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POLITICAL OFFENSE EXCEPTION AND EXTRADITION

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Persons who find themselves in a situation of asylum and refuge shall enjoy special
protection to ensure the full exercise of their rights. The State shall respect and ensure the
principle of non-refoulement, and shall provide emergency legal and humanitarian
assistance.
Article 41 of the Constitution of the Republic of Ecuador

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Background The Julian Assange Case
Giving a further twist to the conspiracy theories being knit around his persona and his brain
child, the WikiLeaks, Julian Assange applied to the Ecuadorian Embassy in London for
diplomatic asylum on 19 June 2012 (WikiLeaks, 2012). His request was made on grounds of
fear of political persecution in the garb of a couple of sexual harassment charges following a
feared extradition to Sweden. An Australian by birth, Assange is an activist and a journalist
who gained worldwide fame when he launched WikiLeaks, a website dedicated towards
releasing classified government information to public according to the principles of freedom
of press.
On 17 August 2012, the Government of Ecuador granted diplomatic asylum to Julian
Assange, thereby recognizing the seriousness of the appellants stance and endorsing his
apprehensions of political persecution and also preventing his extradition to Sweden.
Seemingly in accordance with the statutes of international law, the step lead to a bunch of
controversies as the international diplomatic law is somewhat vague about diplomatic
asylums and extraditions (Vark, 2012) as the latter are normally the result of interests and
initiatives of non-state actors within the framework of international criminal cooperation. The
problem with extradition treaties is that these make an exception to political offenses
(Kinneally, 1987). Assanges WikiLeaks venture places his case within this category due to
involvement of large and influential states like UK and USA, countries where he can be
charged with high treason if extradited to and tried in a court of law. Hence, the political
offense exception has been invoked by his lawyers.
Despite an apparent regard for a negotiated settlement, all the stakeholders have behaved in
an inappropriate manner thereafter. Allegedly, taking advantage of the Diplomatic and
Consular Premises Act 1987, Britain reacted to the Ecuadors decision by threatening to
reverse the diplomatic status and arrest Assange by force from within the embassy premises.
Conversely, Ecuador rallied support from Argentina, Bolivia and Venezuela (Connor, 2012).
On the other hand, US dismissed Assanges diplomatic asylum as it does not identify the
action as part of international law. Strangely, US not only has refused to exert any diplomatic
pressure on Britain to arrest Assange, but has also expressed disinterest in persecuting him
(The Telegraph, 2012).
Currently, Assange continues to stay in the embassy in the Ecuadorian Embassy in central
London to in order to avoid arrest and possible extradition to Sweden to face allegations of

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sexual offences. Concurrently, Ecuador has recently been discussing his case with the British
Labour Party in order to resolve the almost yearlong diplomatic standoff. However, the
South American country is still bent upon preventing Assange's possible extradition to the US
in case he is extradited to Sweden (Quinn, 2013).
Taking advantage of the multifaceted nature of the Julian Assange case with regards to
international law and diplomatic procedures, this essay will strive to examine the political
exception clause of extradition, defining and analysing both terms with regards to their
genesis and weaknesses with special emphasis on the former, while treating the Assange
situation as a case study.
Political Offence Exception with Regards to Extradition
The criminal sciences define a political crime or offence as one involving explicit acts or
lapses (where there is a duty to act), against the interests of a particular state, its
governmental or the established political system (Ross, 2012).
States normally classify political crimes according to varying perceptions based upon threats
to its survival in real or imagined forms, to include both violent and non-violent categories.
This treatment of the political crime gives undue power to the dominant group over all the
dimensions of human and civil rights and freedoms of speech and expression. Sometimes,
even political disagreements of the most common nature are also pigeon-holed as serious
offences. The highly explosive nature of most of the contents of WikiLeaks render Assange
most vulnerable to the perceptions of the world powers involved that is USA and UK.
From the 13th century, B.C., onwards, offenders on the run were captured by medieval
tyrants, in order to gain political power by surrendering mutual political adversaries. This
process later matured into extradition treaties facilitating the return of the alleged political
offenders. In fact, political offense exception was not always used with regards to extradition
till about the end of the 18th century, A.D., when it was routinely applied against individuals
accused of religious or political crimes against the sovereigns.
Taking due advantage of the principles driving the American Revolution like the individual
rights to dissent and freedom, writers such as John Locke and J. S. Mill transformed the
nature of the political offence into a non-extraditable category, in the eighteenth century. The
concept was further matured by a gradually growing reluctance to support the dictators and
tyranny, respect for individual rights and a dislike towards interference in domestic affairs of

Page |6
other states. Formally, the political offense exception was originally codified in the Belgium
Extradition Act of 1 October 1833 and thereafter was included in the Franco-Belgian Treaty
in 1834 (Kinneally, 1987).
Over the recent political history, political offense has never been defined clearly despite
being included in many 19th and 20th century treaties. Though an attempt to clarify the term
was made in the attentat clause of the 1856 Belgian extradition law, which distinctly
excluded attempts to murder the sovereigns from the political offense exception (Wijngaert,
1983), the judicial and executive bodies have been trying to compose a more suitable and
comprehensive definition since then. The Supplementary Treaty is one of these countless
attempts and states that the conceptual context of a political offense is quite flexible as it
varies with each different situation and therefore, cannot be applied uniformly over all the
situations falling in the same category in similar situations. Moreover, if a treaty handles the
clause of political offense rigidly, the absence of any flexibility will nullify its future use.
Subsequently, the absence of a clear definition of political offense presents both benefits and
drawbacks to the process of extradition.
In the context of political exceptions and extraditions, political offenses have normally been
categorized as under (Kinneally, 1987):

The Pure Political Offense

It includes any type of behaviour, except that of common criminal nature, against the
ruling government of any kind that may be perceived as a considerable threat to the
officially promoted ideology (political, religious or racial) or the political structure. Its
examples may include treason, subversion, spying and sometimes even incongruity
with the state or ruling party ideology or orders. Pure political offences are generally
non-extraditable due to their relevance to the internationally recognized and accepted
individual rights of freedom.

The Relative Political Offense

This category of political offenses involves acts that consist of at least some indications
of common crime tied together with some overt or covert political agenda. The criminal
dimension here renders extradition as a difficult and complicated option.

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The Julian Assange case incorporates both the fore mentioned categories from entirely two
different perspectives. From a personal viewpoint, Assange denies the sexual harassment
charges and claims that his crime, if any committed, is purely political in nature and the
criminal allegations are just instruments to bring him to trial for treason. Hence, he should not
be extradited. On the other hand, the British government claims that the presence of the
common crime element makes his case suitable for extradition. Matters have been further
complicated by the Ecuadorian government, which has granted diplomatic asylum to him as a
purely humanitarian practice (Vark, 2012).
Interpretations of Relative Political Offenses Exception
In order to understand the full dimensions of the Assange case, it is essential to identify
several different interpretations of the relative political offence exception.

The Objective Test.

It is one of the most constricting interpretations and

concentrates only on the objective act with a complete indifference towards the
perpetrators motives. For instance, in the Giovanni Gatti case of 1947 in France, the
court applied the objective test to the request for extradition in respect of a criminal
charged with murdering a communist in absentia. Though the political motivation
behind the act was almost proved, the court granted the request for extradition because
it felt that the political character of the offense originated from the nature of the rights
injured and not from his motives. Hence, according to this test, a state may not grant an
extradition request unless it is proved that the nature of the injured rights was political
(Wijngaert, 1983).

The Motives Test.

Quite opposite to the objective test, some courts prefer

concentrating on the criminal's motives alone. Meaning thereby that if the offender is
found politically motivated, the extradition is not granted, irrespective of the
association with political motives or aims. For example, in 1975, two American citizens
were arrested in France for air piracy, kidnapping and extortion. However, despite the
seriousness of the offences committed, the French legal system repudiated the request
for extradition by the US authorities as during the actual act, one of the hijackers
commanded that the aircraft be flown to Vietnam. Being actively opposed to the US
military interference in Vietnam, the French were convinced that the criminals were
politically motivated and thus deserved to be treated under the political offense
exception (Kinneally, 1987).

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The Swiss Test. It is also known as the predominance or proportionality test as it

attempts to justify the political motive or objective of the perpetrator against the
essentials of common crime and if the political motivation outweighs the criminal
intent, the political offense exception is applied. This test has been severely criticised
because of its capacity for the randomness. However, it is the only theory which aims at
balancing important elements simultaneously, primarily the severity of the act and the
overall political atmosphere.

The Political Incidence Test. This test is currently being applied by both US and UK
for interpreting relative political offenses and examines political crimes which are
incidental to and part of political turbulences. It was applied in the Meunier case
involving bombings by an anarchist and extradition was granted as the court considered
an anarchist to be the common enemy of all states (Farbey, 2007).

Like all other past cases of diplomatic asylum, Ecuadors treatment of the Julian Assange
case remains debateable. There are numerous reasons of this controversy. The prime most is
interference of one state in anothers domestic affairs and causing hindrance in its legal
system. Despite the political undertones, the basis of demand for extradition remains common
crime that is the sexual harassment charges. By providing asylum to Assange, Ecuador is
obstructing the course of ordinary justice. Another reason is an apparent lack of solid
evidence to support Assanges claims of an imminent threat to his life and safety and which
gets even more pronounced as US has expressed disinterest in persecuting him. Yet another
reason is non-applicability of any of the four internationally recognized tests. The Swiss or
the proportionality test may seem appropriate to a certain extent but the political aspect
outweighing the criminal one is purely a matter of choice and intent.
Extradition as Expression of International Law
Extradition has been elaborately defined by legal experts and state constitutions (Gasiokwu
and Oche, n.d.). As per O'Higgins, extradition is the process in which state A delivers a
criminal to state B if he has acted against the law of the latter for trial or punishment. On
somewhat wider lines, The Harvard Research Draft of 1935 explains extradition as the formal
yielding of a person by a state to another for prosecution or punishment. The Supreme Court
of the US gives another definition of extradition stating:

Page |9
"The surrender by one nation to another of an individual accused or convicted of an
offence outside of its own territory and within the territorial jurisdiction of the other, which
being competent to try and punish him, demands the surrender".
It is safe to assume from the fore mentioned definitions that:

The state providing asylum enjoys the lawful authority to yield the fugitive to the state
requesting extradition.

There is a cooperative relationship between the two states.

The requesting state has legal authority to try or punish the fugitive.

All the above definitions lack the reference to the wellbeing and safety of the individual
being extradited whereas it is crucial that the rights of the accused must not be unduly
prejudiced during the trial. This flaw coupled with the absence of a bilateral treaty with
Sweden, has been exploited to the fullest by the Ecuadorian government when it granted
asylum to Julian Assange.
The international law of extradition is also governed by a few important considerations
(Gasiokwu and Oche, n.d.). Firstly, all states involved believe that crimes of any category
must not be left unpunished. Secondly, the statute of jurisdiction dictates that the state
providing refuge cannot try or punish the offender, who must be surrendered to the requesting
state for trial and punishment. Thirdly, the factors of territorial jurisdiction and evidence
make it more convenient for the destination state to prosecute and punish the criminal.
Finally, the surrender of fugitives to the requesting state is not obligatory if there is no treaty
between the two countries and in this case the extradition may only materialize on the basis
of mutual benefit.
There are also two basic and internationally accepted principles that govern the phenomenon
of extradition (Gasiokwu and Oche, n.d.) and are generally included in most bilateral treaties:

The Principle of Double Criminality.

It edicts that the act in question must

constitute as crime or at least similar in nature and punishable by law in both countries
that is the host and destination states.

The Principle of Specialty.

This principle dictates that the requesting state is duty

bound not to try or punish the fugitive for any crime other than that for which he was

P a g e | 10
extradited. The principle of speciality will be the only point of relief for Julian Assange
if he is extradited.
Extradition has always been one of the oldest expressions of the international law as the
peace accord amongst Rameses II of Egypt and the Hittite prince Hattusili III in 1258 B.C.,
the most ancient document in the diplomatic history, lists down certain provisions concerning
the extradition of criminals. Moreover, in ancient Greece and Rome, extradition requests by
the state were treated with contempt due to the traditional and time honoured right of asylum,
but sooner or later the fear of divine vengeance often gave way to political concerns
(Magnuson, 2012).
The ancient practice of extradition practice was primarily political and not criminal and dealt
with crimes such as rebellion, threatening the safety of ambassadors and even starting wars
(Garcia and Doyle, 2010). This practice continued well into the 18th century as extradition
treaties were both a rarity and were dictated by the constricted interests of political elites.
With the advent of the 19th century, extradition treaties thrived and started to include a greater
variety of common crimes (Blakesley, 1981). Gradually, extraditions were treated as
compulsory components of international treaties. Procedural details were designed and
established to deal with requests for extradition and exchange of compulsions was imposed
on the parties. Furthermore, the requesting states were bound to lay out the grounds for
extradition and also to validate them according to the relevant treaty which often listed and
specified extraditable and non-extraditable crimes. Simultaneously, domestic courts were
frequently requested to decide upon the legality of extraditions.
For normal extraditions, the executive of the concerned state is applied to first, providing the
reasons for the extradition accompanied by evidential support for the allegations. Subject to
the executives approval, the judiciary decides upon the certification of extradition by
examining both the allegations and the concerned treaty. Towards the end of the process, the
proceedings are sent to the executive who is ultimately authorized to sanction or reject the
request (Hughes, 1986).
Over the course of the last few decades, there have been two important conceptual changes in
the extradition process. Firstly, extradition started off as a political phenomenon that mainly
omitted common crimes but by the advent of the 19th century, it became a criminal
phenomenon that fundamentally excepted the political crimes. Secondly, the human rights
dimension has started to be considered in extradition requests as the rule of non-inquiry that

P a g e | 11
is refraining from questioning the fairness of the requesting states justice system, is
gradually being ignored in favour of human rights of freedom.
In the Julian Assange context, the rule of non-inquiry assumes an added importance as one of
the most questioned matters in extradition is the fear of discriminating or inhumane handling
in the destination countries thereby creating a conflict amongst individual rights and state
rights in international law. This conflict invites the attention of the human rights groups who
raise their voice in concern when people are extradited to countries with poor human rights
records (Demick, 2010) and even US, where there is a possibility of the death penalty or
other harsh sentences. For instance, in the Soering vs United Kingdom (1989) case, when the
extradition was ordered, Soering applied to the European Commission on Human Rights
against it, on the basis of flaws in the US prison system, especially the death row
phenomenon which encompassed insensitive and degrading treatment in violation of the
European Convention on Human Rights. The court agreed with his stance and denied
extradition (Bloom, 2008).
Weaknesses in the Extradition Laws Concept and Application
The phenomenon of extradition, though internationally desired, accepted and acknowledged,
has its share of problem areas, conceptual difficulties and technical complications. Some of
these have been described in the succeeding paras.

Concerns for Safety of the Requested Person.

Extradition,

while

being

an

important and effective step against crime, has serious implications concerning the
rights of freedom of the concerned individual as owing to the length of extradition
procedures, he may be detained in custody for prolonged periods of time without the
possibility of bail. For this particular reason, extradition treaties normally include a
detailed list of constraints and preventive measures, however, these are generally
diminishing thereby adversely affecting the rights and interests of the concerned
individual (Griffith and Harris, 2003). This was probably the only consideration driving
Assanges decision to seek diplomatic asylum wth Ecuador.

Rigidity in the Principle of Dual Criminality.

The principle of dual or double

criminality forms the basis of the extradition law and dictates that the purported crime
driving the request for extradition, must be punishable in both the states. For this
purpose, extradition treaties have always included a list of extraditable offences. While

P a g e | 12
this approach is successful in dealing with common but serious crimes like those of
Julian Assange, it is totally unable to address complicated and organized crimes. In
order to address these complications, following general rules can be incorporated in the
relevant treaties:

Differences in just the categories or terminologies of offence may be disregarded.

Instead of examining the individual elements, the crimes may be treated in

entirety.

In the Julian Assange context, the onus of responsibility lies with Sweden as it has to
describe in detail, the alleged sexual harassment charges and support them with
substantial evidence. On the other hand, it is the job of Ecuador to establish relevancy
of crime according to the local law that is its applicability in the domestic legal
framework (Griffith and Harris, 2003).

Conceptual Flaws in the Political Offence Exception.

The

political

offence

exception is one of the mandatory bases for refusing a request for extradition and is
included in bilateral extradition treaties as such. It means that a state will not sanction
the request for extradition if the offence is deemed of a political nature (European
Convention on Extradition, 1957). However, the term political offence is not only ill
defined but also involves certain complications with regards to establishing solid and
suitable evidence thereby gradually losing its significance and practical application.
There is an international consensus on including non-violent crimes in the political
offence category but the interpretation remains highly doubtful while dealing with
violent crimes. The definition of political offence has always remained generalised and
branded by methodological gauges like proportionality, which means that no offence
may be called political unless there exists proportionality amongst its nature and
political objectives. All these factors have acted in unison to further complicate the
terminology and have also introduced a predictable bias involved in its application as
judges are hesitant to engage with these issues and quite frequently display a bias
towards the interests of the requesting state. Political exception is also gradually losing
its value because of its obstructive impact on the course of justice as terrorists often
exploit the inherent conceptual weaknesses of the term to their advantage.

P a g e | 13
In the Assange case, political exception is difficult to be established despite Ecuadorian
claims to the otherwise. There is no clear evidence that either US or UK, the two main
affected parties due to revelations of WikiLeaks, are behind the sexual harassment
charges laid down by the Swedish government.

The Human Rights Dimension.

The

modern

extradition

treaties

include

obligatory grounds for regretting requests for extradition, which are primarily based
upon recognized anti-discrimination and human rights values. In these scenarios,
extradition may be refused if:

If the host state has ample reason to believe that the extradition may result into
prosecution or punishment on the basis of religion, race, ethnicity, nationality, sex
or social status, political views, sex or status.

If the host state has sufficient cause to believe that the extradition may lead to
torture or harsh, inhuman or degrading handling of the fugitive.

If there is an absence of a guarantee for safety of the accused incorporated within

the confines of the criminal proceedings in accordance with internationally
recognized civil and political rights.

The Soering principle as cited by Bloom, 2008, remains one of the most important
dimensions of the human rights aspect, though its validity depends upon the courts
perception of the risk of punishment, degrading or inhuman treatment. Despite the
comparative effectiveness of the human rights aspect, its practical manifestation
remains complicated as extensive resources are required to establish solid evidence for
discrimination or violation of human rights. This is the dilemma behind the Assange
situation as he failed to prove in front of the British courts a possibility of human rights
violation and in the face of a definite extradition, had to find refuge in the Ecuadorian
Embassy.
Extradition has also been widely criticised because of the perceived unfair attitude of the host
state as it sometimes assumes the role of a prosecuting agent, thereby giving rise to a conflict
of interest through nullifying the dictates of fair treatment and provision of defensive
procedural provisions. However, in Assanges case, the biased behaviour of the British courts
cannot be proved as the proceedings were marred by the dubious conduct of his own legal
counsel.

P a g e | 14
Extradition treaties do not generally demand that extradition requests be accompanied by
solid evidence. Instead, a mere assertion of the committal of offence is considered to be
enough. This makes it extremely difficult for the fugitive to make use of or prove any of the
usual statutory exceptions. Moreover, the usual financial status of the accused renders him
unable to employ the costly legal services.
Conclusion
The Julian Assange case falls within the confines of a relative political offence that is the
actual charges of espionage have been criminally shaded by allegations of sexual harassment.
Logically, in the absence of solid evidence proving covert designs of either US or UK, the
common crime element renders his case most appropriate for extradition. Furthermore, there
are indications that by granting diplomatic asylum to Assange, Ecuador has interfered with
and even hindered both the British and the Swedish legal systems. Finally, the lack of any
solid evidence proving danger of the human rights violation, the apparently crystal clear role
of the British judicial system and the doubtful statements of Assanges own lawyer make him
a likely candidate for extradition to Sweden.
On the other hand, Sweden and Ecuador or Britain and Ecuador enjoy not even a single
bilateral extradition treaty and therefore, the latter is not under any kind of obligation to hand
over Assange to either of the two states.

P a g e | 15
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