case and denying that the Supreme Court had the final authority to interpret the Constitution. The Ohio legislature's resolutions, relying on the Kentucky and Virginia Resolutions, asserted that the states "have an equal right to interpret that Constitution for themselves". The resolutions declared that Ohio had the legal power to tax the Bank.


title: Nullification (U.S. Constitution)

text: The controversy eventually reached the Supreme Court in "Osborn v. Bank of the United States", 22 U.S. (9 Wheat.) 738 (1824). The Supreme Court held that Ohio's tax on the Bank was unconstitutional. The Supreme Court stated: "[T]he act of the State of Ohio ... is repugnant to a law of the United States, made in pursuance of the Constitution, and therefore void." The Supreme Court thus rejected Ohio's attempt to nullify federal law.


title: Nullification (U.S. Constitution)

text: In the 1820s, Georgia passed an act making Georgia state law applicable on all Cherokee lands and declaring all laws of the Cherokee nation void. This contradicted federal treaties with the Cherokees, effectively nullifying those federal treaties. Georgia's actions were reviewed by the U.S. Supreme Court in "Worcester v. Georgia", 31 U.S. (6 Pet.) 515 (1832). While the case was pending in the Supreme Court, the Georgia legislature passed a resolution asserting that under the Tenth Amendment, the federal government had no jurisdiction over Georgia criminal law and the Supreme Court's review of the case was unconstitutional.


title: Nullification (U.S. Constitution)

text: The Supreme Court rejected Georgia's attempt to nullify the federal treaties with the Cherokees. The Court held that "according to the settled principles of our Constitution", authority over Indian affairs is "committed exclusively to the government of the Union". The Court held that under the federal treaties with the Cherokees, "the laws of Georgia can have no force" on Cherokee land. The Court held that Georgia's laws regulating Cherokee land were "void, as being repugnant to the constitution, treaties, and laws of the United States". The Supreme Court thus asserted final authority to interpret the Constitution and federal treaties, rejecting Georgia's nullification attempt.


title: Nullification (U.S. Constitution)

text: Georgia refused to accept the Supreme Court's decision. President Andrew Jackson did not believe Georgia had the right to nullify federal law, but was sympathetic to Georgia's goal of forcing the Cherokees to relocate to the west. He took no immediate action against Georgia. Before the Supreme Court could hear a request for an order enforcing its judgment, the Nullification Crisis arose in South Carolina. Jackson wanted to avoid a confrontation with Georgia over states' rights. A compromise was brokered under which Georgia repealed the law at issue in "Worcester". Despite the Court's decision finding Georgia's actions unconstitutional, Georgia continued to enforce other laws regulating the Cherokees. Ultimately the Cherokees were forced to agree to a treaty of relocation, leading to the Trail of Tears.


title: Nullification (U.S. Constitution)

text: The idea of nullification increasingly became associated with matters pertaining to the sectional conflict and slavery. The best known statement of the theory of nullification during this period, authored by John C. Calhoun, was the South Carolina Exposition and Protest of 1828. Calhoun asserted that the Tariff of 1828, which favored the northern manufacturing states and harmed the southern agricultural states, was unconstitutional. Calhoun argued that each state, as "an essential attribute of sovereignty", has the right to judge the extent of its own powers and the allocation of power between the state and the federal government. Calhoun argued that each state therefore necessarily has a "veto", or a "right of interposition", with respect to acts of the federal government that the state believes encroach on its rights.


title: Nullification (U.S. Constitution)

text: In the Webster–Hayne debate in the Senate in 1830, Daniel Webster responded to this nullification theory by arguing that the Constitution itself provides for the resolution of disputes between the federal government and the states regarding allocation of powers. Webster argued that the Supremacy Clause provides that the Constitution and federal laws enacted pursuant thereto are superior to state law, and that Article III gives to the federal judiciary the power to resolve all issues relating to interpretation of the Constitution. Under the Constitution, the federal courts therefore have the last word, said Webster. Webster said that the Constitution does not give the states a power of constitutional interpretation, and that any such power would result in as many conflicting interpretations of the Constitution as there are states. Therefore, said Webster, under the Constitution, the states do not have the power to nullify federal laws.


title: Nullification (U.S. Constitution)

text: In 1832, South Carolina undertook to nullify the Tariff of 1828 and the Tariff of 1832, as well as a subsequent federal act authorizing the use of force to enforce the tariffs. South Carolina purported to prohibit enforcement of these tariff acts within the state, asserting that these acts "are unauthorized by the constitution of the United States, and violate the true meaning and intent thereof and are null, void, and no law, nor binding upon this State, its officers or citizens". President Andrew Jackson denied that South Carolina had the power to nullify federal statutes, and prepared to enforce federal law forcibly if necessary. In his Proclamation to the People of South Carolina, Jackson said: "I consider, then, the power to annul a law of the United States, assumed by one State, incompatible with the existence of the Union, contradicted expressly by the letter of the Constitution, unauthorized by its spirit, inconsistent with every principle on which It was founded, and destructive of the great object for which it was formed." No other state supported South Carolina. James Madison, author of the Virginia Resolution, also weighed in at this time, stating that the Virginia Resolution should not be interpreted to mean that each state has the right to nullify federal law. The issue was made moot by an enactment of a compromise tariff bill. While the nullification crisis arose over a tariff law, it was recognized that the issues at stake had application to the slavery question as well.


title: Nullification (U.S. Constitution)

text: Northern states in the mid-19th century attempted to block enforcement of the pro-slavery federal Fugitive Slave Acts of 1793 and 1850. Several northern states passed personal liberty laws that had the practical effect of undermining the effectiveness of the federal fugitive slave statutes and preventing slave owners from recovering runaways. For example, a Pennsylvania law enacted in 1826 made it a crime for any person to forcibly remove a black person from the state with the intention of keeping or selling him as a slave.


title: Nullification (U.S. Constitution)

text: The U.S. Supreme Court upheld the validity of the federal Fugitive Slave Act of 1793 in the case of "Prigg v. Pennsylvania", 41 U.S. 539 (1842). The Court rejected Pennsylvania's argument that Congress had no constitutional authority to enact the Fugitive Slave Act, finding that the Act was authorized by the Constitution's fugitive slave clause (Article IV, Section 2). The Court found that Pennsylvania's personal liberty law was unconstitutional because it conflicted with the Constitution's fugitive slave clause. The Court thus rejected Pennsylvania's attempt to nullify the Fugitive Slave Act. However, the Supreme Court implied that states might be able to pass laws denying the assistance of state officials in enforcement of the Fugitive Slave Act, leaving enforcement to federal officials.


title: Nullification (U.S. Constitution)

text: The Supreme Court again dealt with a northern challenge to the federal fugitive slave statutes in the case of "Ableman v. Booth", 62 U.S. 506 (1859). The courts of Wisconsin held the Fugitive Slave Act of 1850 unconstitutional and ordered the release of a prisoner who was prosecuted in federal district court for violation of the Act. The Wisconsin court declared that the Supreme Court had no authority to review its decision. The Wisconsin legislature passed a resolution declaring that the Supreme Court had no jurisdiction over the Wisconsin court's decision. In language borrowed from the Kentucky Resolution of 1798, the Wisconsin resolution asserted that the Supreme Court's review of the case was void.


title: Nullification (U.S. Constitution)

text: The Supreme Court held that Wisconsin did not have the power to nullify federal law or to prevent federal officials from enforcing the Fugitive Slave Act. The Court held that in adopting the Supremacy Clause, the people of the United States had made federal law superior to state law and had provided that in the event of a conflict, federal law would control. Further, the Court found that the people had delegated the judicial power, including final appellate authority, to the federal courts with respect to cases arising under the Constitution and laws of the United States. Therefore, the people gave the federal courts final authority to determine the constitutionality of federal statutes and to determine the boundary between federal power and state power. Accordingly, the Court held that the Wisconsin court did not have the power to nullify a federal statute that had been upheld by the federal courts or to interfere with federal enforcement of that statute.


title: Nullification (U.S. Constitution)

text: "Ableman v. Booth" was the Supreme Court's most thorough examination yet of the theory of nullification. Like the decisions that preceded it, "Ableman" found that federal law was superior to state law, and that under the Constitution, the final power to determine the constitutionality of federal laws lies in the federal courts, not the states. "Ableman" found that the Constitution gave the Supreme Court final authority to determine the extent and limits of federal power and that the states therefore do not have the power to nullify federal law.


title: Nullification (U.S. Constitution)

text: The Civil War put an end to most nullification attempts. Nullification relied on principles of states' rights that were viewed as no longer viable after the Civil War.


title: Nullification (U.S. Constitution)

text: Nullification and interposition resurfaced in the 1950s as southern states attempted to preserve racial segregation in their schools. In "Brown v. Board of Education", 347 U.S. 483 (1954), the Supreme Court decided that segregated schools were unconstitutional. At least ten southern states passed nullification or interposition measures attempting to preserve segregated schools and refusing to follow the "Brown" decision. The advocates of these nullification and interposition measures argued that the "Brown" decision was an unconstitutional infringement on states' rights, and that the states had the power to prevent that decision from being enforced within their borders.


title: Nullification (U.S. Constitution)

text: The Supreme Court explicitly rejected nullification in the case of "Cooper v. Aaron", 358 U.S. 1 (1958). The state of Arkansas had passed several laws in an effort to prevent the integration of its schools. The Supreme Court, in its only opinion to be signed by all nine justices, held that state governments had no power to nullify the "Brown" decision. The Supreme Court held that the "Brown" decision and its implementation "can neither be nullified openly and directly by state legislators or state executive or judicial officers nor nullified indirectly by them through evasive schemes for segregation whether attempted 'ingeniously or ingenuously'." Thus, "Cooper v. Aaron" directly held that states may not nullify federal law.


title: Nullification (U.S. Constitution)

text: The Supreme Court rejected interposition in a similar context. The Supreme Court affirmed the decision of a federal district court that rejected Louisiana's attempt to use interposition to protect its segregated schools. The district court found that interposition by the states is inconsistent with the Constitution, which gives the power to decide constitutional issues to the Supreme Court, not the states. The court held: "The conclusion is clear that interposition is not a constitutional doctrine. If taken seriously, it is illegal defiance of constitutional authority. Otherwise, 'it amounted to no more than a protest, an escape valve through which the legislators blew off steam to relieve their tensions.' ... However solemn or spirited, interposition resolutions have no legal efficacy." "Bush v. Orleans Parish School Board", 188 F. Supp. 916 (E.D. La. 1960), "aff'd" 364 U.S. 500 (1960). The Supreme Court affirmed this decision, thus holding that interposition cannot be used to negate federal law.


title: Nullification (U.S. Constitution)

text: In theory, nullification differs from interposition in several respects. Nullification is usually considered to be an act by a state finding a federal law unconstitutional, and declaring it void and unenforceable in that state. A nullification act often makes it illegal to enforce the federal law in question. Nullification arguably may be undertaken by a single state.


title: Nullification (U.S. Constitution)

text: Interposition also involves a declaration that a federal law is unconstitutional. There are various actions that a state might take to "interpose" once it has determined that a federal law is unconstitutional. In the Virginia Resolutions of 1798, Madison did not describe the form or effect of interposition. But two years later in the Report of 1800, Madison described a variety of actions that states might take to "interpose": communicating with other states about the unconstitutional federal law, attempting to enlist the support of other states, petitioning Congress to repeal the law, introducing Constitutional amendments in Congress, or calling a constitutional convention. Madison did not argue that a state could "interpose" by legally nullifying a federal law and declaring it unenforceable. Madison contemplated that interposition would be a joint action by a number of states, not an action by a single state. Interposition is considered to be less extreme than nullification because it does not involve a state's unilateral decision to prevent enforcement of federal law.


title: Nullification (U.S. Constitution)

text: In practice, nullification and interposition often have been confused, and sometimes have been used indistinguishably. John C. Calhoun indicated that these terms were interchangeable, stating: "This right of interposition, thus solemnly asserted by the State of Virginia, be it called what it may – State-right, veto, nullification, or by any other name – I conceive to be the fundamental principle of our system." During the fight over integration of the schools in the south in the 1950s, a number of southern states passed so-called "Acts of Interposition" that actually would have had the effect of nullification.


title: Nullification (U.S. Constitution)

text: States sometimes have taken various actions short of nullification in an effort to prevent enforcement of federal law. While nullification is an attempt to declare federal law unconstitutional and to forbid its enforcement within the state, some other actions by the states do not attempt to declare federal law invalid, but instead use other means in an effort to prevent or hinder enforcement of federal law.


title: Nullification (U.S. Constitution)

text: Nullification should be distinguished from the situation in which a state brings a lawsuit to challenge the constitutionality of a federal law. A state may challenge the constitutionality of a federal statute by filing a lawsuit in court seeking to declare the federal law unconstitutional. Such a lawsuit is decided by the courts, with the Supreme Court having final jurisdiction. This is the accepted method of challenging the constitutionality of a federal statute. This is not nullification, even if the courts uphold the state's position and declare the federal statute unconstitutional. The theory of nullification is that the states have the unilateral power to determine the constitutionality of federal laws, and that a state's determination of unconstitutionality cannot be reviewed or reversed by the courts. Thus, nullification involves a declaration by a state that a federal statute is unconstitutional and cannot be enforced within the state. Under the theory of nullification, such a declaration by a state is final and binding, and cannot be overruled by the courts. On the other hand, when a state files a lawsuit in court challenging the constitutionality of a federal statute, the decision on constitutionality is made by the courts and ultimately can be decided by the Supreme Court, not by the state legislature or state courts. Because such a lawsuit recognizes the authority of the Supreme Court to make the ultimate decision on constitutionality, it is not a use of nullification.


title: Nullification (U.S. Constitution)

text: As noted above, the Supreme Court indicated in "Prigg v. Pennsylvania", 41 U.S. 539 (1842), that the states cannot be compelled to use state law enforcement resources to enforce federal law. The Supreme Court reaffirmed this principle in cases such as "Printz v. United States", 521 U.S. 898 (1997) and "New York v. United States", 505 U.S. 144 (1992), which held that the federal government may not enact a regulatory program that "commandeers" the state's legislative and administrative mechanisms to enforce federal law. States therefore may refuse to use their legislative or administrative resources to enforce federal law. This should be distinguished from nullification. States that withhold their enforcement assistance, but do not declare the federal law unconstitutional or forbid its enforcement by the federal government, are not declaring federal law invalid and therefore are not engaging in nullification. As "Prigg" held, the federal law still is valid and federal authorities may enforce it within the state. The states in this situation, rather than attempting to legally nullify federal law, are attempting to make enforcement of federal law more difficult by refusing to make available their legislative and administrative resources.


title: Nullification (U.S. Constitution)

text: Some states have legalized acts that are prohibited by federal law. For example, several states have legalized recreational marijuana use under state law. An act's legality under state law does not affect its legality under federal law. An act may be legal under state law and, at the same time, illegal under federal law. The states that have legalized marijuana use have not attempted to declare that federal marijuana laws are invalid or unenforceable. However, the validity of federal marijuana laws remain in question with the absence of a constitutional amendment to justify federal marijuana prohibition. Even so, these states have not explicitly attempted to nullify federal law.


title: Nullification (U.S. Constitution)

text: However, for practical purposes, the federal government lacks the resources to enforce its marijuana laws on a large scale and so the legalization of marijuana under state law significantly reduces the ability of the federal government to enforce the marijuana laws. Both that and the US Attorney General's statement that the federal government will not intervene if following certain guidelines laid down by the attorney general make marijuana "de facto" and "de jure" legal at the state level and "de facto" legal but "de jure" illegal on the federal level.


title: Thol. Thirumavalavan

text: Tholkappiyan Thirumavalavan (born 17 August 1962), better known as Thol. Thirumavalavan is a political leader, scholar and activist from the southern Indian state of Tamil Nadu. He is a Member of Parliament from Chidambaram. Founder and President of Viduthalai Chiruthaigal Katchi. He rose to prominence in the 1990s as a Dalit leader, and formally entered politics in 1999. His political platform centres on ending caste discrimination and consequently the caste system. He has also expressed support for Tamil nationalist movements in Sri Lanka.


title: Thol. Thirumavalavan

text: He did his Bachelor's course in Chemistry at Presidency college Chennai, Master's degree in Criminology and pursued Law at Madras Law College. He completed his Ph.D. at Manonmanium Sundaranar University and was awarded his doctorate in 2018. He worked in the government's Forensic Department as a scientific assistant, from which he later resigned in 1999 to contest polls. He contested the 1999 and 2004 general elections unsuccessfully and won the 2009 general elections from the Chidambaram constituency. He won the 2001 state assembly elections in alliance with Dravida Munnetra Kazhagam (DMK), a post from which he resigned in 2004 quoting ideological differences with DMK. He is an author,and has also acted in Tamil cinema.


title: Thol. Thirumavalavan

text: His confrontation with Pattali Makkal Katchi and its leader Ramadoss has resulted in frequent clashes between Dalits and the Vanniyars. Both parties have accused each other of instigating violence against the other community. Both Thirumavalavan and Ramadoss reconciled their differences and worked together during the period of 2004 to 2009, when they were part of the same electoral alliance.


title: Thol. Thirumavalavan

text: In 2019 Thirumavalavan regained his Chidambaram seat and has been a vocal Opposition MP. In 2021, he led his party to win 4 seats in the Tamil Nadu legislative assembly.


title: Thol. Thirumavalavan

text: In 1988, when working for the government's Forensic Department in the southern city of Madurai, he met Malaichamy, the Tamil Nadu state convenor of the Dalit Panthers Iyyakkam (DPI), an organisation that fought for the rights of Dalits. The next year, following Malaichamy's death, Thirumalavan was elected the leader of the DPI. He designed a new flag for the organisation in 1990, as well as changing its name to Viduthalai Chiruthaigal (Liberation Panthers). As part of his work, he also began visiting Dalit villages in the Madurai region, and began learning about the problems faced by Dalits. The killing of two Dalits in 1992, he says, made him more militant. He was particularly noted for his aggressive speeches which gained him significant recognition. Against the background of increasing Dalit assertiveness, he emerged as one of two major Dalit leaders in Tamil Nadu, with a large base of grassroots support, particularly in the southern districts of Tamil Nadu. During early 1997, he was suspended from his government job on account of his increased political activity. He resigned from his job formally in August 1999 to contest the 1999 Indian general elections.


title: Thol. Thirumavalavan

text: The DPI boycotted elections until 1999 general elections. It is unclear why the party did not contest elections until 1999. The decision of contesting the election in 1999 was considered controversial within the party. Thirumavalavan allied with G. K. Moopanar's Tamil Maanila Congress and represented the Third Front. The party contested in the Parliamentary constituencies of Chidambaram and Perambalur. Thirumavalavan contested in Chidambaram, and managed to poll 225,000 votes in his debut elections. Thirumavalavan alleged in one of his interviews on 22 February 2000 that the opposing DMK administration used National Goonda Act and National Security Act to detain cadres of his party. The phase also culminated the rivalry between Thirumavalavan's party and his competitors in the Chidambaram Constituency, the Pattali Makkal Katchi (PMK). PMK is a party that has a strong presence in the northern districts of Tamil Nadu. The election in the constituency was marked by violence from both the parties. Houses of Dalits were burnt and Dalits in the region were denied employment, while Vanniyar houses were also burnt.


title: Thol. Thirumavalavan

text: In 2001 state elections Viduthalai Chiruthaigal allied with the Dravida Munnetra Kazhagam and contested seven seats. Since the PMK joined the AIADMK alliance, the VCK had to join the DMK led alliance. There were ideological differences in the alliance as it had BJP, which was earlier criticised by Thirumavalavan. Thirumavalavan was elected from Mangalore Constituency to State Legislative Assembly. During the 2004 general elections, he resigned his MLA post on 3 February 2004 quoting humiliation meted out by the alliance partners, especially the DMK. He also quoted that he quit as he contested in the symbol of DMK during the 2001 assembly elections. Thirumavalavan contested once again from Chidambaram in 2004 general elections, this time with Janata Dal (United) and polled 257,000 votes and lost by a low margin.


title: Thol. Thirumavalavan

text: During 2004, after efforts from N. Sethuraman from MMK, Thirumavalavan and Ramadoss, the leader of PMK joined hands through a Tamil protection movement named Tamil Paathukappu Iyakkam.


title: Thol. Thirumavalavan

text: He joined the All India Anna Dravida Munnetra Kazhagam (AIADMK) alliance in the 2006 elections to the Tamil Nadu Legislative Assembly. His party was recognised by the Election Commission of India as a registered political party on 2 March 2006. Viduthalai Chiruthaigal Katchi contested in nine seats in Tamil Nadu and 2 seats in Pondicherry. The party won two of them, namely Durai Ravikumar from Kattumannarkoil, and Selvaperunthagai from Mangalore constituency. The alliance with ADMK broke in 2006, when he started allying with the DMK. His party contested in the local bodies elections in DMK alliance in 2006 and won five chairman to various municipalities. In the 2009 general election, Thirumavalavan allied with DMK and was elected to Parliament from the Chidhambaram Lok Sabha constituency in his third attempt.


title: Thol. Thirumavalavan

text: Thirumalavan's politics are grounded in Ambedkarite and Dravidian philosophies as well as a retheorisation of Tamil nationalism, which seeks to turn it into a force for annihilation of the caste system. Oppression of Dalits, he says, is institutionalised in India, including Tamil Nadu. Although the Dravidian parties which dominate the politics of Tamil Nadu are ideologically committed to the eradication of the caste system, Thirumavalavan argues that they have in practice drifted away from the original ideals of the Dravidian movement. Their policies, he says, have mainly benefitted the middle castes, and had actually led to an increase in the oppression of Dalits, with the middle castes replacing the Brahmins as the oppressor. Dalits cannot and should not expect much help from the Dravidian parties. The solution, according to Thirumavalavan, lies in Tamil nationalism. Caste oppression, he says, can only be ended by building resistance from below, through appealing to Tamil sentiments, as happened in the early days of the Dravidian movement under Periyar E. V. Ramasamy. If a properly Tamil government is formed in Tamil Nadu, he says, caste oppression will immediately disappear.


title: Thol. Thirumavalavan

text: Thirumavalavan's views on the importance of the Tamil identity have also led him to strongly support Tamil secessionist groups in Sri Lanka, including the Liberation Tigers of Tamil Eelam, a militant secessionist group who are formally banned as a terrorist organisation in India. He has criticised India for assisting the Sri Lankan army during the Sri Lankan military operations against the LTTE in 2008 and 2009, and has called upon the government of Tamil Nadu to take steps to safeguard the Tamils of Sri Lanka. On 15 January 2009 he started a hunger fast near Chennai (Maraimalai Adigal Nagar) for the cause of Sri Lankan Tamils. After four days, on 19 January he called off the fast, saying that it had had no effect on the Indian government, and calling for a hartal in its place. He was a part of the 10 member MP team that visited the war-affected areas and transitional centres in Vavuniya on 11 October 2009. The delegation visited various part of Jaffna district and had a meeting at the Jaffna public library.


title: Thol. Thirumavalavan

text: Thirumavalvan has also severely criticised Hindu society for, in his views, being built on the basis of caste and obeying the Manusmriti.


title: Thol. Thirumavalavan

text: Dr. Thirumalavan is also a staunch critic of Hindu nationalism and, in particular, Hindutva. Hindutva, to Thirumavalavan, is the essence of the oppressive Indian state. Hindutva, he argues, has through religion worked to homogenise Tamil society with that of northern India. This, he says, has led to Tamils losing their identity. Ethnic Tamil nationalism, in his view, is essential to combat Hindutva. In more recent years his politics have mainly revolved around opposing the BJP and RSS in their agenda, including the controversial Citizenship Amendment Act. He views Hindutva organizations and ideology as being against the ideas of secularism and social justice. To him the idea of a Hindu Rashtra goes against the Indian constitution and would lead to continuation of caste hierarchies as part of "Sanatana Dharma". He believes Sanatan Dharma rejects equality, freedom and brotherhood. He says that Sanatana forces wanted to divide people on religious lines to implement Manu dharma.


title: Thol. Thirumavalavan

text: In 2009, Tamil Nadu's chief minister M. Karunanidhi passed a resolution in principle for 3% inner reservation for Arunthathiyar community, which Thirumavalavan supported.


title: Thol. Thirumavalavan

text: In 2021, he claimed that it is his policy to expose to people, intentions of the BJP which seeks to gain political advantage by cultivating casteism in Tamil soil, inciting religious sentiment and dividing the society in the name of religion.


title: Thol. Thirumavalavan

text: Thirumavalavan played a guest appearance as a Tamil militant leader in Sri Lanka in his first film "Anbu Thozhi" (2007), directed by L. G. Ravichandran. Thirumavalavan was cast in the leading role of a film titled "Kalaham" to play the character of Balasingham, a law college professor, which was being directed by Kalanjiyam. The film later failed to materialize. He also appeared in a song in Mansoor Ali Khan's "Ennai Paar Yogam Varum" (2007). In 2011, he played the role of the Chief Minister in "Minsaram".


title: Thol. Thirumavalavan

text: In the northern districts of Tamil Nadu with a large Vanniyar population, there are frequent clashes between Dalits and Vanniyars. During the 1999 general elections, there was intense violence in the region with casualties on both sides. Thirumavalavan accused Pattali Makkal Katchi, a Vanniyar caste-based party and its founder Ramadoss of instigating violence among the Vanniyars that result in the attack of Dalits. While Ramadoss alleges that Thirumavalavan encourages his party men to have sham inter-caste love marriage, Thirumavalavan accuses Ramadoss of showing caste superiority and instigating violence against Dalits. Both Thirumavalavan and Ramadoss reconciled and worked together during the period of 2004 to 2009, when they were part of the same electoral alliance. After 2009, when PMK split out of the DMK combine, the mutual confrontation started again.


title: Thol. Thirumavalavan

text: During December 2012, Ramadoss formed an all community safeguard forum comprising 51 intermediate castes. He said he would not have any further alliance with Thirumavalavan and his party. He alleged that the Dalits take undue advantage over other communities using the SC/ST Prevention of Atrocities Act and the Act should be abolished. During April 2013, after the party conference of PMK in Mahabalipuram, there were widespread attacks on the Dalits in Dharmapuri district that resulted in two Dalits being killed. Both PMK and VCK accused each other for the mishap, but Ramadoss was arrested after the orders from the state government for the hate speech and damages to the state property during the violence. Thirumavalavan accused Ramadoss that his loss in the electoral base after the 2009 general elections and 2011 assembly elections has resulted in his going back to instigating caste violence.


title: Thol. Thirumavalavan

text: The BSP was floated in Tamil Nadu in December 2008 with the same ideology as in Uttar Pradesh to unite the Dalits and Brahmins. Some of the prominent members of VCK like Selvaperunthagai, who was a MLA in Mangalore constituency, joined BSP. Thirumavalavan, in his response, claimed that the BSP is no threat to VCK vote bank and that the BSP has dumped the principles of Ambedkar, Kanshi Ram and Periyar. Some of the senior journalists also believed that BSP will not have a firm hold in Tamil Nadu to garner the 19% Dalit vote bank in Tamil Nadu as it did in Uttar Pradesh, as the vote bank is already split by the VCK and Puthia Tamizhagam party.


title: Thol. Thirumavalavan

text: The VCK, in a plan to start a television channel, asked the party men to donate gold on the occasion of the 50th birthday of Thirumavalavan. There were also "Thulabaram" type of functions where equal weight of Thirmavalavan was donated. This was subject to wider criticism, drawing parallels with the exotic celebrations organised by Mayawati, the leader of BSP in Uttar Pradesh. Thirumavalavan clarified that the idea was to collect donations for the party and that his party did not enjoy support from rich people as with the case of other parties. As of 4 October 2012, the party got of gold from seven centres that included Puducherry that had .


title: Thol. Thirumavalavan

text: An altered video of a webinar from September 2020 in which Thol. Thirumavalavan was mentioning certain portions from Manusmriti on the status of women and their role created a controversy where he allegedly said that the Manusmriti treated all women as prostitutes. As soon as the video gained steam, BJP members condemned the his statements and claimed that Thirumavalavan had insulted women by referring to them as prostitutes. Thirumavalavan, however, claimed that he was not demeaning women but emancipating them and that he was merely quoting great leaders. The Chennai city police registered a case against Thirumavalavan for over his comment on Manusmriti on 23 October 2020, based on a complaint by BJP legal cell state secretary. The VCK cadre across Tamil Nadu staged protests, after the call for protests by Thirumavalavan urging the state and union government to ban Manusmriti on 24 October 2020 saying that the Manusmriti degrades Dalits, indigenous people, women and backward castes and spreads hate on them. During the protests, he claimed that a few groups edited out five minutes from the forty minute video and claimed that he was demeaning women and the Hindutva groups are circulating the false message against him.


title: Asahi Broadcasting Corporation

text: On April 1, 2018, its radio and television broadcasting divisions were spun off into two subsidiaries, with taking over the radio broadcasting business, and took over television broadcasting.


title: Mohammad Sidique Khan

text: Mohammad Sidique Khan (Urdu: ; October 20, 1974 – July 7, 2005) was a Pakistani-British terrorist and the oldest of the four Islamist suicide bombers and believed to be the leader responsible for the 7 July 2005 London bombings, in which bombs were detonated on three London Underground trains and one bus in central London, suicide attacks, killing 56 people including the attackers and injuring over 700. Khan bombed the Edgware Road train killing himself and six other people.


title: Mohammad Sidique Khan

text: On 1 September 2005, a videotape emerged featuring Khan. The videotape, shown by Al Jazeera Television, also shows Ayman al-Zawahiri, who is the highest leader of al-Qaeda. The two men do not appear together, and the British government says that al-Qaeda was not connected with the bombing. The Home Office believes the tape was edited after the suicide attacks and dismisses it as evidence of al-Qaeda's involvement. In the film, Khan declares, "I and thousands like me have forsaken everything for what we believe" and refers to his expectation that the media would already have painted a picture of him in accordance with government "spin". He goes on to say, "Your democratically elected governments continually perpetrate atrocities against my people all over the world. Your support makes you directly responsible. We are at war and I am a soldier. Now you too will taste the reality of this situation."


title: Mohammad Sidique Khan

text: Born in St James's University Hospital, Leeds, Khan grew up in Beeston but moved to Lees Holm in Dewsbury, near Leeds in early 2005. His father, Tika Khan, a foundry worker, was born in Pakistan. His mother is Mamida Begum. He received his secondary education at South Leeds High School, formerly the Matthew Murray High School, which was also attended by Hasib Hussain, 7 July bus bomber. After completing his secondary education, he attended Leeds Metropolitan University to complete a degree in business. It was during this time that he met his wife Hasina Patel, and first became interested in extremist Islam. Khan had a daughter.


title: Mohammad Sidique Khan

text: Khan worked at Hillside Primary School in Leeds as a "learning mentor" with the children of immigrant families who had just arrived in Britain. Khan's colleagues commented that he was a quiet individual who did not talk about his religious or political beliefs. However, some of those with whom he came into contact who worked for the education authority assert that he displayed open anti-British white prejudice which were glossed over when concerns were raised.


title: Mohammad Sidique Khan

text: Khan was also involved in the community-run Hamara Healthy Living Centre in Beeston, and worked at its youth outreach project, the Hamara Youth Access Point (HYAP). Staff at the centre have confirmed that two of the London bombers, Shehzad Tanweer and Hasib Hussain, frequented the HYAP. Khan used the outreach project as a recruitment centre, according to a friend of his who spoke to "The Guardian".


title: Mohammad Sidique Khan

text: His mother-in-law, Farida Patel, is also involved in education and works as a council liaison officer at a school in Dewsbury. In 1998, she was the first Asian woman to be invited to a Buckingham Palace garden party, meeting the Queen Elizabeth II and other members of the royal family, in recognition for her work amongst the Muslim community in Dewsbury, and again in 2004. She was said to have been "devastated" by the actions of her son-in-law.


title: Mohammad Sidique Khan

text: Mohammad Sidique Khan reportedly postponed the event from 6 July 2005 because he had to take his pregnant wife to the hospital.


title: Mohammad Sidique Khan

text: On the morning of 7 July 2005, Khan travelled by car with his three accomplices to Luton in Bedfordshire, where the four men caught a train to London King's Cross railway station.


title: Mohammad Sidique Khan

text: From there, Khan entered the London Underground and boarded a Circle Line train heading west, travelling four stops to Edgware Road. The bomb detonated at 8.50 a.m., just as the train was pulling out of Edgware Road station, killing six British victims. Personal documents of Khan's were found on the train.


title: Mohammad Sidique Khan

text: Khan is alleged to have travelled regularly to Dubai to attend military training camps, and is also believed to have spent time in Israel. In 2001, Khan was alleged to have learned bomb-making at the Malakand training camp.


title: Mohammad Sidique Khan

text: He is also alleged to have trained with Indonesian terror group Jemaah Islamiyah and to be directly involved with the 2002 Bali bombing.


title: Mohammad Sidique Khan

text: According to the Israeli newspaper "Maariv", Khan travelled to Israel on 19 February 2003, staying only one night and leaving the next day. "Maariv" reports that he was suspected of having helped to plan the 30 April 2003 suicide bombing of the Mike's Place bar in Tel Aviv which killed three Israelis, carried out by two British citizens of Pakistani descent. The Israeli government allegedly played down the report.


title: Mohammad Sidique Khan

text: According to Ron Suskind's "The One Percent Doctrine", the NSA had been monitoring phone calls and emails between Khan and several Islamic radicals from the United States and England, including Ahmed Omar Abu Ali. Just prior to Khan's planned trip to the US, NSA intercepted email exchanges between him and some of his associates discussing a desire to "blow up synagogues on the East Coast". According to Suskind, the CIA wanted to let Khan into the US so that the FBI could put him under surveillance, but the FBI resisted on grounds that, as one FBI case agent stated, "We just can't take the risk ... he goes up and blows up a temple in Washington." US government officials put Khan on a no-fly list to prevent him from entering the country. Suskind was critical of the decision, which the author suggested tipped him off to the fact that he was known to US authorities and might have caused him to be more cautious with his communication to avoid further surveillance.


title: Mohammad Sidique Khan

text: British intelligence sources and circumstantial evidence suggested that this theory may have resulted from a confusion between two different Mohammed Khans, although it seems that Suskind stood by his claim.


title: Mohammad Sidique Khan

text: According to David Leppard in "The Sunday Times", Khan was assessed by MI5 in 2004, after his name appeared during an investigation into a plan to detonate a 600-lb truck bomb in London. MI5 concluded that Khan's link to the plotters was indirect, and he was not placed under surveillance. MI5 was later criticised for failing to follow up leads relating to Khan. The service responded to the criticisms. Channel 4 News published what it said were excerpts from the transcript of the tape.


title: Mohammad Sidique Khan

text: US intelligence officials have said that Khan was known to Mohammed Junaid Babar, who has pleaded guilty in the US to providing material support to al-Qaeda. Babar, who told investigators that he worked on a plan to blow up pubs, railway stations, and restaurants in the UK, identified Khan as someone he had met in Pakistan.


title: Mohammad Sidique Khan

text: On 18 July 2005, the Pakistani government released video footage of Khan arriving at Dubai airport on 19 November 2004 with Shehzad Tanweer, another of the London bombers. Khan and Tanweer stayed in Pakistan until 8 February 2005, then flew back to London together. A third member of the London group, 18-year-old Hasib Hussain, arrived in Karachi on 15 July 2004 from Riyadh, Saudi Arabia, on flight SV714.


title: Savage Amusement

text: Savage Amusement is the tenth studio album by the German hard rock band Scorpions, released in 1988. It peaked at No. 5 in the US and was certified platinum by the RIAA on June 20, 1988. It was the last Scorpions record to be produced by Dieter Dierks.


title: Savage Amusement

text: The cover shows a woman wearing a black dress on a dark blue background. With her right hand she hides her eyes; thus, only her mouth and nose are visible. The cover of "Savage Amusement" is notable, however, for the fact that instead of the lady's right leg, a scorpion tail is seen. The typical band logo is shown on the upper left, while the title of the album is found in the lower right corner, in red, and underlined (also in red).


title: Arturo Pérez-Reverte

text: Arturo Pérez-Reverte Gutiérrez (born 25 November 1951 in Cartagena) is a Spanish novelist and journalist. He worked as a war correspondent for RTVE for 21 years (1973–1994). His first novel, "El húsar", set in the Napoleonic Wars, was released in 1986.


title: Arturo Pérez-Reverte

text: He is well known outside Spain for his "Alatriste" series of novels, which have been translated into multiple languages. Since 2003 he has been a member of the Royal Spanish Academy.


title: Arturo Pérez-Reverte

text: Pérez-Reverte's novels are usually centered on one strongly defined character, and his plots move along swiftly, often featuring a narrator who is part of the story but apart from it. Most of his novels take place in Spain or around the Mediterranean. They often draw on numerous references to Spanish history, colonial past, art and culture, ancient treasures and the sea. The novels frequently deal with some of the major issues of modern Spain, such as drug trafficking or the relationship of religion and politics.


title: Arturo Pérez-Reverte

text: Often, Pérez-Reverte's novels have two plots running in parallel with little connection between them except for shared characters. For example, in "The Club Dumas", the protagonist is searching the world for a lost book and keeps meeting people who parallel figures from Dumas's novels; in "The Flanders Panel", a contemporary serial killer is juxtaposed with the mystery of a 500-year-old assassination.


title: Arturo Pérez-Reverte

text: In his often polemical newspaper columns and the main characters of his novels, Pérez-Reverte frequently expresses pessimism about human behaviour, shaped by his wartime experiences in such places as El Salvador, Croatia or Bosnia. His views have also been shaped by his research for crime shows.


title: Arturo Pérez-Reverte

text: Throughout his career, and especially in its latter half, he has been noted for cultivating his trademark maverick, non-partisan and at times abrasive persona. This has occasionally been a source of conflict with other journalists and writers. He originally refused to have his novels translated from the original Spanish to any language other than French. However, English translations were eventually published for some of his works, and most of his work is also available in Portuguese and Polish.


title: Arturo Pérez-Reverte

text: Pérez-Reverte was elected to seat "T" of the Real Academia Española on 23 January 2003; he took up his seat on 12 June the same year.