International Judicial Monitor
Published by the International Judicial Academy, Washington, D.C., with assistance from the
American Society of International Law

Summer 2013 Issue

Historic Moments in International Law


An “Unrelieved Record of Misery and Misgovernment”: Liberia and the League of Nations

Stephen C. NeffBy: Stephen C. Neff, Reader in Law – Public International Law, University of Edinburgh Law School

Readers may be forgiven for supposing that the era of international human rights law commenced in 1948, with the modest fanfare accompanying the Universal Declaration of Human Rights.  Less well remembered, however, is that the League of Nations Covenant had included some potentially important human-rights provisions. These were found in Article 23, in which member states promised that they would “endeavour” to provide “fair and humane conditions of labour,” and that they would also “secure just treatment of the native inhabitants” of territories under their control.

On one occasion – but only one – the machinery of the League of Nations was invoked against allegations of serious violations of these undertakings.  This was the case of Liberia – a case that can hardly be said to have been forgotten, as it has scarcely been remembered to begin with. A modest correction of that state of ignorance is thought to be in order.

The League’s concern over Liberia arose out of a spate of reports in the late 1920s about the use of forced labor in the country. Most especially, it was alleged that the Liberia Frontier Force was actively involved in the dragooning of laborers to work on the plantations of the Firestone Plantations Company, which was a major American-owned rubber producer, as well as in other parts of Africa (notably Fernando Po and Gabon). These reports led to the establishment, by the League of Nations, of a three-member investigatory commission.

The commission’s leading member was a British figure, Cuthbert Christy, whose life reads like something out of a novel by Rider Haggard or Rudyard Kipling. He was a scientist-explorer in the larger-than-life Victorian manner, with extensive experience in African exploration. He had also been active in the combatting of trypanosomiasis (sleeping sickness, to the unlettered). Also on the commission was an American sociologist, Charles S. Johnson.  The third member was a Liberian – but not just any Liberian. He was Arthur Barclay, a former president of the country – and also father-in-law of the then-current president, and (for good measure) the uncle of a future president. Because of age and infirmity, Barclay did not participate in investigations conducted outside the capital of Monrovia.

Relations between Christy and Johnson proved tense. Most importantly, they had different views over what practices actually amounted to slavery. Johnson grumbled that Christy was far too ready to employ the “s-word” where it was not appropriate. In the event, though, a report was agreed and presented to the League in December, 1930.  It confirmed the presence of practices that amounted to slavery within the definition of the international convention of 1926 on slavery (to which Liberia was not a party). The sending of Liberian laborers to other parts of Africa, in particular, was stated to be occurring under “conditions of criminal compulsion scarcely distinguishable from slave raiding and slave trading.” The Liberian Frontier Force was expressly found to have participated in these practices. The Firestone Company was exonerated of participation, although it was noted that it may have employed laborers who had been obtained by force. The government of Liberia, as well as “leading citizens,” were also absolved of wrongdoing.


For a while, it looked as if some very significant remedial action was going to be taken – regarding not merely labor recruitment but also the reorganization of the Liberian state generally. Pursuant to the Liberian government’s request for assistance, the League established a Liberian Committee in 1931, which included representation by the United States (not, of course, a League member). This committee dispatched another commission to the country to investigate economic, health, and labor conditions generally. It reported its findings in September 1931. After arduous discussions, plans emerged for a large-scale reorganization of Liberian public life, to be financed by a substantial foreign loan and overseen by either a League of Nations official or an American commissioner with substantial powers. It soon became clear, however, that the Liberian government would not approve of such far-reaching encroachments upon its sovereign rights. In this, it had the support of black groups in the United States, such as the NAACP.

In the meantime, further dark allegations were being voiced about atrocities by the Frontier Force. Reports came in of atrocities by the Force against rebellious tribal groups, most notably the Kru. To investigate these latest allegations, a British doctor named Melville Mackenzie was dispatched to the country in 1933.  (The redoubtable Cuthbert Christy was no longer available for service, as he had been fatally gored by a buffalo in the Belgian Congo the previous year.) Mackenzie managed to arrange a one-year truce between the Frontier Force and the Kru people, which included prohibitions against reprisals for past actions.  Unfortunately, the expiry of the truce, in July 1933, brought further outbreaks of fighting, although the Monrovia government heatedly denied stories of atrocities by the Frontier Force.

In the end, there was pitifully little to show for the League’s efforts. Liberian government opposition prevented the League’s reorganization program from being implemented.  Matters came to a final, dispiriting conclusion at a meeting of the League Council in May 1934.  In attendance was British foreign minister Anthony Eden, who spoke at great length, and with blunt disapproval, about the Liberian situation. He pointed to the country’s “unrelieved record of misery and misgovernment,” forthrightly accusing Liberia of gross violation of Article 23 of the League Covenant. He went on to state explicitly that these violations would justify the League in expelling Liberia from the organization.

The reference to possible expulsion from the League seems to have administered at least a mild jolt to the Liberian delegate, who responded, rather vaguely, that his country “would make such arrangements as circumstances required to prevent expulsion.” In reality, expulsion was regarded as an unrealistic outcome.  It would require a unanimous vote of the other League members, which in all likelihood could not be obtained.  So that particular path was not seriously pursued.

Readers who wish for more detail on this early foray of international organisations into the delicate art of human-rights promotion may usefully consult Ibrahim Sundiata, Brothers and Strangers: Black Zion, Black Slavery, 1914-1940 (Duke University Press, 2003), which has a wealth of material on the political context of the affair, including significant attention to the United States’s involvement. A brief account of the League’s involvement may be found in F. P. Walters, A History of the League of Nations (Oxford University Press, 1952).

It would be comforting to report a happy outcome in the longer term.  Those who clutch at straws might take comfort that Liberia eventually – in 1953 – ratified the 1926 Convention Against Slavery. As for enforcement of human-rights law by international organizations, readers will know that some modest advances have taken place since the 1930s. Sadly, however, the League’s ineffectiveness in the Liberian case has been replicated on all too many occasions since that time.

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© 2013 – The International Judicial Academy
with assistance from the American Society of International Law.

Editor: James G. Apple.
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