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MICRONATIONS AND THE SEARCH
FOR SOVEREIGNTY
Political disagreement is a fact of life. It can prompt people to stand for

public office and agitate for political change. Others take a different route;
they start their own nation. Micronations and the Search for Sovereignty is
the first comprehensive examination of the phenomenon of people
purporting to secede and create their own country. It analyses why
micronations are not states for the purposes of international law,
considers the factors that motivate individuals to separate and found
their own nation, examines the legal justifications that they offer and
explores the responses of recognised sovereign states. In doing so, this
book develops a rich body of material through which to reflect on
conventional understandings of statehood, sovereignty and legitimate
authority. Authored in a lively and accessible style, Micronations and
the Search for Sovereignty will be valuable reading for scholars and
general audiences.
harry hobbs is a Senior Lecturer in the Faculty of Law at the University

of Technology Sydney. Dr Hobbs’ recent scholarship has explored ideas of
sovereignty through the lens of Indigenous peoples’ rights, and he is co-
Chair of the American Society of International Law Rights of Indigenous
Peoples Interest Group.
george williams ao is a Deputy Vice-Chancellor, the Anthony Mason
Professor and a Scientia Professor at UNSW Sydney. He has served as
Dean of UNSW Law and held an Australian Research Council Laureate
Fellowship. He has written widely on constitutional law and has appeared
as a barrister in the High Court of Australia on freedom of speech,
freedom from racial discrimination and the rule of law.
Published online by Cambridge University Press

c a m b r i d g e s t u d i e s i n c o n s t i tut i o n a l l a w
The aim of this series is to produce leading monographs in constitutional

law. All areas of constitutional law and public law fall within the ambit of
the series, including human rights and civil liberties law, administrative
law, as well as constitutional theory and the history of constitutional law.
A wide variety of scholarly approaches is encouraged, with the governing
criterion being simply that the work is of interest to an international
audience. Thus, works concerned with only one jurisdiction will be
included in the series as appropriate, while, at the same time, the series
will include works which are explicitly comparative or theoretical – or
both. The series editors likewise welcome proposals that work at the
intersection of constitutional and international law, or that seek to bridge
the gaps between civil law systems, the US, and the common law jurisdic-
tions of the Commonwealth.
Series Editors
David Dyzenhaus
Professor of Law and Philosophy, University of Toronto, Canada
Thomas Poole
Professor of Law, London School of Economics and Political Science
Editorial Advisory Board

T.R.S. Allan, Cambridge, UK
Damian Chalmers, LSE, UK
Sujit Choudhry, Berkeley, USA
Monica Claes, Maastricht, Netherlands
David Cole, Georgetown, USA
K.D. Ewing, King’s College London, UK
David Feldman, Cambridge, UK
Cora Hoexter, Witwatersrand, South Africa
Christoph Moellers, Humboldt, Germany
Adrienne Stone, Melbourne, Australia
Adam Tomkins, Glasgow, UK
Adrian Vermeule, Harvard, USA
Books in the Series

Fundamental Rights and the Legal Obligations of Business David Bilchitz
Courting Constitutionalism: The Politics of Public Law and Judicial Review
in Pakistan Moeen Cheema
Ruling by Cheating: Governance in Illiberal Democracy András Sajó
Local Meanings of Proportionality Afroditi Marketou
Property Rights and Social Justice: Progressive Property in Action
Rachael Walsh

Carl Schmitt’s Early Legal-Theoretical Writings: Statute and Judgment and
the Value of the State and the Significance of the Individual Lars Vinx and
Samuel Garrett Zeitlin
Remedies for Human Rights Violations: A Two-Track Approach to Supra-
national and National Law Kent Roach
Europe’s Second Constitution: Crisis, Courts and Community Markus
W. Gehring
A.V. Dicey and the Common Law Constitutional Tradition: A Legal Turn
of Mind Mark D. Walters
Administrative Competence: Reimagining Administrative Law
Elizabeth Fisher and Sidney A. Shapiro
Legal Sabotage: Ernst Fraenkel in Hitler’s Germany Douglas Morris
Proportionality in Action: Comparative and Empirical Perspectives on the
Judicial Practice Edited by Mordechai Kremnitzer, Tayla Steiner and
Andrej Lang
Constitutional Dialogue: Democracy, Rights, Institutions Edited by
Geoffrey Sigalet, Grégoire Webber and Rosalind Dixon
The Veiled Sceptre: Reserve Powers of Heads of State in Westminster
Systems Anne Twomey
Vigilance and Restraint in the Common Law of Judicial Review
Dean Knight
The Alchemists: Questioning Our Faith in Courts as Democracy-Builders
Tom Gerald Daly
Australia’s Constitution after Whitlam Brendan Lim
Building the Constitution: The Practice of Constitutional Interpretation in
Post-Apartheid South Africa James Fowkes
Dimensions of Dignity: The Theory and Practice of Modern Constitutional
Law Jacob Weinrib
Reason of State: Law, Prerogative, Empire Thomas Poole
Bills of Rights in the Common Law Robert Leckey
The Guardian of the Constitution: Hans Kelsen and Carl Schmitt on the
Limits of Constitutional Law Translated by Lars Vinx, with an introduc-
tion and notes by Lars Vinx
Parliamentary Bills of Rights: The Experiences of New Zealand and the
United Kingdom Janet L. Hiebert and James B. Kelly
Lawyering for the Rule of Law: Government Lawyers and the Rise of
Judicial Power in Israel Yoav Dotan
Balancing Constitutional Rights: The Origins and Meanings of Postwar
Legal Discourse Jacco Bomhoff
Judges on Trial: The Independence and Accountability of the English
Judiciary Shimon Shetreet and Sophie Turenne

Proportionality and Constitutional Culture Moshe Cohen-Eliya and
Iddo Porat
The Politics of Principle: The First South African Constitutional Court,
1995–2005 Theunis Roux
The New Commonwealth Model of Constitutionalism: Theory and Practice
Stephen Gardbaum
Searching for the State in British Legal Thought: Competing Conceptions of
the Public Sphere Janet McLean
Judging Social Rights Jeff King
Proportionality: Constitutional Rights and Their Limitations
Aharon Barak
Parliamentary Sovereignty: Contemporary Debates Jeffrey Goldsworthy

MICRONATIONS AND
THE SEARCH FOR
SOVEREIGNTY
HARRY HOBBS
University of Technology Sydney
GEORGE WILLIAMS
University of New South Wales

University Printing House, Cambridge CB2 8BS, United Kingdom
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477 Williamstown Road, Port Melbourne, VIC 3207, Australia
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Cambridge University Press is part of the University of Cambridge.

It furthers the University’s mission by disseminating knowledge in the pursuit of
education, learning, and research at the highest international levels of excellence.
www.cambridge.org
Information on this title: www.cambridge.org/9781009150125
DOI: 10.1017/9781009150132
© Harry Hobbs and George Williams 2022
This publication is in copyright. Subject to statutory exception
and to the provisions of relevant collective licensing agreements,
no reproduction of any part may take place without the written
permission of Cambridge University Press.
First published 2022
A catalogue record for this publication is available from the British Library.
ISBN 978-1-009-15012-5 Hardback
Cambridge University Press has no responsibility for the persistence or accuracy of
URLs for external or third-party internet websites referred to in this publication
and does not guarantee that any content on such websites is, or will remain,
accurate or appropriate.

CONTENTS
Preface page ix
1 Prince Leonard Prepares for War 1

2 Statehood and Micronations 20
3 Motivations 82
4 Performing Sovereignty 126
5 State Responses 162
6 The Future of Micronationalism 201
Appendix: List of Micronations Discussed 220
Index 236
vii

PREFACE
People across the world have sought to secede and establish their own
independent micronation. Their motivations for doing so can reflect
their personal commitments and eccentricities and are as diverse as the
nations they seek to create. Secession might be seen as the only possible
course of action to resolve a long-running dispute with the local council
or as a final act of defiance after decades of frustration with regulation
and government bureaucracy. Establishing a new country might also be
designed to promote tourism to a region, to create an art project, to
parody the workings of the state or even to defraud unsuspecting people.
Micronations have been founded around the globe for these and other
reasons. Once established, they seek to assert their claims to sovereignty
in a myriad of ways. They issue coins, print stamps, compose national
anthems, invest themselves with royal titles and sometimes even declare
war on recognised states. Roy Bates – or to use his full title, Prince Roy of
Sealand – who graces our cover from his Principality in the North Sea, is
just one of the many micronationalists who has taken such steps.
Micronations are a subject of fascination for many people, and regu-
larly attract worldwide attention. There is something inherently interest-
ing about the idea that any one of us could break away to form our own
nation, complete with royal titles and the trappings of a real state. Despite
this, the phenomenon has been almost completely ignored by legal
scholars and political scientists. This reflects a view that micronations
are more suited to humour than serious study. After all, the prospect that
an individual or small band of people could separate from a recognised
state and establish their own legally recognised nation is fanciful.
We have written this book because there is more to this story. By
dressing in the language of sovereignty, micronations challenge under-
standings of and approaches to international legal personality. They also
catalyse larger questions about the nature of statehood, sovereignty and
legitimate authority. The creativity and persistent attempts of microna-
tions to find cracks in the law to justify their existence also raise
ix
https://doi.org/10.1017/9781009150132.001 Published online by Cambridge University Press

x preface
important legal and political questions. Can the proponents of sea stead-
ing create a viable state by constructing floating structures on the high
seas outside of national jurisdiction? How do states respond to these
potential challengers? Does state acquiescence to the continued existence
of a micronation have any legal effect? Could a micronation ever become
a state? If not, what value do micronationalists see in statehood? These
are some of the questions that micronations pose. They are the sorts of
issue that motivated us to write this book to provide the first comprehen-
sive treatment of micronations from a legal and political vantage point.
Many people have helped to shape this book. We thank colleagues at
the Faculty of Law at the University of Technology Sydney and the
Faculty of Law and Justice at the University of New South Wales, who
offered helpful comments on draft papers. In particular, we thank
Katherine Biber, Sara Dehm, Rosalind Dixon, Kun Fan, Fleur Johns,
Zsofia Korosy, David Leary, Lucas Lixinski, Jane McAdam, Nicola
McGarrity, Brian Opeskin, Prue Vines, Genevieve Wilkinson and
Stephen Young. We also thank Tom Randall from Cambridge
University Press for his enthusiasm for this project and Priyanka Durai
for her excellent work on the manuscript.
Harry also thanks Annabel Johnson for her patience as he excitedly
recounted the exploits of micronationalists on long walks together, as
well as his parents, Karina and Neil, and sister, Georgia, who encouraged
his love of world maps and flags. George thanks Emma Armson, and
their children Edward and Eleanor, whose attempts at independence and
rule of their household augurs well for their future as micronationalists.
Finally, this book could not have been written without the drive and
energy of those many people – some of whom we discuss – who made the
decision to throw off the shackles of the old and create their own country.

1
Prince Leonard Prepares for War
On a rainy and gloomy 2 September 1967, Roy Bates, a World War II

veteran and former major in the British Army, declared himself the ruler
of the new Principality of Sealand. Like many political entities seeking
statehood, several challenges immediately confronted the apparent
nation. The difficulties facing Sealand appeared particularly grave. To
begin with, the entirety of the Principality’s territorial claim consisted of
a 4,100-tonne decommissioned artificial naval installation located off the
coast of Essex in the River Thames estuary. Initially built in 1942 to guard
the United Kingdom (UK) port of Harwich from invasion, the until
recently abandoned naval fort possessed no arable land. In fact, it pos-
sessed very little habitable land at all. The purportedly independent state
resembled an abandoned oil rig in being comprised of a 51-by-27-metre
pontoon supported by two 18-metre hollow reinforced concrete towers
of around 7.3 metres in diameter.
To make matters worse, the UK government was listening.1
Thankfully for Bates, the United Kingdom was unsure how to respond.
Bates, his family, and a small band of supporters had occupied the fort
since late 1966, initially intending to operate a pirate radio station from
the platform, and the government had spent much of the time since
considering what it should do. While some officials demanded the fort’s
immediate destruction, the Navy were reluctant to intervene, wary of the
formidable, improvised arsenal Bates had apparently stocked. Other
officials were not entirely sure what to make of the situation. The
1
Unless otherwise cited, material in this section is drawn from Adrian Johns, Death of
a Pirate: British Radio and the Making of the Information Age (W.W. Norton & Co, 2011)
249–53; James Grimmelmann, ‘Sealand, Havenco, and the Rule of Law’ (2012) 2 University
of Illinois Law Review 405, 412–24; Dylan Taylor-Lehman, Sealand: The True Story of the
World’s Most Stubborn Micronation (Icon Books, 2020). The Principality of Sealand is
explored in more detail in Chapter 3.

2 1 p r i n c e l e o n a r d pr ep a r e s f o r wa r
Ministry of Defence, for instance, considered his actions bizarre rather

than threatening, remarking that his behaviour was ‘ludicrous. Mr. Bates
is trespassing and it now looks as if he is being very foolish.’2
Complicating matters further were difficult questions of jurisdiction.
As the fort was located outside the United Kingdom’s three-mile terri-
torial waters and the government had abandoned the site some years
previously, it was not clear whether Bates’ occupation violated any law.3
Certainly, it was beyond doubt that Bates himself was causing trouble;
reports suggest that he was repelling attempted intruders with home-
made petrol bombs and air rifles.4 In light of this development, the
Cabinet ultimately determined to ‘dislodge’ Bates and his supporters,
apparently ‘to prevent it falling into the hands of foreign interests’.5
‘Operation Callow’ was relatively straightforward. Officials would
remind Bates that the installation belonged to the Ministry of Defence
and demand that he leave. If necessary, they would offer him an ex-gratia
payment of £5,000 and assist in the removal of his property. Once the
Bates family had been safely escorted off the site, the fort would be
demolished to prevent them or anyone else from attempting reoccupa-
tion. However, Bates refused to cooperate. Baulking at the government’s
offer, he instead demanded £90,000. When this was not forthcoming, he
refused to entertain any suggestions that he relinquish possession. In the
meantime, journalists discovered that a detachment of Royal Marine
commandos were preparing to seize the fort. Anxious to avoid negative
publicity, the government felt that it had no option but to stand down.6
Other strategies were actively considered. David Belasco, a disaffected
Bates supporter, approached the government proposing to betray his
former leader and allow the military safe entry. While the Ministry of
Defence considered the plan ‘implausible’, it did let Belasco know that it
was ‘prepared to take the Fort over’ if he was able to obtain possession
without force.7 Ultimately this too did not eventuate. The Ministry
backed out when it became clear that Belasco wanted the Navy to blow
2
‘Independent Isle “Ludicrous”’, The Times (London, 4 September 1967) 3.
3
Grant Hibberd, ‘The Last Great Adventure of the Twentieth Century: The Sealand Affair
in British Diplomacy’ (2011) 4(2) Britain and the World 269, 271.
4
‘Struggle for Sea Fort’, The Times (London, 28 June 1967) 1; ‘Sea Fort Repels Boarders:
Raiders Faced Flamethrower’, The Times (London, 30 June 1967) 2.
5
Grimmelmann (n 1) 420; ‘Commandos Set to Seize Fort’, The Times (London,
8 August 1967) 1.
6
‘Commandos Set to Seize Fort’ (n 5); ‘Ministry Says Talks Over Fort Broke Down’, The
Times (9 August 1967) 2.
7
Grimmelmann (n 1) 422; Taylor-Lehman (n 1) 57–8.

1 p rince l eonard prepares for w ar 3
the fort up to provide a stunning finale to a book he was writing. In any

event, the abortive plan quickly got out of hand when Belasco swore an
affidavit claiming that the Ministry had asked him to capture the tower by
force. This accusation was taken up by Bates and became the subject of
a story in the Daily Telegraph and, much to the government’s embarrass-
ment, was raised in Parliament.8
Still other approaches were considered. In order to maintain provi-
sions, Bates regularly sailed between the fort and his home on the UK
mainland. To delay and frustrate Bates, Customs sometimes refused to
clear his boat for departure, arguing that it lacked a load line certificate.
Resourcefully, Bates again approached the papers, alleging that the gov-
ernment had ‘marooned’ his children who were living on the fort by
dredging up ‘some obscure bit of marine law’.9 Although Customs
maintained that Bates had merely to ‘hire another boat if his own does
not conform to the regulations’,10 they eventually relented. Another plan
to prosecute Bates for failing to ensure that his 14-year-old son Michael
attended school was similarly dismissed.11 So too was the suggestion that
the UK government pass legislation to expand Britain’s territorial waters
to encompass the fort. As one official noted, such a ‘huge undertaking for
a relatively small purpose would be “a ponderous move, inviting
ridicule”’.12
The United Kingdom had not yet given up. After several months, legal
advice was finally delivered concluding that although a civil action for
possession of the fort ‘would be likely to fail for lack of jurisdiction’,13
criminal jurisdiction over offences committed by British citizens might
well extend to the site. In November 1967, Michael Bates fired several
shots from the fort towards HMS Egeria, a Royal Navy survey mine-
sweeper. However, no damage was recorded, and the evidence was
uncertain, so the incident was ignored. The Director of Public
Prosecutions did not have to wait long for a clearer case. In May 1968,
Michael Bates fired a pistol in the direction of lighthouse staff working on
8
Kenneth Clarke and James Allan, ‘Ministry Planned to Seize Sea Fort’, The Daily
Telegraph (30 May 1968); United Kingdom, Parliamentary Debates, House of
Commons, 18 December 1968, vol 775 col 377W.
9
‘Radio Man’s Children “Marooned”, The Times (London, 7 March 1968) 3.
10
‘Children “Not Marooned”, The Times (London, 8 March 1968) 3.
11
Taylor-Lehman (n 1) 39.
12
Ibid 40.
13
Elwyn Jones and Dingle Foot, ‘Continental Shelf Roughs Tower Fort’ (21 August 1967).
See further Letter from Basil Hall to Sir William Dale (8 August 1967). Sources cited in
Grimmelmann (n 1) 421.

4 1 p r i n c e l eo na r d p r ep a r es f o r wa r
a buoy near the tower. When Roy and Michael were next ashore, they
were both indicted for violations of the 1937 Firearms Act. And yet, at the
moment of its triumph the government vacillated; ‘It was decided not to
take advantage of Mr. Bates’ attendance in Court to try and occupy the
Fort, as this smacked of sharp practice.’14
Unfortunately for the government, the case was ultimately dismissed
for want of jurisdiction. Justice Chapman of the Essex Assizes held that
although Parliament possessed ‘the power to make it an offense for
a British subject to have a firearm with intent to endanger life in
Istanbul or Buenos Aires, or where have you’, it had not done so in this
case as the Firearms Act was held to ‘operate only within the ordinary
territorial limits’.15 While the court did not hold that Sealand was inde-
pendent – and in fact concluded that Parliament could extend its juris-
diction to encompass the offshore platform – Bates nonetheless saw the
decision as providing de facto recognition of his Principality.16
Some journalists and lower level officials were also uncertain of this
distinction. In a feature on ‘the beautiful Princess Joan of Sealand’17
published in the aftermath of the decision, the Sunday Mirror reported:
‘Last week a British judge ruled that the tower was outside British legal
jurisdiction, which means that Mr and Mrs Bates have sovereignty over
their island fort.’18 Customs officials in Essex also apparently began
‘treating Sealand . . . as a foreign country’ informing journalists that
they were ‘awaiting directives about the necessity of passports’.19
Amidst the confusion, the Foreign Office remained firm: ‘Of course we
don’t recognise it as a foreign state. It’s a fort in the North Sea, that’s all.
It’s not a state . . . it’s a building.’20
Following Justice Chapman’s ruling, the issue was returned to Cabinet,
which eventually reached a practical resolution. Bates’ continued occu-
pation may have been undesirable, but as he was ‘doing no actual
14
Grimmelmann (n 1) 423.
15
R v Bates, The Shire Hall, Chelmsford (25 October 1968) 8 (Chapman J); ‘Sea Tower
Outside Court Limit’, The Times (London, 22 October 1968) 3. The United Kingdom
extended its territorial jurisdiction to 12 miles, encompassing Rough Towers, in 1987:
Territorial Sea Act 1987 c 49, s 1(a) (UK).
16
Sealand, About the Principality of Sealand (2019) www.sealandgov.org/about/.
17
As befitting a Principality, Sealand enjoys its own system of royal titles. Princess Joan was
the wife of Roy Bates (otherwise known as Prince Roy).
18
Gordon McGill, ‘The Princess on Sentry Go’, The Sunday Mirror (London,
27 October 1968) 11.
19
Ibid.
20
Ibid.

1 p rince l eonard prepares for w ar 5
harm . . . and the Ministry of Defence had not need of the Fort them-
selves’, ‘there were no pressing reasons for evicting Mr Bates, certainly
none that would justify the use of force or the passage of special
legislation’.21 It was also agreed that in any case, ‘there was some
advantage in refraining from prosecutions which would enhance Mr
Bates’s local reputation as a colourful adventurer prosecuted by
authority’.22
The decision set in place the United Kingdom’s approach to the
Principality over the following decades. The United Kingdom generally
ignores Sealand on the basis it is a non-state actor with no legitimate
claim to jurisdictional authority – provided that it does not cause too
much trouble. This approach has much wisdom to commend it, but it has
allowed Sealand space to attempt to develop into a fully fledged entity. In
1975, Bates introduced a constitution for his Principality. Consisting of
twenty-three articles and purportedly based on the common law, its
preamble reads:
In consciousness of his responsibility before God and before man, and
inspired by the will to serve the cause of Peace for his People and for all
peoples in the world, the sovereign ruler of the p r i n c i p a l i t y o f
se al a nd , His Majesty Prince Roy of s e a l a n d, for himself and for
his successors to the throne, by virtue of his constitutional authority
resolves, swears and proclaims:23
Bates has adopted further state symbols. The Principality has its own flag,
coat of arms, national anthem (in 2005, the anthem was recorded by the
Slovak Symphony Orchestra as part of its series on national anthems of
the world)24 and motto – E Mare, Libertas (From the Sea, Freedom). It
also mints its own currency, commissions postage stamps, issues its own
national passport and sells noble titles. The Principality has also often
pursued diplomatic relations with other sovereign states.
***
On the other side of the world, a former UK colony soon found itself
tangling with a similarly stubborn and eccentric individual, though it
adopted a different approach. At 5.10 p.m. on Friday 2 December 1977,
21
Minutes of Meeting Re: Roughs Tower (5 November 1968) cited in Grimmelmann
(n 1) 423.
22
Taylor-Lehman (n 1) 61.
23
Wikisource, ‘Principality of Sealand: Constitution of 1975’ https://en.wikisource.org/wiki/
Constitutions_of_1975 and of 1989/Constitution of 1975.
24
Slovak Symphony Orchestra, ‘Sealand’ www.youtube.com/watch?reload
=9&v=ENwjBz3m5Y8.

6 1 p r i n c e l eo na r d p r e p a r es f o r wa r
Prince Leonard Casley of the Hutt River Province cabled a telegram to Sir
John Kerr, the Governor-General of Australia. The telegram’s contents
were ominous:
Confirming my letter of 28th November re your Governments [sic] lack of
respect of the laws not only on my people but also on people of your own
country and Mr. Keatings [sic] further disrespect to the courts. Previous
acknowledgement of duress having been applicable it is my official
responsibility to declare that a state of war now exists between our
respective countries and diplomatic relations are at this time now
severed.25
With a permanent population of fewer than twenty residents, no stand-

ing army, and the Province’s 75-square-kilometre territory entirely
enclosed by the state of Western Australia, Prince Leonard was unpre-
pared for war. Two days later, at 3.30 p.m. on Sunday 4 December 1977,
he cabled a second telegram announcing, ‘that the state of war between
our countries has now ceased’.26 The Australian government responded
to neither correspondence, but Prince Leonard nonetheless claimed
victory. According to his reading of the Geneva Conventions of 1949,
a state should show full respect to a nation undefeated in war. As the Hutt
River Province was undefeated, Australia must recognise its sovereignty.
Australia has never recognised the sovereignty of the Hutt River
Province, but its founding reveals how a combination of frustration
with government regulation and anxiety over the ability to secure a safe
and prosperous life for one’s family can set people on a curious path.
Australia’s response, or lack thereof, also illustrates the diversity of
approaches that can be adopted when dealing with self-declared states.
In the 1960s, Leonard Casley bought a property in the Australian state
of Western Australia. Situated at Hutt River in the district of
Yallabatharra, about 500 kilometres north of the state capital, Perth,
Casley intended to establish a wheat farm. The Australian wheat industry
had undergone a significant transition over the previous decades that had
generated long-term resentment amongst many farmers. The Great
Depression led to the failure of countless small farms across the country.
Seeking to counteract the nation’s adverse trade balance and restore
economic prosperity, the Australian government initiated a campaign
25
‘Telegram from Prince Leonard Casley to Sir John Kerr (Governor General of Australia)’
(2 December 1977).
26
‘Telegram from Prince Leonard Casley to Sir John Kerr (Governor General of Australia)’
(4 December 1977).

1 p r i n c e l eon a r d p r e p a r es f o r wa r 7
to ‘Grow More Wheat’. Although leading to a 30 per cent increase in

production, the program quickly turned into ‘one of the greatest disasters
in Australian economic history’.27 Political bickering meant that the
government could only pay 40 per cent of what it had initially promised,
leaving up to 20,000 small farmers who had borrowed heavily to plant
larger acreage bankrupt.28 A subsequent ‘Eat More Bread’ campaign,
launched in an effort to absorb 1 million bushels of wheat unsold from
the previous harvest,29 did little to rectify these issues.
Industry consolidation and rising production levels through the 1930s
began to challenge the capacity of smaller, independent farmers to
compete in a global market. Large-scale grain producers were able to
leverage their size to better negotiate with domestic and international
wheat buyers and drive down prices. Emerging state intervention aimed
at standardising prices was fast-tracked by the outbreak of World War II.
In 1939, the government established the Australian Wheat Board (AWB)
to oversee the marketing, storage, shipping, pooling and payment of the
country’s wheat output. Throughout the war, the AWB implemented
price stabilisation measures, including by guaranteeing prices, creating
a stabilisation fund and regulating the issuing of new growing licences. By
the end of the war, both industry and government accepted the necessity
and desirability of maintaining a policy of stabilisation during peacetime.
When Casley bought his property, the AWB still regulated and man-
aged the industry. National and State Boards sought to shelter growers
from volatility by stabilising prices and incomes. The Board compulsorily
acquired and pooled all wheat produced in Australia, established a home
consumption price, and had the sole authority to market wheat domes-
tically and internationally. Following a bumper harvest in 1968, industry
sought the introduction of production quotas to reduce stock build-up
and maintain pricing levels. The Western Australian government agreed,
imposing quotas for the summer harvest.
The quotas had a deleterious effect on many farmers, including Casley.
In November 1969, while preparing to harvest around 6,000 acres of
wheat, Casley received a letter notifying him that he would be permitted
27
Edgars Dunsdorfs, The Australian Wheat Growing Industry 1788–1948 (Melbourne
University Press, 1956) 270–5.
28
Wendy Way, A New Idea Each Morning: How Food and Agriculture Came Together in One
International Organisation (Australian National University Press, 2013) 140.
29
‘Endorsement by Minister; Whole Community Will Benefit’, Evening News (Sydney,
26 May 1930) 10; ‘“Eat More Bread” Campaign in NSW’, Barrier Miner (Broken Hill,
15 August 1930) 1.

8 1 p r i n c e l eo n a r d p r ep a r e s f o r wa r
to sell only 100 acres. As Casley explained in a letter to the Governor of

Western Australia,
Under this new quota, it would have taken five hundred years to crop the
same average amount of wheat that had been harvested in the previous
twenty years. The gross proceeds would not have even paid the interest on
the hire purchase on two four-wheel drive tractors that were in use. This
did not allow any return for maintenance of their homes and families, no
income on which to survive let alone profit.30
Considering the quotas illegal, Casley called for compensation in the

form of 1.8 million acres of land, ‘whose rentals will thus be a fair
settlement of our losses thus being brought about by the Wheat
Quota’. He also sought that the Governor ‘grant us our independence,
under the Queen and a part of the British Commonwealth’.
Casley’s call fell on deaf ears. Despite filing complaints with the Wheat
Quota Board, as well as the Premier and Governor of Western Australia,
he was informed that there would be no change to the quota. Concerned
that the state might resume or forcibly acquire his property, he served
a formal notice of secession to the Commonwealth and State govern-
ments on 21 April 1970. After observing what he considered a legally
required two-year notice period, Casley officially declared the formation
of a new state on 21 April 1972.
Casley purported to establish his nation based upon ‘the rights of the
Magna Carta and the rights of the Atlantic Treaty and the International
rights to’ create ‘Self Preservation Governments’.31 However, neither
document supports the assertion of independence, meaning that there
is no sound legal basis for Prince Leonard’s action. For this reason,
neither the Australian nor the Western Australian government
responded.
Nonetheless, Casley continued to act as though his claim was lawful.
Consistent with the British diplomatic laws of recognition, following
independence a flag was chosen and correspondence delivered to the
Governor-General of neighbouring Australia. In March 1971, a Bill of
Rights was adopted promising all persons the full protection of the law.
Hutt River coins were minted, postage stamps and passports issued and
30
‘Letter from Leonard Casley to Sir Douglas Kendrew, Governor of Western Australia’,
3 November 1969.
31
‘Fate Accompli: Declaration from Leonard Casley to Sir David Brand, Western Australia
Premier’, 21 April 1970.

1 p r i n c e l eo n a r d p r ep a r e s f o r wa r 9
a national anthem recorded. Casley also sent numerous letters to repre-

sentatives of various states seeking diplomatic recognition.
In the months following his purported declaration of independence,
Casley was anxious that the Australian government might act to dissolve
his aspirant state. Casting around for a more secure legal basis for its
existence, Casley identified a law passed during King Henry VII’s reign as
critical to shoring up the independence of Hutt River. The Treason Act 1495
was passed to heal lingering resentment following the War of the Roses.
Aiming to encourage former advocates of Richard III to support Henry VII
against any potential attempt by the House of York to retake the throne, it
provided that anyone serving or fighting for the king de facto (Henry) against
the king de jure (potentially those with a rival claim through Richard) would
not be guilty of any offence. Drawing on this provision, Casley invested
himself as His Royal Highness Prince Casley and transformed the Hutt River
Province into the Principality of Hutt River. As he (wrongly) understood it,
because he was a de facto prince, the law would preclude Australia prosecut-
ing him or his family for any offences they committed while he attained his
throne and would prevent the Australian government from interfering with
him ‘in the discharge of his Princely duties’.32 Prince Leonard need not have
worried. Australia largely ignored the Principality over the fifty years follow-
ing its founding, save only to ensure that it complied with taxation laws.
***
Prince Leonard’s declaration of war indicates that self-declared states can
be particularly inventive in seeking to have their sovereignty recognised.
But not all attempts to ground international recognition need be so
hostile. In 1992, Dean Kamen, the inventor of the Segway and mobile
insulin pump, as well as self-appointed ruler of the Kingdom of North
Dumpling, convinced his friend, President George HW Bush, to sign
a non-aggression pact between their two countries – though the United
States does not formally recognise the Kingdom.33
The Kingdom of North Dumpling is also known as North Dumpling
Island. It is a privately owned, three-acre island in Fishers Island Sound,
around one mile off the coast of Connecticut. Originally within the
traditional lands of the Pequot Indians, the island was acquired by John
Winthrop, son of the governor of the Massachusetts Bay Colony, in 1639.
The island was owned by the Winthrop family until 1847, when it was
32
Hutt River Province, ‘Formation of the Hutt River Province’.
33
Clarice Butkus, ‘North Dumpling Island: Micronationality, the Media and the American
Dream’ (2014) 8 Shima: The International Journal of Research into Island Cultures 84.

10 1 pr i n c e l e o n a r d p r e p a r e s f o r w a r
sold to the federal government to construct a lighthouse. In 1959, the

lighthouse beacon was automated, and the island sold to a private party.
In 1986, Kamen bought it for USD 2.5 million.
The following year, Kamen sought permission from authorities in
New York State’s Suffolk County to construct a 100-foot wind turbine
on his property. Permission was denied, as regulations restricted struc-
tures more than 40 feet tall in residential areas. Rather than amend his
plans, Kamen purported to secede from the United States. As The
New York Times reported at the time:
Although owning an island in the Sound and considering it to be a land
apart is not an unheard of notion, few people have gone to such theatrical
lengths to establish a semblance of sovereignty.34
Theatrical is the correct word. Styling himself as Lord Dumpling II, Kamen
has staged ‘various tongue-in-cheek performances of sovereignty’.35 He
drafted, or rather claims to have unearthed, a constitution that bears striking
resemblance to the US Constitution, ‘which is why the Dumplonians and
Americans have gotten along for so many years’.36 He also composed
a national anthem, designed a flag and created a currency ‘which features
a 250,000 Dumpling note bearing a portrait of Kamen in bowtie and propel-
ler-donned cap’.37 Kamen also named a Cabinet, appointing several of his
friends to important positions, including the founders of Ben and Jerry’s ice
cream, Ben Cohen and Jerry Greenfield, as Ministers of Ice Cream.38
The Kingdom of North Dumpling clearly differs from both the
Principalities of Sealand and Hutt River. While all three self-declared states
trade on a currency of popular fasciation or bemusement, Kamen has used
his personal fiefdom to garner media exposure and attention for his various
endeavours and scientific activities. In hundreds of interviews with national
and international media, Kamen has characterised the Kingdom as ‘a proof
of concept center’ for his inventions,39 or a ‘working model for how the
34
Nick Ravo, ‘From L.I. Sound, A New Nation Asserts Itself’, The New York Times
(22 April 1988).
35
Butkus (n 33) 87.
36
How to Start Your Own Country (Everyday Pictures, 2010).
37
Butkus (n 33) 87.
38
Michael Inbar, ‘Welcome to Secret Island of an Eccentric Genius’, Today
(22 October 2010) www.today.com/news/welcome-secret-island-eccentric-genius-
wbna39775733.
39
John Richardson, ‘How Dean Kamen’s Magical Water Machine Could Save the World’,
Esquire (24 November 2008) www.esquire.com/news-politics/a5319/dean-kamen-1208/.

1 p r i n c e l e o n a r d p r e p a r es f o r w a r 11
United States should handle many of its energy issues’.40 As he told the
Guardian newspaper in 2009:
‘Dumpling is completely carbon neutral,’ he says. ‘We have solar panels
on every building, a 10kW wind turbine, our own little Stirling engine for
backup power, burning only local fuel. We’re making our own water out
of the ocean with Slingshot [a water purification invention].’41
That was not all; ‘we are now developing a foreign aid program to help
the US’,42 Kamen added mischievously.
***
The Principality of Sealand, the Principality of Hutt River and the
Kingdom of North Dumpling are not independent sovereign states.
Instead, they are examples of the many people around the world who
have claimed to secede and create their own country. A new state is, of
course, the goal of secessionist movements across the globe, including in
South Sudan, Kosovo, Scotland, Catalonia, Quebec and elsewhere. As
should be clear by now, however, the purported attempts at secession of
Roy Bates, Leonard Casley and Dean Kamen differ fundamentally from
these efforts. Built around a committed and eccentric individual, pos-
sessing only a very small resident population and unrecognised by
sovereign states, these would-be countries are ‘aspirant’ or ‘wannabe’
states.43 More commonly, they are known as micronations.
In contrast to true secessionist movements, micronations are generally
considered trivial and are often – though not always – ignored by the
state. This may be because a micronation does not pose a security threat
and lacks a foundation in domestic and international law for its claim to
independence. It may also be because, like the Kingdom of North
Dumpling, it is not clear that statehood is genuinely prized. In all cases,
however, micronations distinguish themselves by dressing in the lan-
guage of statehood and performing acts of sovereignty; they draft consti-
tutions, issue coins, print stamps, compose national anthems and seek to
engage in diplomatic relations with recognised states. In doing so,
40
Butkus (n 33) 91.
41
Mark Harris, ‘Segway Inventor on Future Technology – and Why Videogames Aren’t It’,
Guardian (23 July 2009) www.theguardian.com/technology/2009/jul/22/dean-kamen-
interview.
42
Ibid,
43
Philip Streich, ‘To the Sea! Sealand and Other Wannabe States’ in David Bell Mislan and
Philip Streich (eds), Weird IR: Deviant Cases in International Relations (Palgrave
Macmillan, 2019) 15, 17; Adam Grydehøj, ‘Captain Calamity’s Sovereign State of
Forvik’ (2014) 8 Shima: The International Journal of Research into Island Cultures 34, 34.

12 1 p r i n c e l e o n a r d p r e p a r es f o r w a r
micronations critique and challenge understandings of and approaches

to international legal personality. They also catalyse larger questions
over the nature of statehood, sovereignty, security and legitimate
authority. Put simply, micronations are an oddity that sits outside con-
ventional understandings that help us to challenge and better understand
the law.
The vignettes that we have chosen to introduce our study highlight
several key themes of micronationalism. In each case, an entity led by
a dedicated and unconventional character sought to engineer inter-
national recognition of its statehood. Although none of these microna-
tions has ever achieved actual legal recognition, they nonetheless
consider their efforts a success. This is because performative assertions,
or mimetic reproductions, of sovereignty have value and an effect regard-
less of how a state responds.44 If, like Australia and the Principality of
Hutt River, the state refrains from action, the micronation may regard
that non-response as an implicit acceptance of its sovereignty. Likewise, if
the state reacts by simply acknowledging receipt, suggesting an alterna-
tive department to contact, or even signing a faux non-aggression pact,
the micronation may assert that its sovereignty has been recognised.
Finally, if, as in the case of the Principality of Sealand, the state responds
by implying that the micronation has engaged in some form of criminal-
ity, it opens up space for political and legal debate for the micronation to
contest its claim. As Stuart Hill, the leader of the Sovereign State of
Forvik – a micronation claiming sovereignty over an uninhabited
2.5-acre island in the Shetland Islands, 170 kilometres north of mainland
Scotland – has remarked, ‘it’s a win-win situation’.45
The nature of micronations and the ease with which they can be
established (and abandoned) make it difficult to assess the total number
of such entities across the globe. The growth of the Internet and web-based
micronational communities make accurate assessment even more challen-
ging. A brief survey reveals that thousands of micronations exist entirely
on social media platforms, like Facebook,46 Reddit47 and MicroWiki.48
44
Fiona McConnell, Terri Moreau and Jason Dittmer , ‘Mimicking State Diplomacy: The
Legitimizing Strategies of Unofficial Diplomacies’ (2013) 43 Geoform 804, 810.
45
Cited in Ibid.
46
Facebook, ‘Micronations and Alternative Polities’ www.facebook.com/groups/microna
tions andalternativepolities/.
47
Reddit, ‘Micronations – Small Nations, New Country Projects, Seasteading’ www
.reddit.com/r/micronations.
48
Microwiki https://micronations.wiki/Main_Page.

Several lists of micronations have been developed. The interdiscip-

linary academic journal Shima, which serves as a forum for research
into island cultures, insular communities and imaginations of auton-
omy, has published an anthology on micronationality that stretches to
twenty papers and fifteen micronations.49 Atlas Obscura, an online
magazine and travel company that specialises in providing guides to
strange and odd places around the world, has written forty-four art-
icles on around thirty micronations.50 The Lonely Planet Guide to
Home-Made Nations, published in 2006, features detailed discussion
on fifty micronations.51 A ‘Micronations World Map’, a user-edited
online map that allows people to tag micronations on parts of the
globe, catalogues sixty-seven different micronations.52 A list on
Wikipedia stretches to eighty-nine distinct entries.53 Another user-
edited online map created by Matthew Hubbard (formerly the ruler
of the now defunct Republic of Matthewopia) identifies over 100
micronations and other like entities.54 Complicating matters, however,
is the fact that each list includes several micronations that others do
not. Adding these up to produce an estimated total number of micro-
nations suggests a figure of at least 135 micronations, though many of
these entities are no longer active and it is unlikely that even this tally
is comprehensive.55 In an appendix, we list the micronations that we
discuss in this book.
The entities catalogued in these lists are limited to micronations that
physically claim territory in some manner. In most cases, this means that
the micronation extends so far as the real property owned or occupied by
49
Shima, ‘Micronationality Anthology’ https://shimajournal.org/anthologies/micronation
ality.php.
50
Atlas Obscura, ‘Micro-nations’ www.atlasobscura.com/categories/micro-nations.
51
John Ryan, George Dunford and Simon Sellars, Micronations: The Lonely Planet Guide to
Home-Made Nations (Lonely Planet, 2006).
52
Micronations World Map www.google.com/maps/d/viewer?msa=0&mid
=1VzMWnhHJbOWfCFkaEt TSw_3cNO4&ll=-10.102620343996707%2C-100.464
28450000002&z=2.
53
Wikipedia, ‘List of Micronations’ https://en.wikipedia.org/wiki/List_of_micronations.
54
Matthew Hubbard, ‘Micronations World Map’ https://earth.google.com/web/
@-1.99921679,0.00000001,63.91320881a,14045213.08685379d,30y,0h,0.00000106t,0r.
55
It does not, for instance, include any of the entities that emerged during the Japanese
micronational boom in the 1980s. See, for example, Adam Pasion, ‘The Will to Secede:
Japan’s Micro-Nation Boom’, Japan Daily (9 February 2016) https://japandaily.jp/will-
secede-japans-micro-nation-boom-2573/. Information on this phenomenon is difficult
to gather, suggesting that our tally may overlook micronations in non-English speaking
countries.

14 1 p rince l eonard prepares for w ar
its founder. With this relatively secure land base, these founders institute
the trappings of statehood; seek to regulate citizenship, issue passports,
grant visas, draft constitutions and compose national anthems. While
they may be distinguished according to how ‘serious’ their claims for
secession appear to be – compare the Principality of Sealand with the
Kingdom of North Dumpling – all make a formal and persistent claim to
sovereignty in the real world.
Not all micronations are territorial or ‘secessionist’ in the same way.
Spurred by the rise of internet access, many thousands of microna-
tions are entirely ‘virtual’ or ‘simulationist’. Existing almost wholly
online, these imaginary countries often function more as a political or
cultural simulation than an inchoate or emerging state. Their terrain is
message boards and online forums; it is here where government
business is simulated, non-aggression pacts signed and tips for nation-
building shared. In some cases, these virtual nations maintain physical
embassies and attend micronational conferences or summits, but the
physical territory they claim is fictional or impossible to reach. In
other cases, simulationist micronations may be expressly described as
conceptual or non-territorial. One may not be able to visit these
nations, but because they claim sovereignty, establish governments
and generally act like a nation, they are also properly characterised as
micronations.
One early micronation declared its independence in 1811. The
previous year, Massachusetts whaler Jonathan Lambert landed on
a remote volcanic island group around 2,800 kilometres from Cape
Town and more than 4,000 kilometres from the Falkland Islands in the
South Atlantic Ocean. Although first sighted in 1506 by Portuguese
explorer Tristão da Cunha, who named the largest of the four uninhab-
ited islands after himself, Lambert and his three-man party were the first
ever to settle permanently. On 4 February 1811, Lambert declared him-
self sovereign and sole possessor of the group of islands:
As no European powers whatever had hitherto publicly claimed the said
Islands, by right of discovery, or of possession: Therefore be it known to
all nations, tongues, and languages, that from and ever after the date of
this public instrument, I constitute my individual self the sole proprietor
of the above-mentioned islands, grounding my right and claim on the
rational and sure ground of absolute occupancy.56
56
A Watson, ‘Tristan d’Acunha, &c; Jonathan Lambert, late Sovereign thereof’ (1818) 4(21)
Blackwood’s Edinburgh Magazine 280, 282.

Lambert adopted a flag, renamed the anglicised Tristan da Cunha, the

‘Island of Refreshment’, and sent his declaration of sovereignty to the
United States and governments in Europe.57 Copies and summaries
appeared in scores of newspapers, but Lambert’s claims were dismissed.
Charles Dickens later derided him as ‘Prince Jonathan’,58 while a more
recent account belittled the ‘toy king on his desert island’.59
The Island of Refreshment did not survive for long. Lambert and two
other men were presumed drowned while fishing the following year.
Larger geopolitical concerns soon intervened. In 1816, the islands were
annexed by the British to prevent the French from using them as a base
for a rescue operation to free the exiled Napoleon I from his prison on
Saint Helena, some 2,400 kilometres away, as well as to stop the
Americans from using it as a staging ground for naval cruisers, as they
had during the war of 1812. Two men, including one who had initially
arrived with Lambert, were found living on the island; both were ‘glad to
place themselves under the protection of the British flag’.60
More than 200 years later, micronationalism is alive and well, but
developments in technology continue to affect and influence the phe-
nomenon. In October 2016, Russian-Azerbaijani scientist Igor
Ashurbeyli announced the establishment of Asgardia. Asgardia’s terri-
tory is small and remote; also called the Space Kingdom of Asgardia, its
territory is putatively based on a 10 cm x 10 cm x 20 cm satellite
Ashurbeyli had launched into low-earth orbit.61 Somehow, he hopes
that this satellite will augur the creation of a space colony. For
Ashurbeyli, Asgardia was established with four overarching goals: ‘to
ensure the peaceful use of space, to protect the Earth from space
hazards, . . . to create a demilitarized and free scientific base of knowledge
in space . . . [and] set[] up habitable platforms in space and build[]
57
James Fichter, ‘The British Empire and the American Atlantic on Tristan da Cunha,
1811–1816’ (2008) 36(4) Journal of Imperial and Commonwealth History 567, 570.
58
Charles Dickens, ‘The Diminutive Dependency’ in All the Year Round (Volume XVIII,
31 March 1877) 111, 112.
59
Margaret Mackay, Angry Island: The Story of Tristan da Cunha (1506–1963) (Rand,
McNally & Company, 1963) 31.
60
Fichter (n 56) 582; Watson (n 55) 282; Stephen Royle, ‘Perilous Shipwreck, Misery and
Unhappiness: The British Military at Trista da Cunha, 1816–1817’ (2003) 29(4) Journal of
Historical Geography 516, 517.
61
Constitution of the Space Kingdom of Asgardia, art 5 (9 September 2017); Leah Crane, ‘The
“Space Nation” Asgardia Just Launched Its First Satellite’, New Scientist
(13 November 2017) www.newscientist.com/article/2153196-the-space-nation-asgardia-
just-launched-its-first-satellite/.

16 1 pr i n c e l e o n a r d p r e p a r e s f o r w a r
settlements on the Moon’.62 Assuming that the (significant) techno-

logical challenges can be overcome, Ashurbeyli is hopeful that his ‘nation
above the clouds’63 can take shape. Perhaps small steps are encouraging.
Over 1,200 people have paid a residency fee as a first step to obtaining
citizenship, with more than a million more people registering as followers
on the Kingdom’s website.64
Inchoate efforts at international recognition have followed. Drawing
on a personal friendship, Ashurbeyli has met with Prince Michael of
Kent – cousin to Queen Elizabeth II of the United Kingdom – to discuss
Asgardia.65 Ashurbeyli has also written to at least thirty-two recognised
states, declared that he intends to apply for membership of the United
Nations66 and has sought to promote Asgardia as a home for peoples
without states:
Asgardia will unite the representatives of all nations who aspire to self-
determination in the narrow boundaries of earthly states. It is in Asgardia
where they will get their freedom.67
Asgardia remains experimental and unrealised, but the growth of the

Internet has allowed Ashurbeyli to market his project, attract supporters
and raise funds.
The story of the short-lived Island of Refreshment and the avant-garde
Space Kingdom of Asgardia illustrate how micronations challenge con-
ventional understandings of statehood. Indeed, Jonathan Lambert’s
claim of sovereignty appears to have been established consistently with
the law at the time. Tristan da Cunha was uninhabited and unsettled.
According to the prevailing theories of international law, discovery of
such lands, accompanied by symbolic acts such as raising a flag, provided
62
Asgardia, ‘Concept: Asgardia – the Space Nation, https://asgardia.space/en/word.
63
Humaid Alshamsi, Roy Balleste and Michelle Hanlon , ‘Space Station Asgardia 2117:
From Theoretical Science to a New Nation in Outer Space’ (2018) 16(1) Santa Clara
Journal of International Law 36, 55.
64
Asgardia, ‘Take Your Steps Toward Becoming a Resident’ https://asgardia.space/en/page/
resident-card.
65
Ivan Cherbeko, ‘Head of Nation Talks of Asgardia to Queen Elizabeth II’s Cousin’,
Asgardia (8 March 2019) https://asgardia.space/en/news/Head of-Nation-talks-of-
Asgardia-to-Queen-Elizabeths-II-Cousin.
66
Imogen Saunders, ‘The “Space Kingdom” Asgardia Has Its Own Flag and Anthem, but
a State It Is Not’, The Conversation (15 August 2018) https://theconversation.com/the-
space-kingdom-asgardia-has-its-own-flag-and-anthem-but-a-state-it-is-not-101250.
67
Cited in Sergey Krichevsky and Sergey Udartsev, ‘Space State on Earth and Beyond:
Philosophy, Models, Experience and Prospects’ (2019) 23 Philosophy and Cosmology
30, 45.

1 p rince l eonard prep ares for w ar 17
an inchoate title against other states. That inchoate title could then be
perfected by taking actual possession and forming settlements.68 This is
precisely what Lambert did. On what basis then was his sovereignty
denied? Asgardia may currently possess and occupy no territory, but if
technology develops to allow permanent habitation in space, how should
international law and recognised sovereign states assess the status of
those communities?
Micronations are diverse in form and function. Some are established
on uninhabited islands or abandoned manmade structures. Others are in
remote locations within the territory of existing sovereign states, or even
in outer space. Still others are dreamed up entirely within college dorm
rooms and built on message boards. In light of this heterogeneity is it
even possible to speak of a single phenomenon?
This book contends that it is. We argue that, despite their broad
variety, micronations are a particular and peculiar type of political entity.
In exploring that diversity, the book examines the legal questions that are
catalysed by micronationalism. It analyses whether micronations are or
could be states for the purposes of international law. It considers the
factors that motivate countless individuals all over the world to secede
and create their own country as well as the numerous quasi or faux legal
justifications that they offer. It also explores how recognised sovereign
states respond to the challenge posed by micronations.
We begin in Chapter 2 by developing a conceptual framework and
definition of micronations. As we have seen, micronations are an incred-
ibly diverse phenomenon, but all micronations share central features.
Each makes a claim for statehood despite having no legal basis for doing
so. Drawing on this insight, we compare and contrast micronations with
other entities that purport to exercise political and legal authority. As we
outline, a wide variety of entities with more or less effective government,
more or less legitimate claims to statehood, and more or less recognition
and acceptance by individual states and the international community,
exist around the world. By developing a ‘statehood spectrum’ along
which a range of state and state-like entities may be placed, these com-
plexities can be unravelled and a clearer picture of what makes microna-
tions distinct emerges. We find that micronations are self-declared
nations that perform and mimic acts of sovereignty, and adopt many of
the protocols of nations, but lack a foundation in domestic and
68
Emer de Vattel, The Law of Nations (1797) §208.

18 1 p r i n c e l e o n a r d p r e p a r es f o r w a r
international law for their existence and are not recognised as nations in
domestic or international forums.
Drawing on our conceptual framework, Chapter 3 surveys a wide
cross-section of micronations, focusing on the varied motivations for
their creation, as often expressed by their founders. Such stories are part
of a micronation’s self-created history and narrative. While they may be
aggrandising or performative, they are nonetheless valuable in under-
standing the reasons why a person chooses to found their own country.
Our survey reveals that some are established as conceptual art projects
designed to critique understandings of statehood and sovereignty. Others
are founded in a combination of frustration with regulation and
a burning sense of a political injustice. Still others owe their formation
to their creators’ sense of personal expression and desire for attention. In
many cases a combination of these and other impetuses motivates seces-
sion. In all cases, however, although micronations may purport to assert
sovereignty in any number of ways, they remain conceptually distinct
from recognised sovereign states.
The varied motivations behind the establishment of micronations has
consequences for the political and legal issues they provoke. For instance,
micronations that purport to claim authority over specified territory give
rise to questions over the recognition and regulation of acts of secession
and state creation, while micronations that reclaim land, develop floating
structures on the sea, or seek to build habitable structures in space, elicit
enquiries into the conditions for statehood under international law.
In contrast, micronations established as a humorous endeavour or
a conceptual art project may not intend to seriously engage in these
debates, but they too still face questions over the enforcement of domes-
tic laws. These questions are explored in Chapters 4 and 5.
In Chapter 4, we examine how micronations seek to legitimate their
sovereignty. Founders and proponents of micronations may be eccentric
or unconventional but they can be careful in their attempts to validate
their actions. Mimicking recognised states, they adopt statehood proto-
cols, including designing and developing national symbols and pursuing
diplomatic relations. Furthermore, although they may have little legal
training, they use a wide variety of materials to find a lawful basis for their
claims. Micronations search for a foothold in international legal instru-
ments as if finding a gap or inconsistency in, for example, the law of the
sea, can ground a claim for sovereignty.
In declaring independence, drafting a constitution, regulating citizen-
ship and issuing passports, micronations position themselves as rival

1 prince leonard prepares for war 19
sites of authority. In Chapter 5, we explore the different ways that

internationally recognised states respond to micronations’ claims to
sovereignty. This chapter reveals that even though micronations are
largely ignored in the international relations, political science and legal
literature, in practice states must take notice and consider appropriate
ways to engage. In some cases, states perceive their existence as
a provocation or threat to their own claims of authority and to jurisdic-
tion and can act in swift and decisive ways to foreclose micronations’
scope of action. In other cases, states ignore micronations, considering
them to be trivial or unthreatening. In all circumstances, however, states
deny the international legal personality of micronations and ensure that
any encounter occurs entirely within and according to domestic law.
In the final chapter we consider the future of micronationalism. We
outline the five major themes that emerge from our larger study, explor-
ing in more detail the relationship between micronations and recognised
states, as well as the creativity, diversity, temporality and gendered nature
of micronationalism. Having drawn out these points we reflect more
broadly on the key characteristic shared by all wannabe states: despite
having no legal basis for their assertions, all micronations make a claim
for statehood. Why? What value do founders and proponents see in the
language of statehood? Are their claims intended to be taken seriously or
are they simply a cry for relevance? Finally, we contemplate the success or
failure of micronations. In circumstances where no micronation has ever
become a sovereign state, is the future of micronationalism still bright?

2
Statehood and Micronations
Micronations have received little attention in the academic literature.

When it comes to legal scholarship, there is no account that outlines the
common features and outer bounds of what it means to be a micronation.
In fact, very few efforts offer an explanatory account of micronationalism
at all. In this chapter, we develop a detailed conceptual framework for
micronations to better understand and interrogate their common fea-
tures and considerable diversity. We begin from a simple starting point.
Entities like the Kingdom of North Dumpling and the Principality of
Sealand have pretensions to statehood, but they are clearly not states.
Notwithstanding their forceful or eccentric assertions to the contrary,
their claims to statehood have no legitimate foundation in domestic or
international law.
Our starting point frames micronations in opposition to states.
Understanding what a micronation is therefore requires attention to
statehood. Unfortunately, this task is complicated by the fact that while
states are the primary subjects of the international legal system, no
universally accepted legal account of what is and what is not a state exists.
In this chapter we examine these complexities by developing a ‘statehood
spectrum’ along which a range of state and state-like entities may be
placed. At one end sit internationally recognised sovereign political
communities like the United States of America, Portugal and South
Africa. At the other end sit entities with a more tenuous grasp of
statehood, perhaps because of some legal flaw in their purported creation
or political impediment to their capacity to exercise authority and
jurisdiction.
Not all entities can be placed on the statehood spectrum. At
a minimum, a political community must make and purport to perfect
a claim of and for statehood. For many reasons, a variety of entities
exercising political authority over a territorially bounded community do
not make such a claim. Moving beyond the statehood spectrum enriches
our understanding of both statehood and micronations. It reveals that
20

2.1 w hat is a state? 21
micronations can be distinguished from similar entities on the basis of

two key elements: the absence of any legitimate foundation in domestic
or international law for their existence, and, nonetheless, a claim for
statehood and international legal personality, whether earnest, plaintive,
delusional, satirical or otherwise. By probing these features, we can more
clearly identify what makes micronations distinctive.
Clearing the field of similar but distinct entities allows us to focus
on developing a legal definition of micronations to guide our discus-
sion throughout this book. After exploring several classificatory
accounts that identify commonalities and distinctions among and
between different types of micronation, we outline our definition.
We find that micronations are self-declared nations that perform and
mimic acts of sovereignty, and adopt many of the protocols of
nations, but lack a foundation in domestic and international law for
their existence and are not recognised as states in domestic or inter-
national forums.
2.1 What Is a State?

When the United Nations officially came into existence in October 1945,
it consisted of fifty-one member states. Seventy-six years later, member-
ship has swelled to 193 states.1 This substantial growth reflects several
major trends, the most prominent of which has been the development
and articulation of self-determination as a foundational principle of
international law.2 First expressed in the nineteenth century, the prin-
ciple of self-determination played a key role in the development of the
modern state system.3 Fuelling two waves of state formation in the period
after World War II, it sparked the dismantling of European colonial
1
United Nations, ‘Growth in United Nations Membership, 1945–Present’, www.un.org/en/
sections/member-states/growth-united-nations-membership-1945-present/index.html.
2
See, generally, Antonio Cassese, Self-Determination of Peoples: A Legal Reappraisal
(Cambridge University Press, 1995). James Anaya, Indigenous Peoples in International
Law (Oxford University Press, 2nd ed, 2004), Pt 2.
3
Declaration on the Granting of Independence to Colonial Countries and Peoples, UNGA Res
1514 (14 December 1960); Declaration on Principles of International Law Concerning
Friendly Relations and Co-operation Among States in Accordance with the Charter of the
United Nations, UNGA Res 2625 (24 October 1970) (‘Friendly Relations Declaration’);
Legal Consequences for States of the Continued Presence of South Africa in Namibia (South-
West Africa) Notwithstanding Security Council Resolution 276 (1970) (Advisory Opinion)
[1970] ICJ Rep 16, 31 [52]; Western Sahara (Advisory Opinion) [1975] 12, 31–3 [54]–[58].

22 2 st at eho o d an d mi cronations
empires in Africa and Asia in the 1950s and 1960s and underlay the
restoration of sovereign republics in Eastern Europe and Asia as part of
the dissolution of the Soviet Union.
Self-determination holds that all people have the right to freely choose
their political status.4 As this principle took hold across the globe and the
number of sovereign states increased, the term ‘state’ increasingly
became synonymous with the concept of a ‘nation’. In some cases, the
words were hyphenated as scholars described the division of the world
into a community of ‘nation-states’.5 The terms can also be treated as
identifying distinct concepts. While a state exercises jurisdiction over
particular territory irrespective of the population who inhabit that terri-
tory, a nation is an ‘imagined community’,6 comprising a people that
share a ‘psychological bond’.7 That bond is formed on the basis of a mix
of collective cultural, linguistic, religious or ethnic identities, as well as
shared ‘symbols, memories, myths, values and traditions’.8 A nation-state
is thus a sovereign political entity whose territorial borders are cotermin-
ous with the boundaries of a nation.9
States can have a real and direct impact on the lives of citizens and
residents. And yet, however innate or logical they may appear to be,
states are not natural entities.10 As James Crawford has explained,
‘[a] state is not a fact in the sense that a chair is a fact’.11 What then is
a state?
4
See International Covenant on Civil and Political Rights, opened for signature
16 December 1966, 999 UNTS 171 (entered into force 23 March 1976) art 1;
International Covenant on Economic, Social and Cultural Rights, opened for signature
19 December 1966, 993 UNTS 3 (entered into force 3 January 1976) art 1.
5
Ernest Gellner, Nations and Nationalism (Cornell University Press, 2nd ed, 2006) ch 1.
6
Benedict Anderson, Imagined Communities: Reflections on the Origin and Spread of
Nationalism (Verso, 3rd ed, 2006).
7
Walker Connor, ‘A Nation Is a Nation, Is a State, Is an Ethnic Group Is a . . .’ (1978) 1(4)
Ethnic and Racial Studies 377, 382.
8
Anthony Smith, ‘When Is a Nation’ (2002) 7(2) Geopolitics 5, 14–15. See also,
Anthony Smith, ‘The Origins of Nations’ (1989) 12(3) Ethnic and Racial Studies 340.
9
Note that given the distinction between ‘nation’ and ‘state’, the terminology ‘microna-
tions’ is a little awkward. However, it is the accepted naming for these entities, and we
adopt it for that reason. If nothing else, it also helpfully distinguishes micronations from
microstates. As we explore later, microstates may be very small, but they are states at
international law.
10
Robert Jackson, Quasi-States: Sovereignty, International Relations, and the Third World
(Cambridge University Press, 1990) 7.
11
James Crawford, The Creation of States in International Law (Oxford University Press,
2nd ed, 2007) 5.

2.1 what is a state? 23
2.1.1 Statehood and International Law

One way to answer this question is by turning to international law.
Historically, states were considered the sole subjects of the international
legal system. As the Permanent Court of International Justice noted in
1927, ‘[i]nternational law governs relations between independent
states’.12 International legal scholars have questioned whether this pos-
ition was ever entirely true, but in any case, political developments have
since complicated the picture. Today, a range of inter-state political
entities, international organisations, transnational social movements,
corporations and even rivers possess varying degrees of international
personality.13 And yet, ‘in spite of the complexities’, states remain the
primary subjects of international law.14 The state ‘continues to be the
only actor in international law that really matters, that is, the actor that
plays the decisive role in making, interpreting, and enforcing inter-
national law’.15
To be a state is to enjoy a suite of legal privileges and competencies in
the international sphere. At least five principles that ‘constitute the core
of the concept of statehood’ can be identified.16 First, formally, if not in
practice, all states have equal status and standing.17 While the United
States dwarfs Nauru in economic, political and military might, both states
have one vote in the United Nations General Assembly. Second, all states
possess plenary competence to make treaties and perform other inter-
national acts.18 Third, subject to any international legal obligations, all
states enjoy exclusive competence with respect to their internal affairs.19
In other words, the United Kingdom is not permitted to intervene or
12
SS ‘Lotus’ (France v Turkey) (Judgment) [1927] PCIJ (ser A) No 10, 18.
13
See, for example, Hersch Lauterpacht, ‘The Subjects of the Law of Nations’ (1947) 63 Law
Quarterly Review 438; Reparation for Injuries Suffered in the Service of the United Nations
(Advisory Opinion) [1949] ICJ Rep 174, 178; Gabriel Eckstein et al, ‘Conferring Legal
Personality on the World’s Rivers: A Brief Intellectual Assessment’ (2019) 44(6–7) Water
International 804.
14
Thomas Grant, ‘Defining Statehood: The Montevideo Convention and Its Discontents’
(1999) 37 Columbia Journal of Transnational Law 403, 407; James Crawford, Brownlie’s
Principles of Public International Law (Oxford University Press, 9th ed, 2018) 106.
15
Karen Knop, ‘Re/Statements: Feminism and State Sovereignty in International Law’
(1993) 3 Transnational and Contemporary Problems 293, 297.
16
Crawford (n 11) 42. See also International Law Commission, Draft Declaration on the
Rights and Duties of States (1949) arts 1–3, 5, 12.
17
Charter of the United Nations art 2(1).
18
Case Concerning Military and Paramilitary Activities in and Against Nicaragua
(Nicaragua v United States of America) (Merits) [1986] ICJ Rep 14, 133 [265].
19
Charter of the United Nations art 2(7); Friendly Relations Declaration (n 3).

24 2 st a t eh o o d a n d mi c r o n a t i o n s
intrude on French domestic or foreign policy. Fourth, states are not

subject to compulsory international process, jurisdiction or settlement
without their consent.20 If Australia does not agree to be bound by the
International Court of Justice, for example, it cannot be forced to comply
with any judgment of that Court. Finally, derogations from these prin-
ciples are not lightly assumed. In case of doubt, ‘an international court or
tribunal will tend to decide in favour of the freedom of action of states,
whether with respect to external or internal affairs, or as not having
consented to a specific exercise of international jurisdiction, or to
a particular derogation from equality’.21
These legal privileges and competencies mean that states are powerful
actors in the international sphere. However, while these principles illu-
minate the core of statehood, they do not help us identify whether an
entity is or is not a state; they are ‘consequences of statehood rather than
constitutive elements of it’.22 A definition is still required.
2.1.2 Definition and Criteria

Despite their centrality in the international legal system, no unanimously
accepted legal definition of what it means to be a state exists.23 Perhaps
more perplexing is the fact that international legal scholars have argued
against the utility or even possibility of establishing a clear definition.
One of the early attempts at forming a definition occurred in the late
1940s. In 1949, the International Law Commission – a body of experts
elected by the United Nations General Assembly and responsible for
helping to develop and codify international law – examined this issue
when considering the proposed Declaration on the Rights and Duties of
States. While many members of the Commission suggested that
a definition of the word ‘state’ would be essential for the Declaration,
others demurred. British international lawyer James Brierly, for instance,
noted that a definition ‘would be difficult to establish and highly
controversial’,24 arguing instead that the word ‘state’ ‘was commonly
20
Case of the Monetary Gold Removed from Rome in 1943 (Preliminary Question) (Italy
v France, United Kingdom and United States of America) [1954] ICJ Rep 19.
21
Crawford (n 11) 41. References removed.
22
David Raič, Statehood and the Law of Self-Determination (Kluwer Law International,
2002) 24.
23
Crawford (n 11) 37, 19 8; Grant (n 14) 408.
24
United Nations, International Law Commission Yearbook (1949), 1st sess, 8th mtg,
22 April 1949, 65 [21] (‘Yearbook of the ILC’).

2.1 what is a state? 25
used in documents and speech, and its meaning had been understood
without definition’.25 French international jurist Georges Scelle agreed,
considering ‘that it would be almost impossible to arrive at a universally
satisfactory definition of the term’.26 The following year, Scelle expanded
on this, explaining that:
He himself had been active in international law for more than fifty years, and
still did not know what a state was; and he felt sure that he would not find out
before he died. He was convinced that the Commission could not tell him.27
The Commission resolved its work by avoiding the problem. It con-

cluded that ‘no useful purpose would be served by an effort to define
the term “state”’, and it refrained from outlining the conditions necessary
for an entity to become a state.28
The difficulty in attaining a clear definition has not prevented legal
scholars from seeking this goal. For many years, this task was compli-
cated by the connection between statehood and ‘recognition’. In the
nineteenth century, statehood became entwined with the notion that
recognition played a formal role in the creation of states. The constitutive
theory of statehood, as it is known, holds that a sovereign state is
‘constituted’ or brought into existence by an act of recognition. In the
words of Lassa Oppenheim, ‘a state is, and becomes, an International
Person through recognition only and exclusively’.29 The account begins
from the position that the subjects of any legal system must be identifi-
able with certainty. A particular community cannot automatically be
considered a subject of the international legal system without some entity
making that determination. As Hersch Lauterpacht explained, in the
absence of a properly constituted ‘impartial international organ to per-
form that function . . . [it] must be fulfilled by states’.30
The constitutive theory focuses attention on the ‘juristic baptism’; that is,
the idea that recognition is ‘the agency of admission into “civilized
society”’.31 As existing sovereign states were deemed the proper gatekeepers
25
Ibid.
26
Ibid 68 [67].
27
United Nations, International Law Commission Yearbook (1950), 2nd sess, 52nd mtg,
22 June 1950, 84 [22].
28
Yearbook of the ILC (n 24) 289 [49].
29
Lassa Oppenheim, International Law: A Treatise (Longman, Green and Company, 1st ed,
1905) vol 1, 108 [71].
30
Hersch Lauterpacht, Recognition in International Law (Cambridge University Press,
1947) 5.
31
Crawford (n 11) 16.

to the international community, it endowed them with considerable author-

ity. While a particular community may govern itself according to its own
law and custom, it would not be considered a member of the ‘society of
nations’ unless and until it was implicitly or expressly recognised by other
(primarily European) states. Absent that recognition, international law
would take no notice of the entity; it would not be bound by nor gain the
protections of the law. Unsurprisingly, the constitutive theory played
a significant role in facilitating colonisation and imperialism. Recognised
states drew on discriminatory notions of ‘civilisation’ to deny Indigenous
peoples and communities in the Americas, Africa, Oceania and elsewhere
the right to govern themselves.32 The constitutive theory was also used
within Europe. The 1815 Congress of Vienna sought to settle disputes
arising from the French Revolutionary Wars and the Napoleonic Wars.
While the Congress admitted the representatives of more than 200
European polities, it recognised only thirty-nine states in the Final Act.33
The constitutive theory of statehood produces serious complications.
Putting to one side its historical role in denying international legal status
to Indigenous and other political communities, it seems to suggest that
statehood is relative and contingent on universal recognition.34 If this is
the case then it may have significant consequences for international peace
and security. For example, North Korea and South Korea do not formally
recognise each other as states, but this does not mean that North Korea is
free to invade and forcibly acquire Seoul, nor South Korea, Pyongyang.
Any armed conflict between these two entities will be regulated by
international law.35 Furthermore, as Stefan Talmon has noted, ‘the idea
of one state deciding upon another state’s personality in international law
is at odds with the fundamental principle of the sovereign equality of
states’.36 These obvious shortcomings in the constitutive account have
32
Antony Anghie, Imperialism, Sovereignty and the Making of International Law
(Cambridge University Press, 2012); Ntina Tzouvala, Capitalism as Civilisation:
A History of International Law (Cambridge University Press, 2020).
33
Kalevi Jaakko Holsti, Taming the Sovereigns: Institutional Change in International Politics
(Cambridge University Press, 2004) 128–9; Randall Lesaffer, ‘The Congress of Vienna
(1814–1815)’, Oxford Public International Law, https://opil.ouplaw.com/page/congress-
vienna-1814-1815.
34
Hans Kelsen, ‘Recognition in International Law’ (1941) 35(4) American Journal of
International Law 605, 609.
35
Crawford (n 11) 21.
36
Stefan Talmon, ‘The Constitutive Versus the Declaratory Theory of Recognition: Tertium
Non Datur?’ (2004) 75(1) British Yearbook of International Law 101, 102. See also Charter
of the United Nations art 2(1).

2 .1 w h at is a s ta te ? 27
prompted creative attempts to codify rules governing recognition,

including by imposing an obligation on states to recognise other
states.37 None of these efforts has been successful.38
In view of these and other challenges, the declaratory theory of state-
hood is generally accepted today.39 This account views recognition as
a political act, separate from legal questions over the existence of a state.
In the words of a 1929 German-Polish Mixed Arbitration Tribunal, ‘[t]he
state exists by itself . . . recognition is nothing else than a declaration of
this existence, recognised by the states from which it emanates’.40 The
Arbitration Commission of the Hague Conference on Yugoslavia (also
known as the Badinter Commission), established by the European
Economic Community to consider legal questions arising from the
dissolution of the Socialist Federal Republic of Yugoslavia, reached the
same conclusion. In its Opinion No 1, issued in 1991, the Commission
held that ‘the existence . . . of the state is a question of fact; . . . the effects
of recognition by other states are purely declaratory’.41 On this account,
North and South Korea’s mutual non-recognition has no legal conse-
quence for their status; both are states, and both are bound by inter-
national law.
Nonetheless, problems also persist under the declaratory account. For
one, without widespread recognition it is difficult in practice for a state to
actually engage in diplomatic relations or exercise its rights and obliga-
tions under international law.42 Recognition may be status-confirming
rather than status-creating, but it is still necessary for an entity to operate
as a state. Indeed, as Crawford has noted, in some cases, general recogni-
tion ‘may be practically conclusive’ as to whether an entity is a state or
not.43
The declaratory theory shifts attention away from subjective recogni-
tion to objective criteria. After all, if the effect of recognition by other
states is purely declaratory of a pre-existing fact, it becomes necessary to
identify some content or standard for statehood. While the International
37
Lauterpacht (n 30) 32–3, 73–5.
38
Crawford (n 11) 38.
39
Ibid 25; Talmon (n 36) 106.
40
Deutsche Continental Gas Gesellschaft v Polish State (1929) 5 ILR 11, 13.
41
Arbitration Commission of the Hague Conference on Yugoslavia (‘Badinter
Commission’), Opinion No 1 (1993) 92 ILR 162, 165. Affirmed in Opinion No 8 (1993)
92 ILR 199, 201.
42
Jessica Almqvist, ‘The Politics of Recognition: Kosovo’s Final Status’ in Duncan French
(ed), Statehood and Self-Determination (Cambridge University Press, 2013) 165, 170.
43
Crawford (n 11) 27.

Law Commission may have refrained from adopting any criteria,

a relatively stable list exists. The ‘best known formulation of the basic
criteria for statehood’44 is found in the 1934 Convention on the Rights
and Duties of States (the Montevideo Convention).45 The Montevideo
Convention outlines four criteria an entity must meet to be regarded as
a state: (1) a defined territory, (2) a permanent population, (3)
a government, and (4) a capacity to enter into relations with other
states.46
The list seems clear on its face but there are complications. First, many
scholars consider the Montevideo Convention criteria under- and over-
inclusive,47 both enumerating elements not essential to statehood and
failing to provide a complete definition. The fourth condition has come
under the most scrutiny, with scholars remarking that capacity to enter
into diplomatic relations is ‘a consequence rather than a condition of
statehood’,48 and one that varies with ‘the status and situation of particu-
lar states’.49 Others have noted that the competence to enter treaties is
also not reserved only to states; international organisations can negotiate
and sign treaties.
Second, the criteria themselves are malleable. As we explore in greater
detail in the next section, a wide ‘variety of entities with differing circum-
stances’ fall within the definition.50 For example, entities with a very
small territorial footprint, like the Vatican City (0.49 square kilometres),
Monaco (2.1 square kilometres) and Nauru (21 square kilometres) con-
tinue to be considered and treated as states. The same is true for some
entities that possess no territory. Poland and Czechoslovakia, for
instance, were both recognised by France in World War I despite not
possessing any land.51 Countries with miniscule resident populations are
also internationally recognised. The Vatican City lays claim to 618
44
Ibid 45.
45
Convention on the Rights and Duties of States, 165 L.N.T.S. 19, art 1 (signed
26 December 1933 and entered into force 26 December 1934) (‘Montevideo Convention’).
46
These criteria were adopted by the Badinter Commission, Opinion No 1 (1993) 92
ILR 165.
47
See, for example, Grant (n 14); Alison Eggers, ‘When Is a State a State? The Case for
Recognition of Somaliland’ (2007) 30 Boston College International and Comparative Law
Review 211; Bruno Coppieters, ‘“Statehood”, “de facto Authorities”, and “Occupation”:
Contested Concepts and the EU’s Engagement in Its European Neighbourhood’ (2018) 17
Ethnopolitics 343, 345.
48
Ingrid Detter, The International Legal Order (Aldershot, 1994) 43.
49
Crawford (n 11) 61.
50
Ibid 197.
51
Grant (n 14) 436.

2.1 w hat i s a state? 29
citizens, of which only 246 live within its boundaries,52 while Tuvalu and
Nauru both possess fewer than 11,000 people.
The government criterion is also elastic. There is a strong presumption
of state continuity in international law. This presumption operates to
avoid the premature recognition of another state, which would be con-
sidered ‘an unlawful interference in its domestic affairs’.53 For this
reason, the Badinter Commission explained that finding that a state has
lost its international personality must be approached with the ‘greatest
caution’.54 In practice, this means that a new state attempting to secede
will need to demonstrate ‘substantial independence, both formal and real’
before it will be regarded as ‘definitively created’.55 Conversely, a state
that no longer possesses an effective government is unlikely to immedi-
ately lose its status.56 Indeed, the absence of any effective or even existent
government for many years did not derail Somalia’s status as a state for
the purposes of international law.57 At the same time, for more compli-
cated geopolitical reasons some entities that easily satisfy the Montevideo
Convention requirements, such as Taiwan,58 are not considered to be
states. There is simply no rule prescribing a minimum area of territory,
size of population or effectiveness of government.59 Statehood appears to
be ‘ultimately contingent upon claim and response’.60
Third, the criteria are passive rather than active. They set out elements
that a state must possess, but ‘do not prescribe specific rights, powers or
52
Stato Della Città del Vaticano, ‘Popolazione’ (3 July 2018) www.vaticanstate.va/it/stato-
governo/note-generali/popolazione.html.
53
Jane McAdam, Climate Change, Forced Migration, and International Law (Oxford
University Press, 2012) 134.
54
Badinter Commission, Opinion No 8 (1993) 92 ILR 199, 201.
55
Crawford (n 11) 63.
56
Guglielmo Verdirame, ‘Sovereignty’ in Jean D’Aspremont and Sahib Singh (eds),
Concepts for International Law: Contributions to Disciplinary Thought (Edward Elgar,
2019) 827, 837.
57
Dimitrios Lalos, ‘Between Statehood and Somalia: Reflections of Somaliland Statehood’
(2011) 10 Washington University Global Studies Law Review 789; Ken Menkhaus,
‘Governance without Government in Somalia: Spoilers, State Building, and the Politics
of Coping’ (2007) 31(3) International Security 74.
58
Nii Lante Wallace-Bruce, ‘Taiwan and Somalia: International Legal Curiosities’ (1997) 22
Queen’s Law Journal 453.
59
Crawford (n 11) 46, 52. See further Jorri Duursma, Fragmentation and the International
Relations of Micro-States: Self-Determination and Statehood (Cambridge University Press,
1996); Jackson (n 10) 24.
60
Duncan French, ‘Introduction’ in Duncan French (ed), Statehood and Self-Determination:
Reconciling Tradition and Modernity in International Law (Cambridge University Press,
2013) 1, 2.

capacities’61 that a state must be able to exercise in order to qualify as

a state. This framing is intentional, as substantial variety in practice
precludes definition along capability lines. After all, even if independ-
ence – what Crawford describes as ‘the central criterion for statehood’62
– is added, significant peculiarities must be countenanced. The rise of
regional and global international organisations, for example, has
limited the capacity of states to act in certain ways, while many micro-
states delegate powers to neighbours without risking loss of their
status.63
Finally, although the criteria for statehood set out in the Montevideo
Convention are ‘essentially based on the principle of effectiveness’,64
statehood is more than merely effective governance. An entity must
meet certain conditions of legality before it will be considered a state.
In its Advisory Opinion on Kosovo’s Declaration of Independence, for
instance, the International Court of Justice confirmed that an entity
will not be regarded as a state when its establishment is ‘connected with
the unlawful use of force or other egregious violations of norms of
general international law, in particular those of a peremptory character
(jus cogens)’.65 Hence, despite the Turkish Republic of Northern Cyprus
meeting the Montevideo Convention definition, it is not a state because it
was formed as a result of the illegal use of force. Similarly, Southern
Rhodesia’s unilateral declaration of independence was never recognised
as lawful because the territorial entity was established in violation of the
right of self-determination.
These considerations remove the possibility of a straightforward def-
inition of statehood. In fact, it is likely that no definitive account can be
devised. For one, the centrality of states in the formation of rules of
international law creates ‘something of a logical impasse for international
lawyers when they attempt to conceptualise how that same law might
61
Crawford (n 11) 44–5.
62
Ibid 62.
63
Ibid 70; Zbigniew Dumienski, Microstates as Modern Protected States: Towards a New
Definition of Micro-Statehood (The Centre for Small State Studies, 2014).
64
Crawford (n 11) 97.
65
Accordance with International Law of the Unilateral Declaration of Independence in
Respect of Kosovo (Advisory Opinion) [2010] ICJ Rep 403, 437 [81]. See further Legal
Consequences of the Construction of a Wall in the Occupied Palestinian Territory (Advisory
Opinion) [2004] ICJ Rep 136, 171 [87]; International Law Commission, Draft Articles on
the Responsibility of States for Internationally Wrongful Acts, UN Doc A/56/2001
(November 2001) art 41(2); Roland Portman, International Legal Personality in
International Law (Cambridge University Press, 2010) 252.

2.2 the statehood spectrum 31
regulate states’ existence or demise’.66 Second, in practice, the question

only arises in ‘borderline cases, where a new entity has emerged bearing
some but not all characteristics of statehood’.67 For this reason, it may be
better to conceive of statehood as a spectrum, consisting of a variety of
entities with more or less legitimate claims. In the following part, we
explore the statehood spectrum with the aim of understanding where and
how micronations may be placed.
2.2 The Statehood Spectrum

The Montevideo Convention reflects an understandable attempt to regu-
late the criteria of statehood and identify the primary subjects of inter-
national law with as much certainty as possible. As we have noted,
however, notwithstanding the existence of a relatively clear set of condi-
tions, determining whether an entity is or is not a state can be more
difficult in practice. Statehood is not a binary yes or no; there are many
shades of grey.
For our purposes, we can usefully conceive of statehood as a spectrum
of entities with a strong claim to statehood through to those with only
a weak claim. This is not to suggest that every territorial entity purporting
to exercise political authority falls somewhere along this range. Some
degree of effective governance, political, legal or historical legitimacy,
and a claim for statehood is a prerequisite. In this part, we develop the
statehood spectrum by examining the status of several state and state-like
entities that satisfy this minimum condition.
2.2.1 Microstates
One entity firmly on the strong claim to statehood end of the spectrum is
the microstate. The Montevideo Convention does not prescribe
a minimum requirement as to territory or population, and a diverse
cast of entities, ‘exceptionally small in area, population and human and
economic resources’68 assert their status as states. In the nineteenth and
twentieth centuries, many political scientists and international relations
66
Matthew Craven and Rose Parfitt, ‘Statehood, Self-Determination and Recognition’ in
Malcolm Evans (ed), International Law (Oxford University Press, 5th ed, 2018).
67
Crawford (n 11) 40.
68
United Nations Secretary-General, Introduction to the Annual Report of the Secretary-
General on the Work of the Organization, 16 June 1966–15 June 1967, UN Doc A/6701/
Add.1 (1967) 20 [163].

32 2 st a t e hoo d a n d mi c r o n a tio n s
scholars considered that the very existence of extremely small states was
precarious,69 predicting that they ‘will fade from international life’, either
swallowed whole by larger powers or compelled to integrate by virtue of
their material handicaps.70 Others considered these entities more akin to
‘pseudo-states’71 with ‘pretensions that far outreached the capacities
normally understood to be those of sovereign statehood’.72
The development of the international principle of self-determination
as well as norms against violating the territorial integrity of states altered
that expected landscape. In fact, in several (though certainly not all) cases,
microstates have prospered and overcome their material disadvantages.
Many microstates ‘profit by selling or renting out their sovereign
prerogatives’,73 including by selling stamps, souvenirs and memorabilia,
and even citizenship,74 diplomatic recognition75 and positions in inter-
national organisations.76 Some, like Luxembourg, Liechtenstein, Malta
and the Bahamas, also ‘serve as off-shore financial centres and tax havens,
free ports, and flags-of-convenience’.77 These nations may be small
relative to their neighbours, but provided they possess formal and actual
independence and exercise political authority over defined territory not
lawfully claimed by another state, they meet international conditions for
statehood.
Echoing earlier debates over the appropriate definition of a ‘state’,
ascertaining precisely what a microstate is has proven challenging.
‘Presumably’, Zbigniew Dumieński notes, ‘microstates are polities dis-
tinctive enough to merit being treated in separation from both “normal”
and “small” states’, but while everyone agrees that a microstate is a ‘very
69
Niels Amstrup, ‘The Perennial Problem of Small States: A Survey of Research Efforts’
(1976) 11 Cooperation and Conflict 163, 163.
70
See, Thomas Grant, ‘Between Diversity and Disorder: A Review of Jorri C. Duursma,
Fragmentation and the International Relations of Micro-States: Self-Determination and
Statehood’ (1997) 12(4) American University Journal of International Law and Policy
629, 630.
71
David Vital, The Inequality of States (Clarendon Press, 1967) 7.
72
John Bartmann, ‘Micro-States in the International System: The Challenge of Sovereignty’
(PhD Thesis, The London School of Economics, 1997) 15.
73
JC Sharman, ‘Sovereignty at the Extremes: Micro-States in World Polities’ (2017) 65(3)
Political Studies 559, 561.
74
Vikram Mansharamani, ‘The $2 Billion Market for Passports’, Fortune Magazine (2 April
2016) http://fortune.com/2016/04/02/passports-citizenship-investment/.
75
Kevin Stringer, ‘Pacific Island Microstates: Pawns or Players in Pacific Rim Diplomacy?’
(2006) 17(3) Diplomacy and Statecraft 547.
76
Abram Chayes and Antonia Handler Chayes, The New Sovereignty: Compliance with
International Regulatory Agreements (Harvard University Press, 1995) 266.
77
Bartmann (n 72) 303.

small state’, ‘there is little consensus’ over what constitutes ‘small size and
which states should be labelled as “small”’.78 The problem is that there are
many ways to measure size, including both quantitative measures such as
‘population, geographical area, economic activity’,79 and military
might,80 and qualitative indicators such as relative power in international
affairs.81 While some scholars have proposed creating a composite index
of these factors and identifying those on the lowest position of the scale as
microstates,82 others have criticised such an approach as ‘too cumber-
some and arbitrary’.83 For this reason, a single variable is more com-
monly adopted, generally either territory or population.
Even this remains problematic. First, there is no agreement on terri-
tory or population thresholds beyond which a state is properly classified
as a microstate. Although a population of ‘one million inhabitants seems
to be the most widely used cut-off point, the literature presents many
alternative propositions ranging from 100,000 to 10 million’.84 The
World Bank’s Small State Forum, for example, has adopted
a population figure of 1.5 million for small states, and 200,000 for
microstates.85 Proposed thresholds can be incredibly specific: one scholar
has nominated a limit of 2,928,000 inhabitants.86 In view of such dis-
agreement, any attempt to draw a clear line or threshold on territory or
population is arbitrary. Second, the difficulty is amplified by the fact that
states with similar territory or populations may otherwise differ radically.
Both Singapore and Tonga, for example, possess around 730 square
kilometres of territory, yet ‘it is difficult to imagine more contrasting
states when it comes to such matters as economic performance, military
78
Dumieński (n 63) 3–4, 8.
79
Edward Warrington, ‘Lilliput Revisited’ (1994) 16(1) Asian Journal of Public
Administration 3, 4.
80
Maurice East, ‘Size and Foreign Policy Behavior: A Test of Two Models’ (1973) 25 World
Politics 556, 557.
81
Matthias Maass, ‘The Elusive Definition of the Small State’ (2009) 46(1) International
Politics 65, 72–3.
82
See, for example, George Reid, Impact of Very Small Size on the International Behaviour of
Microstates (Sage, 1975).
83
Ueantabo Neemia, ‘Smallness, Islandness and Foreign Policy Behaviour: Aspects of Island
Microstates Foreign Policy Behaviour with Special Reference to Cook Islands and
Kiribati’ (PhD Thesis, University of Wollongong, 1995) 14.
84
Dumieński (n 63) 11.
85
The World Bank, ‘The World Bank in Small States: Overview’ www.worldbank.org/en/
country/smallstates/overview.
86
Charles Taylor, ‘Statistical Typology of Micro-States and Territories’ (1969) 8(3) Social
Science Information 101, 109.

34 2 st at eho o d an d mi cronations
strength and international standing’.87 Similarly, Qatar and Namibia

have a similar population, but Namibia is seventy-one times the size of
the Gulf State.
Reflecting on these challenges, Dumieński proposes a definition of
microstates that focuses on ‘their qualitative political uniqueness’.88 He
defines microstates as ‘modern protected states’, that is, ‘sovereign states
that have been able to unilaterally depute certain attributes of sovereignty
to larger powers in exchange for benign protection of their political and
economic viability against their geographic or demographic
constraints’.89 This definition accords with Jorri Duursma’s study on
small European states, and is valuable as it emphasizes microstates’
independence and sovereign status – a key condition of statehood – as
well as their relations with larger neighbours. Critical to this definition is
the fact that, by virtue of their small size, microstates delegate some areas
of governmental competence, often in the areas of defence and inter-
national relations, to larger states. Significantly, such delegation is not
inconsistent with formal and actual independence. Otherwise, the status
of microstates as ‘states’ would be at risk.
Several examples help elucidate this condition. The Principality of
Andorra is a 468-square-kilometre landlocked state situated in the east-
ern Pyrenees between France and Spain.90 Believed to have been estab-
lished by King Charlemagne in 795 CE as a buffer region to protect
against a Moorish invasion of France, Andorra was initially ruled by the
Count of Urgell. Over the following several centuries, ownership of the
valleys was passed between various hands, including the Roman Catholic
Bishop of Urgell, the Lord of Caboet and the Count of Foix. In 1278,
following a dispute between the Count of Foix and the Bishop of Urgell,
the two parties agreed to govern the territory jointly. The practice of
shared sovereignty has continued since, despite dramatic changes in
personal rule. In 1590, the then Count of Foix acceded to the French
throne as Henry IV, and in 1607 the King incorporated his personal
domain in the French Crown. From then, the head of the French state
(along with the Bishop of Urgell) has simultaneously served in his or her
personal capacity as co-Prince of Andorra.
For much of the twentieth century, this peculiar arrangement was at
the centre of debate over whether Andorra was a state. Doubts were
87
Dumieński (n 63) 10.
88
Ibid 22.
89
Ibid.
90
Duursma (n 59) 317–20.

finally displaced in 1993 when Andorra approved a new constitution that

clarified its legal and political structure and signed the Treaty of Vicinage
with France and Spain, which narrowed and defined the scope and extent
of external interference.91 Some complications persist. The Treaty
requires that Andorra act consistently with the ‘fundamental interests’
of France and Spain,92 while those two states and the Holy See maintain
some degree of influence in Andorra through the office of the co-Princes.
Nonetheless, putting any doubt to rest, Andorra was admitted to the
United Nations as a full member in 1993.93
Not all microstates are members of the United Nations. The Cook
Islands is a self-governing entity in the South Pacific Ocean with an
unusual political status. Initially settled by Polynesian societies around
1000 CE, the fifteen islands comprising about 236 square kilometres
became a British protectorate in 1888, were annexed by the United
Kingdom in 1900 and administratively passed to New Zealand (then
a British colony) in 1901.94 The Cook Islands remained a New Zealand
dependency until 1965, when it became a self-governing territory in ‘free
association’ with New Zealand.95 This means that while the Cook Islands
has full autonomy over its internal affairs, New Zealand is responsible for
its defence and may support and assist the Cook Islands to engage in
external affairs.96 Unusually, there is no Cook Island citizenship – all
inhabitants are New Zealand citizens.97
This legal relationship has left the Cook Islands’ international legal
status somewhat unclear. In 2005, for instance, the New Zealand Ministry
of Foreign Affairs and Trade issued a memo declaring that ‘the Cook
91
Crawford (n 11) 76 n 182; Duursma (n 59) 338–48.
92
Treaty of Vicinage, 1993, art 4. Republished in (1994) 98 Revue Générale de Droit
International Public 525.
93
United Nations General Assembly, Admission of the Principality of Andorra to
Membership of the United Nations, UN Doc A/RES/47/232 (28 July 1993).
94
New Zealand Gazette (13 June 1901) 1307.
95
Cook Islands Constitution Act 1964 (NZ); Cook Islands Constitution Amendment Act 1965
(NZ). For discussion see Caroline McDonald, ‘An Exemplary Leader?: New Zealand and
Decolonization of the Cook Islands and Niue’ (2020) 55(3) The Journal of Pacific History
394; Alison Quentin-Baxter, ‘The New Zealand Model of Free Association: What Does It
Mean for New Zealand?’ (2008) 38 Victoria University of Wellington Law Review 607.
96
Cook Islands Constitution Act 1964 (NZ) s 5. For the evolution of these arrangements see
Alison Quentin-Baxter, ‘Pacific States and Territories: Cook Islands’ in Robert Smellie
(ed), The Laws of New Zealand (LexisNexis, 2016) [29].
97
For some of the complications that can arise see discussion in Elisabeth Perham,
‘Citizenship Laws in the Realm of New Zealand’ (2011) 9 New Zealand Yearbook of
International Law 219.

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“I thought you were never coming, doctor. It's such a
responsibility being left with Ina upstairs ill and no one else in the
house. First of all, she was headachy; then she was sick; and her
skin's hot and she looks all flushed. I think she's real ill, doctor.”
“We'll see about it,” Dr. Ringwood assured her. “But first of all, I
have to ring up about another patient. You've a 'phone, of course? It
won't take me a minute; and it's important.”
The maid seemed put out that he did not go straight to his
patient; but she led the way to the cloakroom where the telephone
was fixed. Dr. Ringwood paused before going to the instrument. He
bethought himself of a pretext to get this nervous creature out of
earshot.
“Let's see,” he said. “I may need some boiling water—a small jug
of it. Can you go and put on a kettle now, so that it'll be ready if I
want it?”
The maid went off towards the kitchen, whereupon he closed the
door behind him and rang up. To his relief, Sir Clinton Driffield was at
home; and in less than a couple of minutes Dr. Ringwood was able
to tell his story.
“This is Dr. Ringwood speaking, Sir Clinton. You may remember
me; I'm attending your butler.”
“Nothing wrong in the case, I hope?” the Chief Constable
demanded.
“No, it's not that. I was called here—Heatherfield, 26 Lauderdale
Avenue, this evening. I'm Dr. Carew's locum and a stranger in
Westerhaven; and in this fog I went to the wrong house—the one
next door to here: Ivy Lodge, 28 Lauderdale Avenue. Mr.
Hassendean's house. The place was lit up and a car was at the
door; but I got no answer when I rang the bell. Something roused my
suspicions and I went inside. The house was empty: no maids or
anyone on the premises. In a smoke-room on the ground floor I
found a youngster of about twenty-two or so, dying. He'd been shot
twice in the lung and he died on my hands almost as I went in.”
He paused; but as Sir Clinton made no comment, Dr. Ringwood
continued:
“The house hadn't a telephone. I came in here, after locking the
smoke-room door. I've a patient to see in this house. How long will it
take your people to get to Ivy Lodge and take charge?”
“I'll be over myself in twenty minutes,” Sir Clinton replied.
“Probably the local police will be there about the same time. I'll ring
them up now.”
“Very well. I'll see to my patient here; and then I'll go back to Ivy
Lodge to wait for you. Someone ought to be on the premises in case
the maids or the family come home again.”
“Right. I'll be with you shortly. Good-bye.”
Dr. Ringwood, glancing at his watch, saw that it was twenty
minutes past ten.
“They ought to be here about a quarter to eleven, if they can find
their way in that fog,” he reflected.
Leaving the cloakroom, he made his way to the nearest sitting-
room and rang the bell for the maid.
“The water will be boiling in a minute or two, doctor,” she
announced, coming from the back premises. “Will you need it before
you go up to see Ina, or shall I bring it up to you?”
“I may not need it at all. Show me the way, please.”
She led him up to the patient's room and waited while he made
his examination.
“What is it, doctor?” she demanded when he came out again.
“She's got scarlatina, I'm afraid. Rather a bad attack. She ought
to be taken to hospital now, but on a night like this I doubt if the
hospital van could get here easily. Have you had scarlet yourself, by
any chance?”
“Yes, doctor. I had it when I was a child.”
Dr. Ringwood nodded, as though contented by the information.
“Then you don't run much risk of taking it from her. That simplifies
things. I'd rather not shift her to-night, just in case the van lost its
way. But if you can look after her for a few hours, it will be all right.”
The maid did not seem altogether overjoyed at this suggestion.
Dr. Ringwood sought for some way out of the difficulty.
“There's nobody at home to-night, is there?”
“No, sir. Mr. Silverdale hasn't been home since lunch-time, and
Mrs. Silverdale went out immediately after dinner.”
“When will she be back?”
“Not till late, sir, I expect. Young Mr. Hassendean came to dinner,
and they went off in his car. I expect they've gone to the Alhambra to
dance, sir.”
Dr. Ringwood repressed his involuntary movement at the name
Hassendean.
“When in doubt, play the medicine-man card,” he concluded
swiftly in his mind, without betraying anything outwardly. It seemed
possible that he might get some evidence out of the maid before she
became confused by any police visit. He assumed an air of doubt as
he turned again to the woman.
“Did Mrs. Silverdale come much in contact with the housemaid
during the day?”
“No, sir. Hardly at all.”
“H'm! When did Mrs. Silverdale have dinner?”
“At half-past seven, sir.”
“Was this Mr. Hassendean here long before dinner?”
“No, sir. He came in a few minutes before the half-hour.”
“Where were they before dinner?”
“In the drawing-room, sir.”
“The maid had been in that room during the day, I suppose?”
“Only just doing some dusting, sir. She had been complaining of
a sore throat and being out of sorts, and she didn't do anything she
could avoid bothering with.”
Dr. Ringwood shook his head as though he were not very easy in
his mind.
“Then Mrs. Silverdale and Mr. Hassendean went in to dinner? Did
the housemaid wait at dinner?”
“No, sir. By that time she was feeling very bad, so I sent her to
bed and looked after the dinner myself.”
“She hadn't touched the dishes, or anything of that sort?”
“No, sir.”
“And immediately after dinner, Mrs. Silverdale and Mr.
Hassendean went out?”
The maid hesitated for a moment.
“Yes, sir. At least——”
Dr. Ringwood made his face grave.
“Tell me exactly what happened. One never can tell with these
scarlet cases.”
“Well, sir, I was just going to bring in coffee when Mr.
Hassendean said: ‘Let's have our coffee in the drawing-room,
Yvonne. This room's a bit cold.’ Or something like that. I remember
he didn't want the coffee in the dining-room, at any rate. So I went to
get it; and when I came back with it they were sitting beside the fire
in the drawing-room. I was going to take the tray over to them, when
Mr. Hassendean said: ‘Put it down on the table over there.’ So I put it
down and went away to clear the dining-room table.”
“And the housemaid had dusted the drawing-room this morning,”
Dr. Ringwood said thoughtfully. “Mr. Hassendean wasn't long in the
drawing-room after dinner, was he?”
“No, sir. They didn't take very long over their coffee.”
Dr. Ringwood looked judicial and seemed to consider some
abstruse point before speaking again.
“Mrs. Silverdale didn't look ill during the day, did she?”
“No, sir. But now you mention it, I did think she seemed rather
strange just before she went out.”
“Indeed? I was afraid of something of the sort. What do you
mean, exactly?” Dr. Ringwood demanded, concealing his interest as
well as he could.
“Well, sir, it's hard to say exactly. She came out of the drawing-
room and went upstairs to get her cloak; and as she came down
again, I passed her in the hall, taking some dishes to the kitchen.
She seemed dazed-like, now you mention it.”
“Dazed?”
“Funny sort of look in her eyes, sir. I can't describe it well.
Seemed as if she wasn't taking notice of me as I passed.”
Dr. Ringwood's face showed an increase in gravity.
“I'm afraid Mrs. Silverdale may have got infected too. What about
Mr. Hassendean?”
The maid considered for a moment before answering.
“I didn't notice anything strange about Mr. Hassendean, sir.
Unless, perhaps, he did seem a bit nervous—high-strung like, I
thought. But I'd never have paid attention to it if you hadn't asked me
the question.”
Dr. Ringwood made a gesture of approval, inwardly thanking his
stars for the lay public's ignorance of diseases.
“And then they went off together?”
“Yes, sir. Mr. Hassendean took the cloak from Mrs. Silverdale and
put it over her shoulders. Then he took her arm and they went out to
his car. It was waiting in front of the door.”
“H'm! I suppose the housemaid hadn't touched the cloak to-day?”
“Oh, no, sir. She'd been in Mrs. Silverdale's room, of course; but
she wouldn't have any reason to go near the cloak.”
Dr. Ringwood feigned a difficulty in recollection.
“Hassendean! I surely know him. Isn't he about my height, fair,
with a small moustache?”
“Yes, sir. That's him.”
Dr. Ringwood had confirmed his guess. It was young
Hassendean's body that lay next door.
“Let's see,” he said. “I may have to come back here in an hour or
so. I'd like to have another look at my patient upstairs. Will Mrs.
Silverdale be back by that time, do you think?”
“That would be about half-past eleven, sir? No, I don't think she'd
be back as soon as that. She's usually out until after midnight, most
nights.”
“Well, you might sit up and wait for me, please. Go to bed if I'm
not here by twelve. But—— No, if you can manage it, I think you
ought to keep awake till Mrs. Silverdale comes home. That patient
shouldn't be left with no one to look after her. I'm just afraid she may
get a little light-headed in the night. It's hard lines on you; but you
must do your best for her.”
“Very well, sir, if you say so.”
“Perhaps Mr. Silverdale will turn up. Is he usually late?”
“One never can tell with him, sir. Some days he comes home to
dinner and works late in his study. Other times he's out of the house
from breakfast-time and doesn't get back till all hours. He might be
here in five minutes now, or he mightn't come home till two in the
morning.”
Dr. Ringwood felt that he had extracted all the information he
could reasonable expect to get. He gave the maid some directions
as to what she should do in possible emergencies; then, glancing at
his watch, he took his departure.
As he went down the steps of the house, he found no signs of the
fog lifting; and he had to exercise as much care as ever in making
his way through it. He was not unsatisfied with the results of his
interrogation. Young Hassendean had met Silverdale's wife by
appointment, evidently. They had dined together; and then they had
gone away in the fog. Clearly enough, from what the maid said, both
of them were in a somewhat abnormal state when they left the
house. ‘Dazed-like,’ ‘a bit nervous—high strung.’ He recalled the
expressions with a faint annoyance at the vagueness of the
descriptions.
It seemed quite likely that, instead of going to a dance-hall, they
had simply driven round to Ivy Lodge, which young Hassendean
must have known to be empty at that time. And there, something had
happened. The girl had gone away or been taken away, and the
youngster had been left to die. But where had Yvonne Silverdale
gone?
Dr. Ringwood opened the door of Ivy Lodge and took the key of
the smoke-room from his pocket. The house was silent as when he
left it. Evidently no one had come home.
Chapter III.
Sir Clinton at Ivy Lodge
Dr. Ringwood left the smoke-room door open to ensure that he
would hear anyone who entered the house. He made a second
cursory inspection of young Hassendean's body; but as he took care
not to alter the position of anything, he discovered no more than he
had done when he inspected it originally. There seemed to be
nothing further for him to do until the police came upon the scene; so
he picked out a comfortable chair and let himself relax whilst he had
the chance.
The patient next door worried him a little. Perhaps he ought to
have got the girl off to hospital at once, fog or no fog. It would be
awkward if she turned delirious in the night. And from that, his mind
drifted to other cases which were giving him anxiety. With this 'flu
epidemic, Carew's practice had been anything but the nice, quiet,
jog-trot business he had imagined it to be when he promised to
come as locum.
By some incongruous linking, his thoughts came back to the
events through which he had just passed. Death was all in the day's
work for a medical man, but he had hardly bargained for murder. At
least, he had hitherto assumed that this was a case of murder, but
possibly it was suicide. He recalled that he had not seen any pistol;
and he felt a momentary inclination to search the room for the
weapon; but his fatigue was greater than his interest, and he
abandoned the project. After all, it was an affair for the police, when
they came to take charge; it was no business of his.
Nevertheless, he could not shake off the subject of the tragedy;
and, despite himself, he began to speculate on the possibilities of the
situation. Suppose that, after dinner, young Hassendean and Mrs.
Silverdale had simply driven round to Ivy Lodge. That would account
for the empty car at the door. Then they must have come into the
house. He had found the door unlocked, so that anyone could enter.
That seemed rather a peculiar point. Surely, if they had come here
for the only purpose which seemed covered by the case, they would
have taken the obvious precaution of closing the front door against
intruders. But if they had done that, how could Silverdale have got
in? He could hardly have had a latch-key for his neighbours’ house.
It occurred to Dr. Ringwood that possibly Silverdale might have
gained admittance through some unlatched window. He might have
seen something through the smoke-room window and got into the
house like a burglar. But all the curtains were tightly drawn. No one
could see in from the outside, even if they had wished to do so.
Obviously, then, it could not have been a chance discovery of his
wife's guilt that had roused Silverdale to the pitch of murder. He must
have had his suspicions and deliberately tracked down the guilty
couple.
Almost against his will, Dr. Ringwood's mind persisted in an
attempt to reconstruct the happenings of the night. Suppose
Silverdale got in—no matter how—then evidently he must have
surprised the two; and the end of that business had been the
shooting of young Hassendean. But that left Yvonne Silverdale and
her husband still unaccounted for. Had she fled into the night before
Silverdale could shoot her in her turn. Or had her husband forced her
to go with him—whither? And if this were the truth of the matter, why
had Silverdale not locked the door? There seemed to be many
things needing explanation before one could feel that the case was
clear. Well, that was the business of the police.
His train of thought was suddenly interrupted by the sound of feet
at the front door, and he pulled himself together with a start and rose
from his chair. He was just moving towards the door when it opened
and Sir Clinton Driffield, accompanied by another man, entered the
room.
“Good evening, Dr. Ringwood,” the Chief Constable greeted him.
“I think we've managed to get here at the time I promised, though it
was a difficult business with all this fog about.”
He turned to introduce his companion.
“This is Inspector Flamborough, doctor. He's in charge of the
case. I'm merely here as an onlooker. I've given him the facts, so far
as I know them from you; but I expect that he may wish further
information if you have any.”
At Sir Clinton's words, the mouth under Inspector Flamborough's
tooth-brush moustache curved in a smile, half-friendly and half-
inscrutable. Simultaneously, he seemed to be establishing good
relations with the doctor and appreciating some obscure joke in the
Chief Constable's remarks.
“It's very lucky you're a medical man, sir. Death's all in the day's
work with you and me; neither of us is likely to be put off our balance
by it. Most witnesses in cases of this sort get so confused by the
shock that it's difficult to squeeze any clear story out of them. A
doctor's different.”
Dr. Ringwood was not particularly susceptible to flattery, but he
recognised that the Inspector probably was voicing his real
sentiments. All three of them were experts in death, and among
them there was no need to waste time in polite lamentations. None
of them had ever set eyes on the victim before that night, and there
was no object in becoming sentimental over him.
“Sit down, doctor,” Sir Clinton broke in, after a glance at the
medical man's face. “You look as if you were about tired out. This 'flu
epidemic must be taking it out of you.”
Dr. Ringwood did not wait to be asked twice. Sir Clinton followed
his example, but the Inspector, pulling a notebook from his pocket,
prepared to open his investigation.
“Let's see, now, doctor,” he began pleasantly. “I'd like to start from
the beginning. You might tell us just how you happened to come into
the business; and if you can give us some definite times, it'll be a
great help.”
Dr. Ringwood nodded, but seemed to hesitate for a moment
before replying:
“I think I could give you it clearest if I were sure of one thing first. I
believe that's the body of young Hassendean who lived in this
house, but I haven't examined it closely—didn't wish to disturb it in
any way before you turned up. If it is young Hassendean's body, then
I can fit some other things into my evidence. Perhaps you'll have a
look for yourselves and see if you can identify him.”
The Inspector exchanged a glance with his superior.
“Just as you please, sir,” he answered.
He crossed the room, knelt beside the chesterfield, and began to
search the pockets in the body's clothes. The first two yielded
nothing in the way of identification, but from one of the pockets of the
evening waistcoat the Inspector fished out a small card.
“Season ticket for the Alhambra,” he reported, after glancing over
it. “You're right, doctor. The signature's here: Ronald Hassendean.”
“I was pretty sure of it,” Dr. Ringwood answered. “But I like to be
certain.”
The Inspector rose to his feet and came back to the hearthrug.
“Now, perhaps, sir, you'll tell us the story in your own way. Only
let's have it clear. I mean, tell us what you saw yourself and let's
know when you're bringing anything else in.”
Dr. Ringwood had a clear mind and could put his facts together in
proper order. In spite of his physical weariness, he was able to take
each incident of the evening in its proper turn and make it fit neatly
into its place in his narrative. When he had finished, he had brought
the story up to the point when the police arrived. As he closed his
tale, the Inspector shut his notebook with a nod of approval.
“There's a lot of useful information there, doctor. We're lucky in
having your help. Some of what you've told us would have cost a lot
of bother to fish out of different people.”
Sir Clinton rose to his feet with a gesture which invited the doctor
to remain in his chair.
“Of course, doctor,” he pointed out, “a good deal of your story is
like What the Soldier Said—it isn't first-hand evidence. We'll have to
get it for ourselves, again, from the people who gave it to you: Dr.
Markfield and this maid next door. That's only routine; and doesn't
imply that we disbelieve it in the slightest, naturally.”
Dr. Ringwood agreed with a faint smile.
“I prefer getting a patient's symptoms at first-hand myself,” he
said. “Things do get distorted a bit in the re-telling. And some of what
I gave you is quite possibly just gossip. I thought you ought to hear it;
but most certainly I don't guarantee its accuracy.”
The Inspector beamed his approval of the doctor's views.
“And now, sir,” he said, glancing at Sir Clinton, “I think I'd better
go over the ground here and see if there's anything worth picking
up.”
He suited the action to the word, and began a systematic search
of the room, commenting aloud from time to time for his companions’
benefit.
“There's no pistol here, unless it's hidden away somewhere,” he
reported after a while. “The murderer must have taken it away with
him.”
Sir Clinton's face took on a quizzical expression.
“Just one suggestion, Inspector. Let's keep the facts and the
inferences in separate boxes, if you please. What we really do know
is that you haven't found any pistol up to the present.”
Flamborough's grin showed that the Chief Constable's shot had
gone home without wounding his feelings.
“Very good, sir. ‘Pistol or pistols, not found.’ I'll note that down.”
He went down on hands and knees to examine the carpet.
“Here's something fresh, sir,” he announced. “The carpet's so
dark that I didn't notice it before. The pattern concealed it, too. But
here it is, all right.”
He drew his fore-finger over the fabric at a spot near the door,
and then held it for their inspection, stained with an ominous red.
“A blood-spot, and a fair-sized one, too! There may be more of
them about.”
“Yes,” said Sir Clinton mildly. “I noticed some on the hall-carpet
as I came in. There's a trail of them from the front door into this
room. Perhaps you didn't see them; they're not conspicuous.”
The Inspector looked a trifle crestfallen.
“I know you've a sharp eye, sir. I didn't spot them myself.”
“Suppose we finish up this room before going elsewhere. All the
windows are fast, are they?” the Chief Constable asked.
Flamborough examined them and reported that all the catches
were on. Then he gazed up and down the room inquisitively.
“Looking for bullet-holes?” Sir Clinton questioned. “Quite right.
But you won't find any.”
“I like to be certain about things, sir.”
“So do I, Inspector. So does Dr. Ringwood, if you remember.
Well, you can be certain of one thing. If two shots had been fired in
here this evening, and if all the windows had been left closed as they
are now, then I'd have smelt the tang of the powder in the air when
we came in. I didn't. Ergo, no shots were fired in this room. Whence
it follows that it's no use hunting for bullet-holes. Does that chain of
reasoning satisfy you, Inspector?”
Flamborough made a gesture of vexation.
“That's true enough,” he confessed. “I ought to have thought of
it.”
“I think we've got the main points, now, so far as this room itself
goes,” Sir Clinton observed, without paying any heed to the
Inspector's annoyance. “Would you mind examining the body, doctor,
just to confirm your view that he was shot in the lung?”
Dr. Ringwood assented and, crossing over, he subjected young
Hassendean's body to a careful scrutiny. A few minutes sufficed to
prove that the only wounds were those in the chest; and when the
doctor had satisfied himself that his earlier diagnosis was correct, he
turned to the Chief Constable.
“There's no certainty without a P.M., of course, but from the way
the bullets have gone in, it's pretty obvious that the shots took effect
on the left lung. There's very little external bleeding, apparently; and
that rather looks as if one of the intercostal arteries may be involved.
He must have bled a lot internally, I suspect. Probably the P.M. will
confirm that.”
Sir Clinton accepted the verdict without demur.
“And what do you make out of things, Inspector?” he demanded,
turning to Flamborough.
“Well, sir, with these small-calibre pistols, it's difficult to give more
than a guess. So far as I can see, it looks as if the pistol had been
quite close-up when it was fired. I think I can see something that
looks like scorching or discoloration on his dress shirt round about
the wound, though the blood makes it hard to be sure. That's really
as far as I'd like to go until I've had a better chance of examining the
thing.”
Sir Clinton turned back to the doctor.
“I suppose a wound in the lung may produce death at almost any
length of time after the shot's actually fired. I mean that a man may
live for quite a long while even with a wound like this and might be
able to move about to some extent after being shot?”
Dr. Ringwood had no hesitation in agreeing with this.
“He might have lived for an hour or two—even for days. Or else,
of course, he might have collapsed almost at once. You never can
tell what will happen in lung wounds.”
Sir Clinton seemed to give this a certain consideration. Then he
moved towards the door.
“We'll take up the blood-trail now. You'd better switch off the light
and lock the door, Inspector. We don't want anyone blundering in
here and getting a fright by any mischance.”
They went out into the hall, where Sir Clinton drew the attention
of the Inspector to the traces of blood which he had noticed on the
carpet.
“Now we'd better have a look at that car outside,” he suggested.
As they descended the steps from the front door, the Inspector
took a flash-lamp from his pocket and switched it on. Its rays merely
served to light up the fog; and it was not until they came almost to
the side of the car that they could see much. The Inspector bent
across, rubbed his finger over the driving-seat, and then examined
his hand in the light of the lamp.
“Some more blood there, sir,” he reported.
He cleaned away the marks on his finger-tip and proceeded to
explore the other seats in the same manner. The results were
negative. Apart from one or two spots on the running-board at the
driving-seat door, the car seemed otherwise clean. Inspector
Flamborough straightened himself up and turned to Sir Clinton.
“It seems that he must have driven the car back himself, sir. If
someone else had done the driving, the blood would have been on
some of the other seats instead of this one.”
Sir Clinton acquiesced with a gesture.
“I suppose that's possible, doctor? A wound in the lung wouldn't
incapacitate him completely?”
Dr. Ringwood shook his head.
“It would depend entirely on the sort of wound it was. I see
nothing against it, prima facie. Driving a car isn't really much strain
on the body muscles.”
Sir Clinton ran his eye over the lines of the car in the light of the
side-lamps.
“It's an Austin, so he'd be able to get the engine going with the
self-starter, probably, even on a night like this. He wouldn't need to
crank up the car. There would be no exertion on his part.”
The Inspector had been examining the ground.
“It's frozen fairly hard,” he reported. “There's no hope of tracing
the car's track on a night like this, even if one could have done that
through all the marks of the town traffic. That's a blank end.”
“You may as well take the number, Inspector. It's just possible
that some constable may have noticed it, though the chances are
about a thousand to one against that, on a night of this sort.”
Flamborough went round to the rear number-plate and jotted
down the figures in his pocket-book, repeating them aloud as he did
so:
“GX.6061.”
He came round the car again and subjected the whole interior to
a minute scrutiny under the light of his flashlamp.
“Here's a girl's handkerchief lying on the floor,” he said, as he
peered down at the place beside the driver. Then, holding it in the
light from the side-lamp, he turned it over and reported.
“It's got ‘Y.S.’ embroidered in one corner. That would be for
Yvonne Silverdale, I suppose. It doesn't take us much further. Except
that it proves this was the car she went off in with young
Hassendean, and I expect we could have got better proof of that
elsewhere.”
“Nothing else you can find?” Sir Clinton inquired.
“No, sir.”
Before the Chief Constable could say anything further, two
figures loomed up through the fog and a startled exclamation in a
female voice reached the group around the car. Sir Clinton caught
Dr. Ringwood's arm and whispered hurriedly in his ear:
“The maids coming back to the house. Spin them a yarn that
young Hassendean's met with an accident and been brought home.
Tell them who you are. We don't want to have them in hysterics.”
Dr. Ringwood moved towards the dim figures in the fog.
“I'm Dr. Ringwood,” he explained. “I suppose you're the maids,
aren't you? You must go in very quietly. Young Mr. Hassendean's
had a bad accident and mustn't be disturbed. He's in the room to the
right as you go in at the door, so don't make a fuss in the house.
You'd better get off to bed.”
There was a sound of rapid whispering and then one of the maids
enquired:
“Was it a motor accident, sir?”
Dr. Ringwood, anxious not to commit himself to details, made a
gesture to the window behind him.
“Don't make a row, please. Mr. Hassendean mustn't be disturbed
in any way. Get off to bed as soon as you can, and keep quiet. By
the way, when do you expect the rest of the family home?”
“They've gone out to play bridge, sir,” answered the maid who
had spoken before. “Usually they get home about half-past eleven.”
“Good. I shall have to wait for them.”
The bolder of the two maids had advanced as he was speaking,
and now she stared suspiciously at him in the dim light from the car
lamps.
“Excuse me, sir,” she ventured. “How do I know that it's all right?”
“You mean I might be a burglar, I suppose?” Dr. Ringwood
answered patiently. “Well, here's Inspector Flamborough. He's surely
protection enough for you.”
The maid examined Flamborough with relief.
“Oh, that's all right, sir. I saw Inspector Flamborough once at the
police sports. That's him, right enough. I'm sorry to have been a bit
suspicious, sir——”
“Quite right,” Dr. Ringwood reassured her. “Now, just get off to
bed, will you. We've got the patient to think about.”
“Is it a bad accident, sir?”
“Very serious, perhaps. Talking won't mend it, anyhow.”
Dr. Ringwood's temper was becoming slightly frayed by the
maid's persistence. However, she took the hint and retired with her
companion into the house. Inspector Flamborough made a gesture
which arrested them at the door.
“By the way, when did young Mr. Hassendean leave the house
to-night?” he demanded.
“I couldn't say, sir. We left ourselves at seven o’clock. Mr.
Hassendean and Miss Hassendean were just going out then—they
were dining out. And Mr. Ronald was dressing, I think. He was going
out to dinner, too.”
Flamborough dismissed them, and they vanished into the hall. Sir
Clinton gave them a reasonable time to get out of the way before
making any further move. The Inspector occupied himself with
writing a note in his pocket-book.
“I think we may as well go into the house again,” the Chief
Constable suggested. “Just fasten that front door after us, Inspector,
if you please. We may as well have some warning when the family
turns up.”
He led the way up the steps, entered the hall, and, after opening
one or two doors at random, selected the drawing-room of the
house, in which a banked-up fire was burning.
“We may as well wait here. It's to be hoped they won't be long,
now. Sit down, doctor.”
Then, noticing the expression on Dr. Ringwood's face, he
continued:
“I'm sorry to detain you, doctor; but now we've got you, I think
we'll have to keep you until the Hassendeans come in. One never
knows what may turn up. They may have something to tell us which
might need medical checking and you've been too much of a gift
from the gods to part with so long as there's a chance of our utilising
you.”
Dr. Ringwood tried to make his acquiescence a cheerful one,
though he was thinking regretfully of his bed.
“It's all in the day's work,” he said. “I'm only a bit worried about
that case of scarlet next door. I'll have to look in there before I go.”
“So shall we,” Sir Clinton explained. “Once we've got all the
evidence from the family, we'll need to ring up and get the body
taken off to the mortuary. You say we can telephone from the house
next door?”
“Yes. I had to go there to ring you up myself. The Hassendeans
have no 'phone.”
“We'll go round with you then. . . . H'm! There's the door-bell,
Inspector. You'd better attend to it. Bring them in here, please.”
Flamborough hurried out of the room; they heard some muffled
talk broken by ejaculations of surprise and horror; and then the
Inspector ushered Mr. and Miss Hassendean into the drawing-room.
Dr. Ringwood was unfavourably impressed at the first glance. Mr.
Hassendean was a red-faced, white-haired man of about seventy,
with a feebly blustering manner. His sister, some five years younger,
aped the air and dress of women twenty years her junior.
“What this? What's this, eh?” Mr. Hassendean demanded as he
came into the room. “God bless my soul! My nephew shot? What
does it mean, eh?”
“That's what we should like to know, sir,” Inspector
Flamborough's quiet voice cut into the frothing torrent of the old
man's eloquence. “We're depending on you to throw some light on
the affair.”
“On me?” Mr. Hassendean's voice seemed to strain itself in the
vain attempt to express his feelings at the Inspector's suggestion.
“I'm not a policeman, my good fellow; I'm a retired drysalter. God
bless me! Do I look like Sherlock Holmes?”
He paused, apparently unable to find words for a moment.
“Now, look here, my good man,” he went on, “I come home and I
find you occupying my house, and you tell me that my young
nephew has been shot. He's a good-for-nothing cub, I admit; but
that's beside the point. I want to know who's to blame for it. That's a
simple enough question, surely. And instead of answering it, you
have the nerve to ask me to do your work for you! What do we pay
police rates for, tell me that! And who are these men in my drawing-
room? How did they come here?”
“This is Sir Clinton Driffield; this is Dr. Ringwood,” the Inspector
answered smoothly, taking no notice of Mr. Hassendean's other
remarks.
“Ah! I've heard of you, Sir Clinton,” Mr. Hassendean
acknowledged, less ungraciously. “Well, what about it?”
“We've met under rather unfortunate conditions, Mr.
Hassendean,” Sir Clinton admitted soothingly, “but they're none of
our choosing, you know. I quite understand your feelings; it must be
a bad shock to come home to an affair like this. But I hope you'll see
your way to give us any information you have—anything that will
assist us to get on the track of the person who shot your nephew.
We really depend on you to help us at once, for every hour lost may
make it more difficult to lay our hands on the criminal. Without
knowing it, you may have the key to the thing in your hands.”
More by his manner than by his words, the Chief Constable had
succeeded in pacifying the old man.
“Well, if it's put like that, I don't mind,” he conceded, with a slight
lessening in the asperity of his tone. “Ask your questions and I'll see
what I can do for you.”
Dr. Ringwood, watching the change in the situation, reflected
sardonically to himself that a title had its uses when one came to
deal with a snob.
“That old bounder was rude to the Inspector on principle; but
when Sir Clinton Driffield asks precisely the same question, he's
quite amenable,” he thought to himself. “What a type!”
The Chief Constable, when he began his interrogatory, was
careful not to betray that he already had some information.
“Perhaps we'd better begin at the beginning, Mr. Hassendean,”
he suggested, with the air of one consulting a valued collaborator.
“Could you throw any light on your nephew's arrangements for this
evening? Did he mean to stay in the house, or had he any outside
engagement that you knew about?”
“He told me he was going out to dinner with that hussy next
door.”
Sir Clinton's smile further disarmed old Hassendean.
“I'm afraid you'll need to be more definite. There are so many
hussies nowadays.”
“You're right there, sir! You're right there. I agree with you. I'm
speaking of the French one next door, her name's Silverdale. My
nephew was always hanging round her skirts, sir. I warned him
against her, often enough.”
“I always knew something would happen!” Miss Hassendean
declared with the air of a justified Cassandra. “And now it has
happened.”
Sir Clinton returned to the main track.
“Have you any idea if he meant to spend the evening next door?”
Miss Hassendean interrupted before her brother could reply.
“He mentioned to me that he was going with her to the Alhambra
to dance. I remember that, because he actually asked me where I
was going myself to-night, which was unusual interest on his part.”
“Scattering his money, of course!” her brother rapped out angrily.
“He had money to scatter, then?” Sir Clinton asked casually. “He
must have been lucky for his age.”
For some reason, this reflection seemed to stir a grievance in the
old man's mind.
“Yes, he had about £500 a year of his own. A very comfortable
income for a single young man. And I had to sit, sir, as his trustee;
pay over the money quarterly to him; and see it wasted in buying
jewellery and whatnot for that wench next door. I'm not a rich man,
sir; and I give you my word I could have spent it better myself. But I'd
no control over him, none whatever. I had to stand by and see all
that good money flung into the gutter.”
Dr. Ringwood turned aside to hide his smile at this revelation of
the drysalter's soul.
“By the way, who gets that money now?” Sir Clinton inquired.
“I do, sir. And I hope I'll put it to better use.”
Sir Clinton nodded in response to this sentiment, and seemed to
ponder before he asked his next question.
“I suppose you can't think of anyone who might have had a
grudge against him?”
The old man's glance showed some suspicion at the question;
but his sister seemed to have less compunction, for she answered
instead.
“I warned Ronald again and again that he was playing with fire.
Mr. Silverdale never took any open offence, but . . .”
She left her sentence unfinished. Sir Clinton seemed less
impressed than she had expected. He made no comment on her
statement.
“Then I take it, Mr. Hassendean, that you can throw no light on
the affair, beyond what you have told us?”
The old man seemed to think that he had given quite enough
information, for he merely answered with a non-committal gesture.
“I must thank you for your assistance,” Sir Clinton pursued. “You
understand, of course, that there are one or two formalities which
need to be gone through. The body will have to be removed for a
post mortem examination, I'm afraid; and Inspector Flamborough will
need to go through your nephew's papers to see if anything in them
throws light on this affair. He can do that now, if you have no
objections.”
Old Hassendean seemed rather taken back by this.
“Is that necessary?”
“I'm afraid so.”
The old man's face bore all the marks of uneasiness at this
decision.
“I'd rather avoid it if possible,” he grumbled. “It's not for use in
Court, is it? I shouldn't like that, not by any means. To tell you the
truth, sir,” he continued in a burst of frankness, “we didn't get on well,
he and I; and it's quite on the cards that he may have said—written, I
mean—a lot of things about me that I shouldn't care to have printed
in the newspapers. He was a miserable young creature, and I never
concealed my opinion about him. Under his father's will, he had to
live in my house till he was twenty-five, and a pretty life he led me,
sir. I suspect that he may have slandered me in that diary he used to
keep.”
“You'd better make a note about that diary, Inspector,” Sir Clinton
suggested in a tone which seemed to indicate that Flamborough
must be discreet. “You needn't trouble yourself too much about it, Mr.
Hassendean. Nothing in it will come out in public unless it bears
directly on this case; I can assure you of that.”
The drysalter recognised that this was final; but he could hardly
be described as giving in with a good grace.
“Have it your own way,” he grunted crossly.
Sir Clinton ignored this recrudescence of temper.
“I'll leave the Inspector to see to things,” he explained. “I'll go with
Dr. Ringwood, Inspector, and do the telephoning. You'd better stay
here, of course, until someone relieves you. You'll find plenty to do, I
expect.”
He bade good-night to his involuntary host and hostess and,
followed by the doctor, left the house.

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