a. ~. 35, rn.::a

StrZUlle TEIICHI

lm'ROJXJOTION

--~---

Page VV-l.

VV-1. · The purpoee of thi• IWllllllU'Y ie to preeent to

the Tribunal an ari!\17eie of the main point• in the evidence

I adduced both b7 the Proeecution and ·by the Defense relatln&

to the Defendant SUZUKI.

VV-2. :ror the eake of convenience thie evidonce baa

been arranged under separate headings. and. ae far aa wae

possible, the cb;.onology of evente baa been f ollowed.

~ The contentions of the Prosecution baaed on the _

evidence are aet out in appropriate place• in t he Summary and

s9ecial mention ia made of avidence, ad&lce~ by t he Defense.

which the Prosecution eeeka to di ~tinguieh.

~ The Defendant SUZUKI ii charged und.er Counts

1-17, 19-22• 25-32, 34-47 and 51-55 of the Indictment. all

numbers bein& inclusive.

l. MILITARY N t'AIRS mm~u a.

~ In hle atfidavi t SUZUKI etatas that hie frequent

contac~a with China and the Ohineee made him aympathetic with

the Chineae Nationalietic movement and that after an interview

with Chiang Xai-ehek in 1'27 hie eympat}V for that movement

was all .the more intensified. Hie experiences cultivated hi•

convict ion tbat the aspirations of the Chinese people for the

recover7 of China's nat i onal right• would be realised in due

couree of tioe and that Japan ahould aeaiat and cooperate with

the »ew China represented by t~e Nationalist Party and that he

VV-5. a. ~. 35, rn.::a .

,..

PURL: http://www.legal-tools.org/doc/3ac9c0/

Page VV-2.

(VV-5.) ia glad to know that OM of his Chinese friends liu Lin under-

etands him thoroughly.

VV-6. The witneos Hu Lin, a newe~a9er Editor in a.

Sha.n&hai states that in 1927 SUZU-Al sy:upathized with the

Kuomin&tang and advoca t ed that Japan should help bring forth

cooperation between tt1e Generalissioo and ?tarsh!\.11 Cha."lg

lisueb-hang· In 1935 Sino-Japanese r.~la.tionshi}' was gettine b.

worse and SUZUKI still advocat Ad Sino-Japanee~ cooperation. a .

~ Cn cross-examinntion .;uzu-,<I told the 'i'r::.bunal

that in 1932 and 1933 he wne attached to the Bureau of

. Milit.ary .Affairs. nie duties pertained to liaison matters

in military affairs concerning China. r.nd enabled him to study

the Manchurian probl em and tho China Incident and in 1932 he

went to Shanghai to inveBtieate the ~.e.nchurian Incident and b .

conditions in China propor. He wa s again in China after the

Tang-ku t r uce was signed. a .

VV- 8. On redirect eJtamination SUZUKI told hie counsel

that while in China he had a convorsqtion ,.,ith Kwang Fu who

was on intimate t erl!ls with Chiang Kai-shek and Chnirl!lan of the

Political Council in Peking. Kwfl.?lg Fu said t~at there wer e

three points around w:uch J upan and Ch ina 3hould rtake effort s

for the restoration of relationo.

(1) Not to take up the Manchurian problem until

both sides had cooled off.

(2) Japan should not seek a specia1 economic statue

-------------·-~.

a. Rx. 3606 b. T. :55,183

YV-7. a • . T • 3.5,255 b . 'I. 35,256

.YY::!t· a . T. 35,338


-

(VV-8.) in China proper but should e~~e in economic

activities on equal terms with the Powers.

(3) The 001D1Don aim of Sino-Japanese relations should

be anti-collll!IWlism.

~ SUZUKI approved of these suggest i ons and

expressed hie opinion to his superiors that settlement

of the various local issues in North China should be ~der-

taken by relying upon and trusti»g the various North China

organs of the ClU.neee and in cooperation with t he Chinese. a.

!Y=.!Q.• Not all of his opinions were adopted. As a

result of the Manchurian Incident t here was in the Army a

feeling of contempt for the Kuomint;tnng and bei ng only a

Lieutenant Colonel his views did not carry much weight • . a.

!!::!l• On cross-examination he was shown a document

which had been received by MOHISHI~, the Section Chief of

the Asiatic .lffaire :BurAau of the Foreign Office, on 12 July

1933 • .lvritten memo on the document etated that it had b een

received from Lt. Col. SUZFKI "·1th a note that as t he War

Minietry and the Army General Staff had unanimou3ly agreed

on t he giat of the policy set forth in the document, it was

desired that the government would decide its policies along

t hose lines. The policy set out i n t he document stated in

part I

YB-·

~we m~at make t he North China Regi me suppress the

National Party's .Anti-Japanese activities in North

China and make the party gradually reduce itself until

VV-11· a. T. 35,339 a. ~. 3607 A,

T·. 35,262

VV-10. a. T. 35,340


Page VV-4.

(VV-11.) it• final disao'lution ••• We should proclaim to the

world that the Imperial Government as well as its

petple 1hall be hostile to the Nanking Government as

long as it does not alter its past attitude towards b.

Japan." .. 1. • a. VV-12. SUZUKI went on to say thut the poHcy did not

express his own views and that it 'was hts own private opinion

that he gave to Hu Lin in the course of a private convers~tion.

VV-13. It is submitted that SUZUKI deceived Hu. Lin as

to the real policy of the War Ministry and the J.rmy General

Staff whose avowed object wns the final dissolution of the

Uational Party and hostility ·towards the Na.nking Government.

If this contention is support ed by the evi dence , end the

Prosecution contends that it ie, it renders the testimony of 'du

Lin worthleae when he sayd that SUZUKI was advocatir..g Sino-

Japanese cooperation. SUZtr.tCI knew what the real policy was and \

was lending his efforts towards its implementation, and, it is

submitted that the evidence establishes that SUZUKI 1s alleged I

sympathy with the Chinsee Nationalistic move~ent was a sham

and not in accordance with the true facts. He has ~een shown

by the evidenoe to be a person unsympathetic with that movement

and hie subsequent activities aro consistent with that view.

!!::!!· A.a to his attitude towards Russia it is to be a.

observed that :KIIX> ~ecorde in his diary that on 18 .April 1933

in a conversation at the residence of Mar~uis Inoue, SUZUKI

Y...V:-:.~ a. '?. 35,264-5


Page "-5.

(VV-14.) said that there were two kinds of enemy, an absolute enemy and

a relative enem;y. Ae Russia aimed t o destroy the National

structure of Japan. he pointed out Rus~ia as an absolute enemy • . b.

In hie affidavit. referring to t his conversat!on, SUZUKI states

as long as Russia aided and abetted t he activities of the 3rd

International which plotted to effec.:"t a. C~mnr.inist 'revolution

in Japan abolishing tM :E>nperor syot em(" R~~o i;ia was an absolute

enemy of Japan.

VV-15. To further show his attitude towards Russia a.

during this period, the Prosecution ad·:·uced evidence

through the witness T.AXEBE, formar Chief of the General

.Affairs Department of the Manchurian Government, that at

a meeting in Toyama Military School in Tokyo in 1933 after

ARAKI had spoken; .)UZUY-I r using a map of Manchuria, China

and th~ Soviet Union, made a statem~nt which consisted in

layint; the ground for ·the necee~ity for a war of Japan

against the Soviet Unicn and for the necesGity of captur-

ing the Soviet Mari time P;.·ovinae ~ Zc:.ba!.kalye and Siberia. a r

!!:!§.· In hie own evide~ce SuZUKI says that he

remelibers E:Xplaining maps of ll.an<;hurin but denies mclcing

any speech connoting the necessity ~f oilitary occupation b.

of Siberia. The witness KOS.AKA supports thio statement.

VV.-17. The ?rooecution contends that as early as

1933 STJZUKI was, in fact , advocat ing the expansion of

Japan by means of ttggr fl ssive war and again 1a attempting

to conceal his real attitude to serve hie present ~urpose.

VV-14. ~. T •• ~5,231 YY.-J..Q.

a. Ex. 3371 T .• 31,835

a. T .. 35,232 b. T .. 36,985


-

PA8e VV- 6.

2 . OHINJ. AFFAIRS BOARD a.

VV-18. In his affidavit SUZUKI etatea that the

China Incident commenced duri ng his otay in Tongning

and tlat he "deepl y deplored• such devel opments. Many

feat ures of the pol icy relative to the China Incident

decided by the High Command and government were diametri-

call7 opposed to his fundamental ideas on China.

VV-19. When he was appointed Chief of the Political

Section of the China J;Cfairs Board, on 16 December 1938, be

had ·to execute the d~ties assigned to him within the fram&-a.

work of such a pol icy. He eet about hie task with the

following principles as his personal guide:

(1) Cooperation between the Chinese and Japanese

on terms of equality.

(2) The security of the Chinese in war striken areas.

(3) Respect for the right s and interests of the Pcwere

ii\. China. a ..

VV-20. He f'Urther states that the establishment of

new regioee in Ch.ina was incompatible with hie basic idea•

regarding Chinese affairs but it had been a fixed policy over

which he bad no control. a..

VV-21. On cr oss-examination it was established that the

China Affairs Board was organized in December 1938 and that

he was the f i rst Chief of the Political Section. He admitted

that he was one of the organizers of the Board of which the

VV- 18. VV.-20. --a. !t'.. _ 35,193 a . T. 35 , 195

VV-19. a. .T. 35, 194

YY::;U_. .T. 35 ,266 a.


-Page VV-7.

(VV-21. ) Prime Minieter was President and other Cabinet Ministers were

Vice Presidents. The principal officeo of the Board were in

Peip~ng and Shanghai a.Ld there were other offices in Ka.lgan

in Inner Mongol ia and in Ainoy. a .

VV-2J. He went on to aay that the Board. handled busi-

nes s affairs in China in rel ation t o i ndustry. transportation

and economic problems and the cc.ntrol of the oof'.rd was effected

through t he !forth China Development Co1;ipMy and the Ce:ntral

China Developm~nt Go'!J})any. The i:loard also gav~ advice at times

to Provisional Governments · in Ct ina. a ..

VV-23. When aeked on croe3-exacinat1on what features of

the policy relative to the China Incident and iecided by the .

High Command and Gc·vernment wera diametl'icnlly 09poeed to his

fundamental i deas on China, he r.e-plied that the features of

the policy were the d\Jciaione of Jblluut·y 1938 and October 1938. a.

VV-24. Th3ae decieione were that Japan hoped for the es-

tabliehment of a new government in China and in cooperation

with that g~~ernment Japan would work for t he stability of

East Asia an'l f or Sino-Japa."lese c.:>operation.

~· SUZUXI felt that th~mgh t he .Army telked of ea-

tablishing a new r egime in China. &uch a reg ime would natural -

l y be eete.b!i&hed under the au thor:l.ty anci influence of the

Japaneae Army and it would be diffic"J.lt to hop~ for a spon

taneous expree~ion of will on t he port of t he Chinese

peopl e to establish a government of their own.

~· a. 1.r ... 35,267

VV-23. a. T. 35.270

~· a . T., 35 ,271


{/

-a.

VV....a§. He also felt that it was wrong for Jopan to ~0~~~9s

an economic ayatem in China baaed on Japanese le.we. He vaa b.

making every effort to advance aleng thP lines that would make

Japan'• interference in the political affairs of China as

emall as possible.

':f!!..::E1.• At this point the cross-examination was directed to

what in fact waa done by the China Affairs :Board to mi nimize

such interference of Japan after hie appointment aa Chief of

the Political Section.

~· In March 1939 Liaison office• were aet up in China. a.

SUZUXl atate•-that prior to tneir establiahment the Army bad .

Special Service jgenciea al 1 over China. and the opinion wa•

adTanoed that it was not good that the Army solve all prooleme

according to it• own viewpoint and that the viewpoint of all

administrative government efficea be aleo taken into con-

eideration in dealing vith such problems. a.

VV-29. On turther· cross-examination SUZUKI atated that - ' in June 1939 the China Affairs Eoard did not concern itself

with such matter• aa the appropriation of ~oneye for the wtJ

project. He did not know that the moneys for that project

were to lSe paid out of the surplus Maritime' s Custom

Revenue t1r that the funds were to be drawn in the name of

a .Japanese to maintain aecrecy. a.

~· Vhen confront ed with a document from the file•

of the Fereign Miniater it became cleqr that correspondence '

dated 29 June 1939 had passed b etween SUZUKI and the Chief of

..... •

VV-26. VV-?9.

a. ~T. 35,272 a. _ T •• 35 ,279

b. ~. 35,276 VV-30. ~ Ex. 36C8, A,

D'=Sl· a.

... ~. 35,217 T. 35,281


..

.)

_ t - • ·="-'--""-==.z~..==:i.:-.i..;;.--~~'.!::· ;::;;;:~-.Lo--,_..._,, __

.fage VV-CJ

(VV-31. ) the Bureau of Fe.st Asiatic Affair• of the Foreign i.\inistry

conoe~ning t~1e nomination of a Japanese to be responsible for

the expens9e of t~e Yu project in accordance with a ieoieion

made at a moeting of the China Affair• Board. SUZUKI tilen b. .

admitted that he thought that t here had been expenses for

the Wl1 project .in accordance with auch a decieion.

VV-.Il· He went on to say that he did n?t :C'\0·11 thr ·.>)~.r-

po ae for which the f'unds vera to be drawn or whether they

were to be drawn secretly; he merPlf conveyed to the Foreign

and the ·Foni.gn Office and the China Affair :Board lh-Mch ·

officea in the Ohina area, t he '?ommuniclltions which bad been

1ent te him from the Var Ministry.

VV-32. He did know that the Mari time Ous tome revenue

was customs duty levied on imports into China and that the \

va.rieua branch agencies of the MJn1 were carrying on the Yu

project at the time and may have utilized the revenue of the a.

Maritime Ouatoms for their ex~enditure. a.

~· He admitted that the problem• of creating new

governments in China were matters which he had eJVery r e3son

t o remember compared with others and that it wae t he moat

i!'lportant problem of the Board.

VV-34. When the China Affair• Beard vae asked to give

a letter to XAGESA (wh o was going to 1ee WaD8) in order to

1hev that the Board was not opp_9eed to Wang ' a peace -moves, a.

SUZUKI wrote the letter. He also admitted that in February

·-----.c..------------·------·------~· ~. , b. 35,283

!.!-3a. a. ~. 35,285

VV-33. a. '· 35,286

VV-34. a. 'I. 35,288


(/

-(VV-34.) 1940 the China .ltfair• ~oard recommended advieerd fer the New

Central Government and t hinks that in t hat same month 40 b .

million yuan was author ized to be l oaned to t hat government.

~· As turther evidence of SUZUKI' a attitude •to···ards a.

China the Proeeoution witness Goette stated that on 27 Sep-

tember 1939 he had a conversation with SUZUKI in Tokyo in

vhich Goette raised the question of the Chinese ~rith whom the

Japaneee ar~ wer0 working and SUZ\f'AI said that they ad.mi t ted

that they could not get General Chiang Kai-shek to their s ide,

therefore, t he war ·against China would go on. a.

~· In his affidavit SUZUKI states that he to l d a newe-

paper man whote name he does not remember t hat t he policy of

the government to deal with ~ang was illusory for Chiang Kai-

ahek was the only real ruler in China.

VV-37~ It ~be mentioned here that i t was during his a.

eervice with the China .Affairs Board that he s tates that he

voiced hie opposition to the proposed conclus ion of the Triple

.llliance (27 September 1~40) because the Nazi conception of

dictatorial and to tali tarion government was not i n ha.rmcny

with hit political views and for the added reaeon that Ger many

waa then at var with Great ~ritain, with w~icn latter country,

Japan muet keep on friendl y terms.

VV-38. The aoti vi ties of the China Aff air• ~oard and of

IUZUKI during his period of o~fioe have been gone into with

eome particularit y to prove tilo fact th.Rt this pov.erful Boa.rd,

e• *"'-VV-34.

b. ' · 36,291

VV-35! a . I. 3780

VV-36. a. 'I. 35 ,234

VV-37. a. i .. , 35,190

'


(VV-38.) ~ith SUZUKI as one of its important heads , 1as tlmarting •a

spontaneous expression of will' on the part of the Chinese

people to establish a government of their own. So far from

making an effort to minimize the interference of Japan in the

politic al affairs of China, the establishment of neVT regimes

in China was financed and encouraged.

VV-39. It is submitted that, by r eason of his of fic e end

the importance of the matters engaging the ac t ivities of the

China affairs Board, SJZUKI had full kno'lfledge of l'lhet was

being done and his alleged efforts to minimize interference

and to bring about cooperation between Chine and Japan on

terms of equality are unsupported by the evidence. The Pro-

seoution contends that SUZUKI was in favour of aggressive

warfare in Chine end was active in the exploitation of that

·country and its r esources.

3. THE PLANNif'l} BOARD a.

vv-40. As SUZUKI states in his affidavit his s tudies i n

financial and economic matters in the Finance Ministry in

1929 arounsed in him a lively interes t in problems of natioaal

economy.

VV-41. This interest in economic matters will be shown by

the evidence to have influenced his whole car eer and eventually

led to his appointment as President of the Plan~ing Board in

April 1941.

VV-42. The Ordinance for the orgenizatio~ of the Plan-a•

ning Board provides in Ju-ticle I that the Board shall have

~· a. R. 35 ,175

vv-42. a . Ex. 71, R. 684


I I I i

(VV-42) ch!lrge of

Page VV-12

(1) Drafting of pl ans conc€rni~g the· exnan

sion gnd emoloyment of the t otal na tional r esources i n

times of oeace and war a nd r enorting of such ol s ns,

together with r easons ther ef or, to the ~rime ~~inister.

The ordingnce further ryrovir es (Article 1, U9 r 'l

gr~oh 4) that the Bc'lr d shqll ~d just and coordin~te af

f sirs of the various government of f ices with r egar r t o

the making and executio~ of a nation~l mobiltz'ltion ul'ln~

.VV-43. It is pr obsbly qui t e t r ue as SUZUKI stat es a . in his affid11vi t and the l)l ans ,,,er e not T)r el)3r ed by the

.. Pl anning Bo'lrd in an autono~ous way ~nd th1t the execu--

tion of such· ol ans was not the r esnonsibility of the Pl~n-

ning Board. Neverthel ess the 0 r e sident of the Pl anning b Board, a s SUZUKI stnt e s 0 on cros s-ex~rnin~tion, h'ld

Power t o advise the Prime Minister ~nd Cabinet on ~~tters

of national oolicy other t han those co~cerning'military

affa irs and f or ei gn a f fa irs 'lnd on l"'l'l tters whi ch ~11ould

i;if f ect trade and the n!ltion'll r esources of J s'!):in which,

it ts submitte~, would i~clude the negoti1tions with the

United St at ed in the month ·immedi ~tely preceding the out-

bre'lk of the war.

VV-44. In hts evidence a ~the Pr osecution witness

Liebert stqt ed t h'lt t he ?r es i dent 0f t he Pl anning Bo1r d ,

t ogether with the ?r esidents of control associ'lti o~s

t 11 ~ J This is denied b.by con ro e~· an'lnese economy.

VV-43. a . ~. 3?,240 · · i b .. ;... 35',293

VV- 44. a . ; ; .• 8,403 b. '-·· 3 ',241


Page VV-13

(VV-44) SUZUKI who stqtes th~t the organizqtion ~nd oryer q-

tions of co~trol associ~tions wer e in ch~rge of the

Ministries concernea 3~d not of the ?lqnning Boqrd.

It is submitted that SUZl11<I hirself re~oves 'lny

0oubt which ni ght exist as to the iroor+~nce of

his office when st~tes c .th~t he w~s instructed by

the Prime Mtniste~ to concentr~te his energy on the

work of "econol"ic mobilizqtion". It could only

have been r.iob iliz ~tion for wqr '\S he hi."""self well

knew. VV-45~ In his affid'lvit SUZUKI st~tes ~ .. th'lt

he was 3S~e~ by KO NOYE to ~ssu~e the post of President

of the Planning J3oard and, while he w!ls r eluctant to

acceut, KONOYE told hi~ that his r efusal would h'lve

Pl 'lCed KO NOYE tn -in awk1°ard oredic'l!"ent :;ecquse :a

condition of Ogura's qccept3nce of a Cgbinet ~ost was

th~ nol"'ination of a ne"1 ?resi~ ent of the Planni ng

Board«'

VV-4' .. At the s~l"le ti?Tie, 4 Al)ril 1941, he 'll'l S ~u

pointe~ Minister without Portfol i o which em1bled hi!"" a .

to attend C~binet Meetings., He understood thqt hls

".>riT"ary funct"'.on lay in the executlon of th~ business b ..

of the Planning Boqrd. On cros~-exqn1~at1on · he

stated thqt he did not sug~est th'lt bec~vse his ori-

1"1!\ry function lqy in the executio~ nf the business of

the Planning Board th9t he coul0 esc'll)e the resnonsib-

VV-44., c. J:. 35,30,

VV-45 .. Se i,_ -35,196 b .. R,. 35,292

•


P~ge VV-14

(VV-46) i lity att3chtng t o ~ Mtnis t e r of St9te.

VV·-42. In his affidavit (\ . he stste~ th'lt he un-

derstood he w~s es'1eci~llv chos en , not bltndly to co~

ply with the eyborbit~nt de~~nds then ~~de by the ~rMY gnd Navy but t o see th'\ t the- 9J.loc·'3.t i on of vi t9.l cor

rnoddi ties be r.i'lde in such "\ W'\Y 'lS not. to exh~ust the

very sources of the n"\tion 1 s cconor:lc 'Oov1er throu~h over concentrnti on on the nroductio11 of T!"Unltions qnd

to secure the cultur1l ltfe as ~uch qs 1)CSsible.

VV-48c- His f i r st tC\Sk vr=ts or vdng \''O the Cot"'!'lOd-

1 ty Mobiliz'ltion ~1~n or 0l~n for the \lloc'ltion of a .

Vital i~ateri~ls f or the f:ts C'll yr qr 1941 . SUZUKI b ... stltes in his a f fi<lavit t hqt the Corr'odity i.1r-b1.liz~-

tion Pl an sanctio'1e0 by t he Cabinet on 2?. ,•,ugust 1941

was forr.ula t ed so ·1 ~ to ensur e self- suoT)lY -=ind self- suf

ficiency as nuch 9s possible in r Psucct of vit'il corl"od1.

ties , with ~ vtew to gu"lrqnteetn~ the security of n'lt

i onal livel thood '3.S .,,ell 9S to or Pserve the 1)eoule 1

s

sense of security with r cgqra to n~tion'll defFnser

VV-49... . It ; s the co"'tention of the ?r osecutlon ·

th'it thls 01qn (liko othPr s which will b e r eferred to On cros s-eX3~1 -~tion , SUZUKI '

lRter) w~s '3. V!ar T)l~n .

s tated a .. that one covld not S"\Y it was q ·w~r nlan.

Great stl·ess W!'IS lRid on t he oro,....nt CX'!J"\ns io'1 of qr nr;l -When shown '3. st~tement·

ments but t h,t w~s not ~11 . r.t!\de to the nressb. coT'\cernt'1g the nl9n he qdnitted he

VV-(8. !:lo T ~ 35,196 b ~ T_ , 3 5, 199

:::x. 1132


P-ige VV-14

(VV-46) i lity att9chtng t o ~ ~tnister of St9t e .

VV··4Z. In his affidavit '\ .. he st9te~ th~t he un-

derstood he w~s es0eci911v chosen , not bltndly to co~

~ly with the eyhorbit~nt dem~nds then ~~de by the ~rMY

9nd Navy but t o see th'lt the ':llloc·':!tiol"l of vit~l cot'l

rnoddities be nqde in such " wqy ~s not to exh~ust the

ver y sources of the n'ltion 1s c-conol""ic 'Jower throu~h

over concentr~ tion on the oroductioP of r'Unttions qnd

to s ecure the cultur ~l ltfe as ~uch qs rycs sible .

VV-48~ His f irst tqsk ~qs ~r wing ro the Co~Mod

i ty Mobiliz'ltion ~1~n or 0l~n for the \ lloc'l tion of 9 .

Vital ;:2ateri"llS for the f:ls C'll yr .,,_ r 1941 . SUZUKI br st~tes in his aff i aavit thqt the Cor~odity Mrbllizq-

tion Pl an sanctio~ea by the Cabinet on 22 ~ugust 1941

was for!Tlul~ted so ·is to ensure self- suunly 9no self-suf

ficiency as nuch 35 possible in r Psocct of vit'll cor~od t

ties, with 9 vtcw to gu'lrqnteein~ the s ecurity of n~t

ional livelthood gs well 9s to Dr Pserve the ryeoryle ' s

sense of security with rEgqr~ to n"ti on'll defFnse r

VV-49~ It ~s the co~tention of the ?r osecutton ·

+h~t thts 0 l'ln (lika othPr s which will b e r ef errPd to

On cros s-ex~~t ·gti on , SUZUKI '

a . that one coul d not s'ly it was q wgr nl an. stat ed Great stl·ess w~s lAid on the l)ro,..ot CX'J'\nsio,, of !lrriq-

ments but th lt w~s not ~11 . When shown~ st~tement·

m~de to the 'Jressb. c oncerni~~ the nl9n h e 9(1oitted he

VV-48. q., T t 35 ,196 b • T. , 3 5, 1 99

Sx. 1132


sn

~e. e ·~·-1 . >

<Vlr , 4 · ) mJ!.:J nave ;:1a<ie t:~o state. ·.e·:1 t i \l "-. ' ic: :i t ,.~es e.;i ou.nced t ::r.t the

1· 1ter:u~.t1onal situati:>n , .• ~ich ;1c.cl undergo·n.o r B\'.ddo"l ci'li:>.ng~ e.nd.

VV- 50 I n a ,:s,.•or to h is .-.wn Cou.1P.ol on rec'.1:-ect c,r.am1~tion

e.. t>.at in formulating t~~ 1941 l•io~Uize.tion Plan,

:iational "c'iefe;ise, g()uerPlly s·99e.ki .:::; , vas co··.siclered but nothing

s ... eo i fic, e•.ich e.a any ~oaqiblo conflict '.'ith t }10 United States or

Gree.t 3ritain was ever oo· :si~~ered .

a. t~~at : ie

\o!e.a ooufro:'lte:l •:.rit:1 two eve·,1ts of :.~P.j~r i1n ·.orte;.100, In ~he first

cl.is .Ptc:1 of t:-oo:)f! to 5ou t h ·.'r A .c!:' I .~c1o-Cj ·.inP. br01:.~·t in its wa.'.ce

t l: e econo:nic oloc:~~e o :· Je· ;£\'l o;• t ·e l; .-1 tocl. Ste.t eA, Groat ::ritr.in

inn , ;?etrole·.,.m , :fertilizers :>Ht. ot:• ·r vitcl. oo'llffio~ities .

e .•

IY=fil. ';;:·.o ;: asked on croes-0T..Nni'1P. tion

etooJ. is.o;.:.1ne tools a:.1<1 acr e:· iron \-rore to b o u~od in t~a me.nufe.ct\•ro

of mun1t!.I) 1s of '-!t>.r s1:zmn re:·?liec: i n t:;.o r.ffirme.tive.

v-; -49 . c. ..,.,. 1132, .'1' . 10 , 20~ VV-52 • e.. .T . 3 ' 2 :.!', _,.,... ---

'.'V-50. a. T. 35,341 VV-53. a. .T. 35,198

-V\-51. e.. T. 35,198 -


(VV-53) Page VV- 1. '.> e :1ce of 2 ;uiy 1941, ·,::.t :1eard from KO: ·oy, ; t hat t:-io:· mi ght be dis-

b. t:i.at i t · 10 '.1.lt't be a s erious _matter

if' J e;?e.;;\ woro s'J: jectecl t o an economic embargo. 'l'he ? rime ?·anistar

er.id t :.at t !:J.e step "'as ~erative to "le.rd off an im··.ediate d.D.ngor of

a war· with t ::1e So.,iet Union.

a. V .. - 54, Oa crosa-exami~ation SUZUKI atat~d he himself die ~ot

t hin!< t hat t :1e move would ''a.rd r:i ff tho imir~diate danger of e. '"rar b .

wit:1 t he Soviet Union . :!e obj ected to t he !llOve bocau.se >e f elt

i n view of the :egotietiona witn America e.rd in vi~~ of the domestic

ai tuatiou H waa unwieo to de9loy J~.,o.n1 e forcos over a wido arc.a.

:i:-.e~her >.is ob,jection b e baaed on economic or military grou·.tde it is

to be obaorvod t hat SUZUKI was o e of t>.o Cabinet Ki nistere who c.

decided to c4ia;.,atcil t a o troo:?a e:.1d !' ie v i ows ·were :~ot S1.'.ch a a t o

oa·J.se ;11m ~o relinquish his o:Z:fice.

~. I a July 1941 a ··~ lar·. wns crontocl f or i.'ronch I·-do- Phina

a tlcl. t he o~loitation of its iie.t'.ll'e.l 'r oeourcoe , SUZ.iKI stated in his ' a..

crosa-elf.m!'lination that he unl~rstood that c Stationary ~CJnomic I

I nveetigatio:.i or gan was to be eatablia!·ed i n the J~a!'lese Oonsulatcl

a . V"-56. I n 19 ,1 t ho opinion

i n Je)e.n t ;1at aa lon_, as t .:e j ,1i t e<! Stato8' ref •.iaed to s ell Ja.?2.n needod

.,

commo( itiea J a:?a:i. '·'as co~·lelleC:. t o t ake by !'o::-ce of e.rme t?ic areas con

tainint, such resources. Wilen asked on crosa-e:iauni Mtio;-. '.f :·.e co .~.si<lered b.

s uch a refusal a ju.stificat i oi: fo:- a,~gresaivo "'ar, SlJZ:JKI r e:-:>lied that

undGr any 01rcumst£>:.1ce a aggressi ve war ,.,as wrong.

V'T- '.33 . b . T. 35,1g9 VV-55. e.. T. 3E, 301

VV-54. a . ir , 35,295 VV-56. a. T. 35 , 200 b . T~. 35,294 b. T. 35 ,300 c. T. 3E,295


.,,..

Page VV-17.

VV-57, I:l Au:,-..t.st 1941, :.e WP.B Ol'derecl by t he :.=irir'1e Mlnf•hr t~ · e .•

et~ three ::>roblerillt which it :.a eub:.:i tted are b dicative of

t he i m;?ortance of ·;;. :e ' ''Or!-: of t:-.e Pln•P~L'Jt; l302rd ,

(a) Can J e;?a·.:, :?rovic1e >.orae1·: wit :: :· eeded materials without

relyi~g ~on America1 or Britain? SUZUXI 1 s answ6r waa no.

(b) Supposing that the severance of economic relations wae

to coiltinue, would J e:;?an bo able t o stp.r d it for the duration?

~!is ansl'ter was t:1&t so long as no f urther s::iecial developn:ent occurred

in Je:pi}Jl~se.....American r elatioue, Japan coulc! rely upon her

ato~91lee, excepting :.1etroleum and a few other t ili:l8s, so that

.ia:-?r-.n might eec~..,e a coll83)&e f or a yoar and a halt or :::.>Ossibly

two years.

( c) Supposing that war 'broke out and J~'.?an euccce<iod in

ta.'ting the oil ~roducing aree.s of the ~;etherlands East Indies , would

JS'.·?an th8'n be able to obtdn t !lo ncodod ·?etroleum. He re:?orted

th.at immediate acquiaitio::. of t ; -.e :r.>etroleUJD would be impossible

because military occ~'_>ation would necussarily be attonded with

eer ious destruction.

~. I n order to further sho,1 that \"Br was be i ne.· p l a.r.r,.e tl

V~ld ~::repared S!JZUXI "1a8 cross-examined regatdbg oil well equipment.

lie ea~-e :ie first J..ieard of foe Arm.v E\llci ·:avy dismantling oil well

equip;nent to be taken Sou t h in t he middle of Awzuet J.941. ~e thinks

ta.at t~is was done wi th the t hougllt tilat t hore mie;ht possibly be a

war an~ vitil. t :·.e fu.rtil.er t~\oug!1t t~ie.t it might be vory useful to a.

e~loit t he oil fields of the aroas to be occ~iod.

VV-59. The atte~•tion of t ;1e '?ribunal is ~lso drawn to the

fact that SUZUKI too!<: ovor and rovieod the Five '!ear Pla·:. of his a,

predeo~aaor in office P'.OSEI~~O which :1as bee'1 described i n the

Genoral Sum:nation of t~o Prosecution.

a • . T. 35 ,200 VV-59. a • . T. 35 ,293

VV-5d. a • . T. 35,200-1


Pa.:;e ' .'V-18 .

vv..HJ. r..e •i!as also active in t >.e formuJ'.e.tion of other Pla:ls

which the ProRacution co:1t e nC:i- coul<l only :·ave = ~ad as t '.'.leir object

a. VV-61, The Traffic i.-:obilization Plan

was aunouncl')d in the p~ees as a plan t o ;?lace la··.d a 11d soa tre.a s-

:t!Or tation on a wartime bads t o meot t :-:.tl req_uircments of tile b.

times but S!YZUKI denied t!l8.t it wae a :plan il'l ·:;r~aration for war . c

Ti:e Workers Mobilization Plan • of 13 Se9tombor 1941. wae described

in the :ryress as & &ch ome, joi1~tly for mulated by t ho Planning :Soard

and t he welfare offica , bo.so<' o:~ t >.e emergency labour pol icy and

aimed at in~'.l!'ing t he st't"lpl y of B'Jific ie:1t l ebour for t~e incroased d.

~roductio:l of munit io~s . Again SiJZtJ'~I deni~d t hat this wns a war

p l an. ,

IY=.§.?.... I n adt!ition to t ho f.oro~oine; thA e.tte:1tion of tile a .

Tribune.l ie ~iroctot'i t o t ho Koy I ·.1dustTiu1> Control Ordinance of . b.

30 Aut,"J.&t 1941. •r;~e witno88 Li obert dasorib os t;11s as th~ most

awoepi-:-t; of all co .. :.tr ol o.-ca·.-.e.nces . It was to serve as a foundation

for t :ie COI119let'l co:1t .:-ol of All major indt\stries by the gover :unent. C .,

1 In ~~is affidavit oJZUKI points out t hat the outlines of this pla:-i

were formulated ~rior to h is assum:i;>tio~ of office as Pr~sideut of t he

Plan::ing Board; nevert~.eloss, t :10 law wae :._')assod duriY'.<:; :.~¥1 tenure of

offico,

VV-63, Attention is also C.ireetod to t ho l~?orial P6trolewn a. b.

Company Ordinan-::e :.;>a88od on 15 March 1941. As S"'t.JZ:JXI poi nts out

this waa beforn be assumed offico but tho company itself was orgai izod c .

on l Septen:b~r 1941 aftor >.e became Preaide·.it of th~ »oard.

---- •... - ----- - . --- - .- .. ------~

VV- 61. a . :r.:x. 113:5 , 'r •. 10 , ~ , b. T. 35,297 c. Ex. 1140, '· 10 , 228 e.. !r. 35,298

VV-62. -VV-63 . -

a. T. a,4r 3 b. T. 8,403 o. 11! . 35 . 240

a. 1 . 8,290 b. T. 3:: , .a41 c . 'R . 0.476


Pe(:,'8 VV-19

VV-64_., .Atte .tion is also drawn to t :.ie creatio·:;. oi t;le Sixt:t a..

Committee. ~llis Si~t:: 0o:nmittea \ ·Tas aet u_? S':ZUKI states 111

order to eu:pple:.1e .1t material •1e oeaaary for carrying on a war for

national self-defe·~ee agai"-let An1erioa, :9ritain a-.~d t:ie '.:Jet!1erlm1de

wJ:.ich mi&::t be u.navoio.able in view of t:1e sv.rroundi ng <?ircumstance.

1.i'he f u.nctio:1 oi t~.o com:nittae was to .. or~: o .. t ~la.rm fo r t ;·.e develo~

-nent, aoqni eiticm 2.nc~ contru:!. of 1·esources in t h3 SoutD.er ;1 Areas

wj:ic!l mi~:ht poeGibly te l' CCu::_:iot'.. 0 ::i 2 December 1941, "'h'C)n t~e

o:;>eni:~ oi :iostilities ·.l'.d bti~n decided u:'?on ~1£. Wl'.CJ orc~ered by t :-e

Frime .::t nister to c.ct as c··ai:..-ma>-: of t1le .Jmn'lli t t ee.

t! ••

VV- 65. The Regulations of the Sb:th 001.ur.ittee and its b.

on ::conomic Counter Flans for t;1e Sou t hern .Area e.re in

evide:·.ce, a~d are not discussed in dotail in this sl•.mmary. It is

quite ev ideat . that t he war o! "aelf-defen..e" oontem.:>lated the ac~•.uiei-

tion and exploitation of reflottroes on t !1e Southorn Areas which it was

planned to ooc~y.

VV-66, It is also to bA 'obsor.ved t :18t on several occasions

SOZUKI atte11ded meetings of t :·e Privr Council and t he Investigating

Committee of t~e Priv-3 Council b.

a, aa an e~lainifl8 :-:ember. I n ilia·

affidavit ~e states that the f unction of an o:cplainir-E; member is to

rnake et•.ch necessary e~lanation" as ma~ b~ or dered by t he 1:1nieter in

charge and t'.id .io t i !"clude t~e rig~1t to vote, ~~he matters ~iscuseed at

t !1e meeti.J8e in July 1941 were the conclueion of a protocol betweei1

Frat.oe and .:e: ... )a :1 with regar d to the dof~nee of French I ndo-China.

VV-64. a. 'l. 3 5,244

VV-65, a. 2::. 1331, 1. 11, 944 b. !:x. 1332,T... 11, 945

vv •. 66. - a , Ex. 649, T . 7069 ilx. 650, 'i' . 7074 ~x. 1241, T. 10,690 i x, 1267, T. ll,l06

b, v. 35,236


I I

~- ~_-_... __ _

PQ6e VV-20.

·-v- 67 L At t::e mec tir..s on 8 Deoem~)er 1941 t he "QpJ;l,IO~ SAll'.ADA

r epor t ed on t~·.e outbr eak of war againet America a ;1d X1ngl and and at

the meeting on 10 December 1941 the prO:?O&~l made by Japan to

Germa•1y a~ Ital y r egarding a no separate :-;ieace treaty was tho

subject under disc1J.asion.

VV-6B. It is um10cessary to em:i;>hasize the iurgortano'> of t;~oso

mcoti:"lgs at wh ich SUZUKI was :·;ir .::aont as an ex:9J.aining member .

a. VV-S9 . Mor eover, it vns SUZUKX who r eported to t ho

Emperor on 2S Septomber 1941, that if as a roault of war tho United

State• a~ould b e ~rovented from importing r ubber and tin from t~o

Sout~orn a.roe.a , it ~ould no t i.mply any vital blow aQ they might be

replaced by i1D9orts from South America and that large seal~ production

of artificial rubber would bo feasibl e in t h e United States •

VV-70 , •

It is t he conto~tion of t ho Prosecution that ,SUZUKl

vae active in r.aeiating in t he orgallization of the Greater Ea.at

Asia Ministry. He attended t:i.('I meeting of t:~.e Investigating Committee a.

ot the Privy Co-Qnoil on 9 Oc\eber 1942, as an explaini ng member b.

as he himself says on c~oa~-examination "to ole.rify t he yosition

of t ho Govornment " r egarding the measure . The evidence also e1A>wa

t~t at t~16 4th meeting of th~ Ctmmi ttee when asked i f there was a~ c .

i ntention of caangiug t he name of t :1e Ministry SUZUKI replied that

h v oonaiderod t~e name Greater East Asia Mi nistry proper because it

i~Hpoke straightforwardly the consistency of oetablishing Greater Zaet

Asi a and t!lat he had no intention of changi ng i t. On cross-examination . d.

h tt admit& that one of t l-.e mai n tasks of t !1ie new 11:inistry was to

oxploit t h o ;1atural reaouroe s in t >e oocuµied areas. On oroas-oxamination

VV-69 . a. ~. 35,242 - VV-71. a . Ex. 687, :T. 12, 070 b . ~. 35,247 o. Ex. 687, ~. 12,87t' 'd. T.-. 35, 319


' I \ . I t \ • j

I •I I

0

{VV-70) o. TOGO stated t :'le.t t ::..::. er-.}ation o:.' t h.:> : ·,.• · ?:i nistry ha<.1 ~).)v:-1

ple.r.nod by tho fo·xr Cabine t :'loard Prusidonta a :•d : ' ri&'lOi:i;>ally by t i'.c

Plannir-t; :':'oard •

• VV-?l. !L .. activities of t l: .• 1 PlAn "i &ig ::~oard ave been dealt wit!\

at s01,1c le~th in order to lonc'i eu:yport to the.} co11tcntion of the

Pr1eocutio11 that it vae a•1 im:,orte.nt organ in planni~ e.ril pr3'.?arin&

for aggraesiv:c war and in .)x:i?lOiting t ho a.roas to bo oocu.,.,iod e:•1d

that S"..;'Z".:XI • ae Proeid~nt of t :iat »oard and a Minister of State wae

act1Toly .... ne;agod in t he formula tion . an'4 execut~.on of such :i>lans e;id

proparatior~•.

4. LIA! so~ co:. l'Em;_ 'OES

VV-72, It ie now pro:?oee~ to doal with t~o Liaison Coufereno88

and th~ attitudo of SUZUKI irt reapeo~ ta tho matters v.~ich came. up ~or

diecussion at those conferences,

a. YY-73, SUZUKI statee that ab-:>ut the e·.1d of August the

Prime Hinietcr ordered :;.im to attend t he Lie.ieon Conference to rilS!ce

replies to c:.uesti,,ne r egardil'lg economic ::1r obl cmf', :iv vas told he vas .. to attonft aa Proaidj· t of trc Plam1ing »oard and Nae t -: b .:iar that in

mind "·£:.en asko.d to speak, SUZUKI intorp··cted t!1ie "to mean t: ~.a.t :.D was

to e.ttond as tlie t echnical aHistl'.''t of '·ho Prime Mi nister a11d to

retrain from &:i?eaking exc~t 'by or aor. or v.ith tho consent. of tho o.

Prime :·iil'listor, On orose-oxam·.nation ho stated t~\at by techi1ical

aaaieta:.it 11~ mea nt t :1at ~10 was t o r epl y to questio:.--.e on economic c.

~: roblems.

a . U-74, Ev e%_'?lainod t liat t a Liaison Confcrcaco wae not a

policy ~ ... oidi;15 bo~y existing ovl)r r n:: abovo t;u~, Cabbot but "1as a

VV-70 . a, '!. 35. 756 ~· a . 41'. 35,201 b. T, 35,202 o. .T .. 35,301

' V"-74. a. .'1 .• 35,203


~---

Page VV-22. (VV-74)°

mo et i~ co:wo·'.od wi t :1 a viv"T to rct>.C~\ing e.n undorata:~c~i••f: tiu'out;·h

an oxcile•l&O of viewa as bot weoa t~lC C:-ovorn""iJ'.lt i>.n<1 (loncral-->:-:aa.d-- ' b.

quartors. O·.: croes-c:r.:amination }'.e t>drnittoe t hat w:1en e. docisi" n

ltad boon roac::ed at a Liaison Confcro:ice t ::.oro was 11 ttle or no

c~1ango made in tlle.t ducision wh.: n it \·•.:i:1t bac)t to t ho Cabinet. As t ::o

?rim-l i:i nist\lr ve.s in attcndanco. generally s;?eeking, whatever :1ad

beon C'.iacustJod at t he Liaison Conf orctncc wae approved by the Ce.b i~ot.

~\fter t hJ ~·n.:: cf At'guet >.0 only at t onded such conf cr oncos as ho wae c.

orderoc°. t -, ettc·.-:.c!· by t~uJ ? rime : ;inietvr. but after t ;io oetablieh-

oent of t i'.3 'roJO Cai> i~et Liei91>n Conf . roncos werv :·ol d co·'.tinuously

up to t ::o .:::.1(~ of :."cvember anc°. · '> attoa1ded all of t hese conferences.

VV-7o, 1.rhe dafe·:id.ant TO~ was oroeetexamined with r egard to a.

c1 .

Liaison Oonf ~reucee anu stated that a numbor of t hose Oonferoncea

were .. ; old betweoa 23 October 1941 and 8 December 1941 a nd that those b.

~reeent . i~eluding SUZUKI, were active in accordance with t~eir ~utioa.

DuriJl6 th~ beginning of t l•e Liaison Conferenoee s:i-ZUKl wae one of t :!oao

OPJ?O'Sed t-:> t!le 11-·ithdrawal of Ja:?~meae tr00'9S from Chi na within e.

apoeifiel~ t ime limit. It wae upon tho t erms of pr o .. >osit ions A a r:d l3

t o negotiate ,,,i t h t!le uni tod S tatee • tilat t "-e views 1> ! t~o Liaieon

Oonf.:>ro;100 of l :.:ov,,mber 1941 were eplit into tvo. Tile argument we.e

a4.va·11eod. by one group,_ Which includod SUZUKI• that there l'!Oul<1 "be no

alter•lativo v:too··· .. t to ma.le" a decision on wer in tho ovent t !lat' t ho c.

pro·1oei tione were not accc-?ted.

'."V-76, T>.0 decisions ari•ivod at c1uring t ;·.o Liaison Cot1for .:no..: e

in :. ovomber have been fUlly coalt -.•1t ~1 in t ho C:.uiwreJ. Sum.'l!ary of t l'ic

Proeocution case . .Attontio r. is draw.! horv t o t h..: Lie.ison Co:lferenco

preeee.1-.1~ . t: • .., ll1r9orial Conf.:irane.'.3 of 5 : over.ibor, 1941, to tho Lie.ison

VV-74. b. T. 35,302 c. T. 35 ,303 c. . T-. 35,304'

VV-75. e.. :'l' .. 3 6,072 "b. ·T .. :56,074 c. T-. 36,062-3


I I I

,

(VV.:.76) a. Oonfvrence of 11 : ·ovembor 1941 when the dratt of t:1e "Pri:lci~~.

roaeons alleged f or the comme:acemont of ;,oetili tiee against t h.; v. s • .A. . b.

a;td :Bri tai11" "tas adopted; to the Liaison Conferenco of 13 i~ovember 1941,

when it was co".leidered vhat meaeurea would be taken 86ainst For ei&n

oountri:e• ae a roeul t of tho Imporial Oonfore .100 on 5 !Tov.;mber 1941; o.

to t~10 Liaison Conference of 20 :•:ovembor 1941, deciding ~on a

military administration f or occupiod territoriua; t o tho Liaison

Conference of 2? : ·ovembor 1941, ,.,:·.era there wae unanimous ngreemc!lt t o d.

wage war against the •.:;iited States; to tho Li aison Conferences of

the firet week in December when t ho ter?1s of t !•· Final >!otv trere

dieoueeed.

VV-77, It a;1ould be pointed out t hat in answer to counsel for a,

the accused TOGO, SUZUKI stated t iler o m~' ::ayo boon some Liaison

Oonferencee he attended and. some . 1e did not attend ootwoen l Dec.~ber

1941 and the outbreak of tho P ncifio War.

VV-78, It appears from :·.is evidence tilat STJZUKI is endeavoring

to minimize both t~o importance of these Liaioon Conferences and t~e

illl!>orte;1ce of the ~art that he ~layed at tht m; he dous this by

doecribing himself &8 a technical a881stant or <iered t o attend. and by

•~ing that the decisions of t he Liaison Oonforence wero not binding on

the Cabinet. VV-79 , It is submitted that evon if s::zux:t atte~dod t heae

Liaieon Conterences a8 President of t he Ple.nn1ng Board, that fact 1e

indicative of the importanco of th~ functions of that Board :?articularly

d\U'ing the mont:,.a immediately ~receding · t he outbreak of war. Aleo whether

or not the docision9 of the Liaison Conferences wore bindi~ upon t he

W-76 a , Ex. 1175, 'J .. 10,362 b. Ex. 1169, T. 10,332

Ex. 878, .T, 8,994 o, Ex. 877, T. 8,987 d. '"'J. 36,079

VV-77, e.. '1' ~ 35,332

- ·-~

\

'


(VV-79) P~o VV-24.

Oabinet, and it is submitted t~ult in pi·aetice t:~oy wore; it ir.uqt ;1o t

f · · bo f orgotten that throughout tho ~?~riod S'UZUKt wae atter.dir.g at..~h conferoncos !:o was a Membo:: of the Oabinot and fixed with t he

ree:9onsibilitia a of tile Minister of St~to . The defendant '20JO in hie a .

affidavit doscribes SUZUKI as one of those Cabinet Z.iinistors who

had a voice in t !10 Liaison Conf'urence.

5. '.l·HE !·iEETI:::G AT OGIKUBO 01f l? OCTOBER_}.9';11

YY-80. On l? October 1941 SUZUKI was :.1resent at a conf ereD.ce

at t~le ?rime Hinieter' s !)rivate r esidence at OGIKl!DO \tlhon t ile ~'far

Minister, t!!e ':.. 'ayy Minister and tho Minieter for Forei gn Affairs wore

also present. SUZUKI in yet anoth.Jr effort to show t he unil119ortant a.

part :10 plqed at this conf 13ronce stated t hP.t ho was proeont i'\8.ving

beon directed t o make a record of 1 ta proeoedi nge .

YY-81. On eroea-examination he was aeked if ha wore a more

aecretar~· at the meeting; l~e replied that he was not. Tho main

topic \·'8.e wilether or not to CO"ltinue nugotiations \dth America and in

connection \\'1th this the question of t h1:1 withdrawe.l of .Jailaneso troo:-:Js b.

from Ohlua also came up.

VV-a?, On t!~ is question there was a sharp difference of v i ews

betweer. t ile Primo Hiniater e.nd the War Minieter. a.

Tile ::•avy really

thought var Wit!l America was impOHiblo but did not desire to say so.

The Army di e not neceea~ily deeire war but vigorously objected to the b . .

Withdrawal of troops from 0:11na.

YY-83. a.

SUZUKI stated ' tha t he did not make any remark at t his

co~orenee. lie was busy taking noteo of what the othor Ministers woro

TV-79. a. T.36,266 VV-8?. a • . T. 35,205 - -- b. T,. 35, 206 !!:-!Q. a. T. 35 ,205

~. a. T,. 35,305 TV-81. a. T. 35 ,304 - b. T. 3 5,304


I

PS£;o VV-25.

'- · a. VV-84. In answer to counsel f or XIDO SUZUKI ate.tea t hat he

doee not know if t he Secretary of the Cabinet TOMITA was present in

another room but remembers t hat KIOO reoorde in his Diary that

~MITA visited ICIOO and gave him a roport of what transpired at the

meeting.

W'Mtever part SUZUKI ma,y have taken in the discussions

at Ogikubo, it is noteworthy that he wae invited to at t end by the

? r ime ?-iinieter and it ie submitted ie another indication of the fact

that he was one of those persons aotive in tho discussions leading up

to the outbreak of the Pacific War. Thie is borne out by the evidence

ot TOJO vho in his atfidavit stated a.

that t he purpose of the

meeting was an informal converention among the Ministers concerned with

regard to the pr ospects of t ho current American-Jspaneso nogotiations

ae well as the decision to be taken r egarding tho issue of peace vorsua

war.

6. 1'iiE FALL OF T?.E THIRD KQl!OYE . OA.Brn

VV-86, A portion of the affidavit of StJ'ZiJKI a .

is taken Up Yi th

an aocour.t of hie various visits to KOi~YE. XIOO, TOJO and HIGJ..sP:IXUl1I

in October 1941 immediately b~:torc t :!e resignation of the x01;o?E Oabinet. b.

He aqa that in this liaison-"!)tk ho acted strictly as a messenger.

Theae oonveraation9 are also fully report ed in a document entitled c.

•J'aote Portaini~ to the Resignation of tho Third XONOYE Cabinet" and <l.

in XIDOI e Diary.

a. YY-e7. lt also appears from SUZUKI' s affidavit that on 14

October 1941 XO~!OlE aekad J.lim to sound out t he War Minister as t,o his

•VV-84. a. ~. 35,252

VV-05. a. T. 36,299 -a.~' 35,203-213 b. T.., • 35, 243 c . Ex. 1148, T.10, 250 d. Ex • . 1149, J • 10,274

Ex. 1150, T• 10,275 Ex. 1151; !l'. io, 281

~. a. It 35, 208

'


(VV-87) Page VV-26.

Y1eva on tho diApoaition of t ho political eiti.l&tion after X01''0YE1 a

Cabinet reeigued. TOJO told SUZUKI that he belieTed that no one b.

but Prince lllGASHIKUNl could eave t:1e situation. Late that evening

SUZUKI comoyed thie to KOi.;OYE who was greatly elatod snd asked him

to convoy tho views of TOJO and himself to KIDO.

a. VV-68, On th~ following mornin&, 15 October. S"J ZUKI called

on KllX> who aaid it was not customary to install a momber of the

Imperial family ae the hoad of a Cabinet and that thore seeoed to be a

gro\l'l ·f r.'.On. in the ~rq who would make thoir wa~ into var under t ::iu

leadwrahip of HIGASHll"JKI s o he (XIDO) would thin: it 0ver carefully.

I VV-89 ~ SUZUKI reported thie to X:Ol~O~ and a littlo later

XlDO tolO:?honed and SUZUil want to see him. KIDQ asked him to go to

the ~·Tar Minister and ask if l:'.e can hold down t he t>-rut:f' s ,,ar faction a.

if HIGASHIKUl-!1 hoada the governmen\ and doc idea against war.

VV-90. He 1aw 'IOJO who 8aid if HIGASlalCUNI heeds the government

and docidee on a no war policy ar"1 if it oaniiot chock the Army, under

whote Premiership can it bo checked. TOJO could no-t say then· whethor /

or not it could be chocked.

VV-91, SUZUXI conveyed this to XIDO and early ·tho next day he -

Yaa oaJ.lfUi by lCO!-.'OYE to aeo HIGAS".dIKUliI and i "lform hill as to the a.

nation• a strength. He told HIGASHIKUl11 that J ape.n wl!le not aufficiontly

etrong to go t o war. He renortod to XIDO what had. tiranSPired since - -t ho previous ~ and that afternoon XO~!OYE told SUZUlq tha.t it had been

decided not to aekHIGASHIKUltt to head a govornment and th,at tho Cabinet

would resign.

'

o.

YY-87. b. T ... 35,209

ffr8&.~ a. ~T~ 35,210

. VV-89 , a • . T- 35 ,21Q

~ a. ~ 35,21.l. b. T,. :!5,307 c. T. 35 , 212

'

•


a. lu ~is croes-exemination SUZUK! stated t~At a~~ut

the timo of t ho fall of the Third XONOYE Cabinet he went to see EIDO

and told him t ho only w~ to suppreBB the attitude o~ t he Army was to

have the Emperor stato that ho did not want a war. SUZUX! :.-omomb~>~e

that ICIOO die! not agree with his viev1.

a. VV-93, • He wae oross-ex~ined on this oonvoraati :>n by ·.;ounsel

tor KI:OO . and stated that ?ie tho~t that the conversation was on 13 •

October 1941, and that XIDO had a~i~ t hat ~erhe.,:ls in the final analysis

1 t might be neceaeary to petition t he Empero:- for hie influence but t :iat b.

it wa1 not yet the proper timo. SUZU'A:I s~s ho made the arune

•U&geetion to XOKOYE who aaid it "'Ould be necessary to obtain the agree

ment of t~e War, ·:::avy and Foreign Affairs Ministers a~d if such an agree

ment were obtained, it would be no JDA.tter at all to petition the

impero1· and asked SUZUD, firet ot all, to obtain the opinion of !i.'l()JO. I

After meet1ll8 the War Hinieter, it wa1 found that the mathr was diffict'lt o.

and it was t!J.en that he spoke to KIDO about the matter.

VV-94. 'l'he Prosecution attaches i1D.9ortance to t ho e.ctivities of

SUZUJtI in this period immediately preceding the tall of t he ~hird XO~.qQYJi':

Cabinet becauae it 1e made clear that SUZUKI wae busily eng~d in the

political manoeuvrea of t!le day and had an i ntimate knowled8e posaened

b7 few peO"_?le ot what wae going on behind tho scenes in J~~anoee politics

leading to th~ formation of the TOJO Cabinet.

YY-9?. a. T. 35,305

YY-93. a. T. 35,326 b, T. 35,327 c. T. 35,328


Page VV-28.

a . VV-95. When SUZUKI was i i'lformod by KOrfOY.E that ~WO would

form a Ce.binet KOr!OYE went on to BS\Y that he believed the.t TOJO would

oheck the war faction and proceed with the American negotietions and

when asked by TOJO to conUnue in his office ho consented in con-

tormity with the advi~e of Ko:ron.

} a. VV-96, He ";as crose-examined as to ' 'ht1t!1er he thought the.t

T0.!0 would bo able to check the wa:r faction; he r e-:_1lied that TOJO him-

eelf did not necessaT11y seem to advocate war on his own but there was

1ome hidden power pushing this war agitation. At this time the }.rfD3

was urgin& war.

a. I

VV-97, Upon becoIJ1ng Primo ?Iinister TOJO told SUZUKI that it

was hie · desire t!lat SUZU'J{I concentrate his energy on the work o!

• eoonomid mobilization and not to me4dle in political affairs.

a. VV-98, Two questions were :!)Ut to SUZTJKI by TOJO -

(1) If .the American.-Ja~anese negotiations shouln bo brokun off

end no prospect exists for th~ t er minationof the economic severance,

to what ext9nt may JapE'n i:r.aintain her ou,r.'})ly of commoditieo.

YY-99 . SUZUKI answered t;1at whilo t her o would l:e somo increaee

in the steel pro~uced there \·•ould be a decrease in commodities t'rom

Thailand and Indo-Ohina because Amcirioan and :Sri tish interference must

be expected, and further that the prospect was anyt>.ing but bright in

respect of ~mmo~ltios to bo imported from the United States, Groat

J3ritain and the Netherlands , especially in the case of petrol eum. The a.

manufacture of artifiuial petrol eum could not meot the ~..rgent needs. \

VV-95. n. T. 35,213 VV-98. a. T • 35,215

VV- 96. a. '1' . 35,30~ VV-99, a. '!' • 35,217

VV-97 1 a. 'l' . 35,214


Page VV-29. l

VV-100. (II) If Ja~en should succeod in the event of war in

occupying the natural resources zones in the Southern Regions without

serious damage• how far could self-supply be expected?

VV-101. SUZUKI ane\·tered that ehipplng would be difficult, the

supply of steel would diminish and impor~G from Fronch l udo-China and

Thailand, parti.}ularly rico, would be r educed. Kith roga.rd to inq>orte

trou the Southern regions an Ostlm~t.e oould not ta rr.a~e by the Planning

Board but accox-ding to the etudic.s made l:y the J.J-m:y a~d Ne.vy

Ministries tae petroleum obta~n~b~e in the f !rat year would approximate

300,000 tone and in the second year would approximate 2,000,00~ tone

provided that the Scn1thern Areas could be occ::upied after the outbreak ot a.

war.

a. VV-102,_ SUZUKI states in his affidavit that the policy of .

· TOJO to bring about the eucoaseful conclusion of tho A.merican-Ja!>Sneee

negotiations was concretely cani.fertad in t.ho dt.c!aion of the Imperial

Conference 5 l~ovt>mber 1941 whi:::h decided to withdraw the ar.med forces I

from China to make the negotiations auco~asful.

YY-103. Furt~1e:r:mor .: , the condit ions for conducting the

negotiations were more fevorable t han at the time of the KO::OYE Cabinet

by the recognition of the withdrawal of troops which had been vigorously

opposed by t he .Army. Y.oreovcr, the troopa which r.ad edvanced into

Southern Indo-Ohine. were to be withdrawn.

a . VV-104. The fact is, it ie uubmi~tad, t hat the docision· to with.-

draw the troops :t'>:cn China made at the Imperial Oon:tore!lce on 6 lTovembor

1941 did not contemplate an immediate or complete withdrawal. It was

VV-101, a. T. 35,218-9

VV-102. a. T. 35,220

YY-104. a . Zx. 779, T. 7, 904


(VV-104) decided that

P~e VV-30.

"among th~ Jayaneae troops deayatohed to Ohina for

the disposal of the Chineso I~oident , those in the

designated areas in ::rorth Chinn. and Mongolia and on

Hainan Island will be stationed thore for a neoeosary

term after the e&tabliahmont of peace between uapan and China.

Simultaneously with the oetal..lieh.r.ent of pear.;e, we shall

commoncc to withdraw t he r est acoordi:ig to a se;>a.:·a.te ag:.·ee-

ment between Jo.pan and China., and with the establishment of

public order this will be completed within two years." ·

A note appended thereto states that 11 If the Unit~d States

should ~aka an inquiry as t o the necessary term, it will be .

replied that our aim \·Till bo approximat ely 25 years. n

YV-105, .\:ii th r ega1·d to the wi thdrawo.l of troops from .French a.

Indo-Ohina tho decision was .

"That the Japanese troo9s uow despatched t o French In,0:...China

will be ":ri thCA.rawn immediately a:!'ter the settlement of the China

Incidc.nt, or after an impartial pee.en •·rill have been established

in the Par East."

a. VV-106. On orosc-exami nation when informed that the

deoieion was that the::e vould be no withdrawal until peace betv.een

China and J apan had been come t o, ~e r aplied t!'lat Ae thought peace and

the "1 thdro:wal of troops are one and the same thi ng,

a . VV-107. He stat ed further on cross-examination that he did

hear that a decision to withdraw the arm~d forces from Ohina to mak~

·vv-105. a. Ex. 779; T. 7,904

IV-106, a. T. 35,312

YY-107, "• T. 35, 310

j


P&&e VV-31.

CVV-107) the negotiations suooeesf'ul had certain qu.alifioRtions attaching to

'· that Yithdrawal but it was also decided that, d8!)end.ins on the

progrees ot the J~anee~erican negotiations, t hooe conditions

o~d be changed.

YY-108, The Proceculiion su":>mi ts tlu>.t t he • illingneOB ot SUZUXI

to serve in the TOJO Cabinet leada to• t ha i~resistible conclusion that

he was willi118 to plunge Japan into war, a conclusion which is s~orted

b7 his subsequent co~duct,

!L~fl.!MP~i: !\li_ co:..~r;~·cras. - .

VV-109, Wbatevor doubt may oxiet as to SUZ"Ui=Ifs attendance at

the Imperial Oonfe1•ence of 2 July 1941, ho does not deey that he

attended the Imperial O~n.forence of 6 S~9to~ber 1941, 5 November 1941, and a,

l December 1941. The decisions mede at those Oonferencos have been

fully diecuaeed in the Gennral Sumn:ary of t1'e case for the :Prosecution,

It ii ono"8h to e~ that SUZUKI cannot OB"8:90 from assuming his she.re ;

ot the re8!)oneibil1ty attaohing to the decision made at t hose Oonforencee b,

whioh includes the decision for wa» on l December 1941, '

9. TliE DECISION FOR WA.~.

VV-110. SUZUKI states t !:at tho determination t o conti:'lue the

JapaneeG-\mOJ"ioan d~gotiations was nullified by tho }.merican re:!>ly of

26 :;ovomber. He heard tho Forei&n ~·:inister explain thnt the reply was

tantamount to an ultimatum e~d beill8 told that it constituted virtually

an ultimatum he could not but sens e that war with America might .be un-a.

avoidable,

VV-109. a, ::x. 1107, .T. 10 , 140 !r. 35,236

b. !r. 36,080

YI-110. a. 1!. 35,223

\

1


Page VV-32.

VV-111. He was directod, he states, t~ attend . •he confe~enco

between the government and Senior Statosmon .on 29 :·ovember and to

an1wer such questions as ;Jligl~t be :9Ut to the government regarding a.

national economic strength. Ho was e.slced quoetions by Admiral

OKADA regarding shipbuilding c~~acity and nirplane ~roduction and by b,

another questioner regarding tho stnpl" of steel.

VV-112. SUZUKI attended t ho mcetin.~ of t 11e Cabinet on l December

before the Impo:riel Conference t·thfl n TOJC sa id t hat war with America

waa unavoidable and the ..'trmy e.nd :~avy will turn to war operations.

However TOJO stated, as related by S'JZUK!, ~fhen t·'e aee a definite

chance for sucoeae in nogotiations, the wr..r operations will be

immediately sus, ended and tile t;overnment trill turn to negotiatians.

' . _·VV-113. SUZUKI egroed ~ith the decision believing that this

a. was unavoidable as lone; ne Japan had an .d.merican ultimatum.

a. VV-114. The Imperinl R&acri~t for war was signed by st1ZUKI

b. who stated that )it \·1as CC3rt ainly not w~at he desired but he thol.J8ht

tba1( t~1e opening of h"stilities was une.voidable for defensive. pur~ f

posea so long aa ' an ulti~atum h~d alr eady been deliv0red and J~~e.n

waa placed in a position liable t o be militaril~· attacked at ~ moment.

a. VV-115, Ee states in hie affidnvit that via-~vie G-ree.t

Britain and the United States, l'!h ioh he regarded o.e militarily one

and inseparable, he was c1vinced that J el)an should keey on the moat

friendly terms and that J e!_.,an ehouJ.d never make them an ene~ unless

indeed Jgpan vaa militarily attaokod or pl~oed under an i mmediate

menaoe of attack,

VV-111. a. T, 35,223 b •. T. 35,224

VV-113, a. T. 35,225

VV-114, a. Ex. 1240, T. 10,685 b ~ ·T. 35,246

,

VV-115. e. \1" .Z5iJ.90

\


P88e VV-33.

YY-116. mien asked on cross-examiilation where he expected to a.

be attacked he replied that they did not kno· · ~·1liere but at the

time Japan' a national economy ::.ad been seriously disrupted and hearing

that Japan had been given an ultimatum, he felt tr.ey could not be

sure when they would be attacked.

a .. VV-117, S"Jt.UKI so.ye that the ffonl. note t o Amer lee. was not

diacuaaed at any Liaison Conference or Cabinet mCJe ting that he attended.

He nover knew about any note being ne~t; ho did not sign it and did

not know its conients until after it was deliver ed.

a, VV-1~ He goes on to say that once the decision that war

was unavoidable had been reached, all these mor e or less technical I

matters were left to the Foreign M:l.nit-Jter to do on his own responsibility

in such a v.ay that all pr0ce~dings would be ln accordance with Intor-

national Law ond. thG1·efo:-e he did not !lave muc.h interest in these matters.

a.. VV-119£ When askGd on cross-examination what took place with

respect to a note to Great :Sr:l tain he ee.id that he felt t.t.at even to

the United K:!.ngd.om a note would natu:-all y be se?".t e.nd if such a note

were not sent th~re would be ample i·eason why it ttas not. The:-ef'o:re, he

did not ooncel'n himself ~ith it.

a. VV-120. He sqs that he does not knot' why no note we.a sent to

the United Kingdom., He recalls very faintly that a f t or the outbreak of .

war this matter came up for diacuo3ion and tho Foreign Minister e~laint*d ,

that dnoe Great :Sri tain was one with tho United Ste.tea the!'e was no

neoeaeity to send such a note because the note would bo automatically

made known to Great Britain.

VV-116. a. ~. 35,313

VV-117, e. T. 35,315

VV-ll8. a, T. 35,315

vv ... 119. a. ~. 36,315

VV--J20. a. T. 35,316


VV-121. ·.;:e admitted that he knew that "-r oat Britain was E'.

1ovoreign state nnd >ad an ambassador in Tokyo and Ja·>l'n h ad an

ambaHador in London but he hed no i nt erdet whatsoever i n such

mat ters and did not concern himsel f with it.

a. VV-122. He add.:-d that after he.vin~ hoard r.11 tito evHenco

that has beea p:-4'1::i• nt ad on this mat~er befor o the Tri"c'\1 '1..l} . ho

telt that from !lis own pobt of v10w ;1e would cer~ain: . .Y ha··l'1? s ent

a note to Great Brita.in.

a . YY-123. On cross-e~ami no. t ion S:J3UKI d.~nied t hat he knew the

hour, place or dP.t::: for openi ng hoetl:H';iP'J or that the t ask force

had sailed tor P ea:r:: :t!:ir.bc-r . The fi rs t t i .!le he l uru' .r\ed of t he

attack vaa on the ~orntng of Dece~tor a. F.o h~d ,one at 6;30 a.m.

to t}?-e Cabinot o!~~"° !.o ul;ton~ a Cab1.net m<Jt t ~ng and was t hen told

b7 the Ohief Seer:? ii ;....r:r, ::>i t}~u Cc:b~, r. Elt F:OS!:H.O t1nr1. l <.'ur "led f or the ·o.

tiret time thnt hn.;tU:.ti.Cl~ hu'i M'llil1 ~no1-1d . It \"M ~t'ter tho con-·-.

ol~eion ot the· ~.-1~· 3 ~ sunfl nr icio;1 th&.'.; t '.1e lTavy !H.i1 ~. c+o:-: st\id some-... t hing to t he effe~t t,~";"-foe '!'i i;a-:, hnd i.;ailod :i::io or t wo wro'rn before

t he commencomttnt c:f h·>ot: ~ l.i t.iurt but he is not to\> sure \ 1hat wc.s ~ .

aotuall~ ea.id t o him.

!!::124. Whether or not , owins to hie di eint GrP.at , s;z~EI v.as un-

avare of the co1:tc11ta of t he fi;1al. no te t o t lle :ini ;,r.£:. 5 t,.!:.) t-, c l." of t~e

Prosecution au'.Jmi~ e that he ca:mot G~c~po ~eB;>on6~i~.~ 1.;r fo~ the

deoieion to wege an fV-;grr sai ve -war con~;·;;.l'y ~<• t he "?'·'i "lOi::;>l ee of

Internatione.J. 1P-w. R~s c.x;,ila~10.tion ! 0 1• tho f a ilure to notify the

TV-122. a. T. ~5, ::Sl7

!!-J.ro. a. T. 3~. ~<14 b. T, ., --;) ~' ·35 o. 'l' . ~s ~~14

. I


. \ 1

\ I

\

Pago VV-35 •

(VV-124) United Kingdom of the conmcncemont of ~ostilitios is , in tho sub-

mission of t he Prosecution, unworthy of cof1sideration.

10. PRI SO~".'£RS OF W.A:R . - C""T:"

a . VV-125 . In ~is affi~avit S: .Z~7.I r ef ers to a ?rosecuti0~ Docu.~ent .

Thie documc:lt entitled 11The ~mployment of \far Prisoners" is contained

i n tho Foreign Affairs t·iontbly : .e:i?or t of S<'ptombor 1942, and was

published by the Foreign Section of tho Poli ce 3uroau of t~e ?.ome

Ministry.

VV- 126, Thf' De.f ence witness Wi.~:,\!;.\ , a Director in tho ?J.anning

a. 3oard states that the meeting roferre~ t~ in t ne do cument was not \

hold under t he auspices of t :1e Pl~nning Board b·:.t under tile a.ue:9i ces

of the P . O.W. Information 3 ·._ir eau for which purpose the Planning :Soerd b .

merely lent its conference ro~m. SUZU!~I in hie aff idavit supports t his

conte:iti on and. goes on to nay t !".at t r.e Plannin·;; :Soard ~.ad not tho

slightest authori~y concerning the tree.tment of P .O .~·' . a.

VV-127, J'm 1>xaminati'>n of t " e documeat itsel f discloses that at

the 1 conference cortain principles were disc•.leeed and decided upon among

them being, that P.O.W. a:1oll be t r ensf £;rrod to .Ja}an t o mitigate the

labor s~ortage and ~o c2rr1 out eyeciPi inr2or~e~t work • . Of t he

i ndustries in tho ~ational Mobilization P lan, war prisoners shall be

employed f e r mining, stevedoring an~ engi neering and construction wor~

for rtationa.l def ence . F or tho time bei ng war !)risonere shall be

elll'J?loyed in stevedoring i :1 i~9orte.nt porte.

YV- 128, The document also refers to the fact t hat P . a . W. have been

employed in Je.pan f or stevedori ng to s~eod up t he t ransportati on of

materials in wartime with satisfactory r esults.

VV-125. a . Ex. 1971.A, '! . 14, 505

VV-126. a . T. 35,164 b. T. 35,247

VV-127. a . Ex. 19'11-1\., T. 14,505


'

?t\6e VV-36.

e.. VV-129~ On croes-exe.mination , S'"uZU"lI admitted that the

Planni11€ ]loard !:ad "' thor i t v over ana was ooncsrned •·'1th t)le •"'-'ll'l Y of

and tho demand f or, l abor in J e;)a.1. In part that ).abor po>·er waa

•um>lsms \lted by P • 0. W. T~e J.abor of t '.1s : • 0 . W. was not lioit•d, h•

ea~•, to ~'to tranw~ortation of munition• olon• but was utilh•d for b.

the pUX'")oee of facilitating trnns:1ortatiCTn genexe.lly,

!J:l3o. Tho ?Toaocuti •n sub,ui\• that whil• the Ha1ming :Soard

.. it did authority over t:>e aw.>Pl!' ond de\i\f'.nd• of · c.bor in Je.~e...,, tho lloard must """'"'"it• shar• of the ,..,onol.btlity for t he •"'110"

meut of var !)riooncra on work tlircctly connected '11th th• proaeeution

of the var e.nd contra!'y to tt.e l-"86\'.e Conve·l\tion. a.

to the Germnn VI:l31. On 17 1'~~, 1942, Ott reoommonded

Government that certain •apones• be decorated •'.ho !»VB mad• important

oontribution• to (lerm-..Ja:>an••e coopsrntion and to the j oint

veging of var _and vho at t he ••""• ti"• occupy key positioll8 i n th•

Japaneee .\rmy or Government . ,\11\ong those so ree JJlUllOnded VB8 SUZU!Uo

who ...., deacrib•d aa controlling eoonomie pla•r .• i n& i n .;ape.n e.a ...,11

e.a t he organi•ation and adm\niotr~ti·te oonot.ruution in the aout1"'rn

territoriea.

• · f'!-13,~ On the strength of thia g-tee.t authority, Ott cont1.nueo,

hie connection with t l:.s ;.smy and hi• pareonnl relation• with 'l'OJO ,and

SUZUKI, ha• oreat•d a position for him•slf that can be labeisd .. a

/

I

kind of Vic• c;,,,neellorehi!>· Thi• i• ahovn by hi• ordOr of rank in

th• Cabin• ' at official function• and al though he wB.s formerly

ambiguOu• in hi• attitude t;,..,araa oor""""Y• SUZUKI llaB eopeeiallY

---------------- -----.--···.--.- ---------VV-129. a. T. 35,319

b. ~. 35,220

IY-131. a. LX. 1272, T. 11, 353


(VV-132) recently &"I"t'lc,t'ted cooyeration 'l'i th Ger ma1.y and hAd an im,ortant

share in th3 de~ision of Ja7au1s er.try i~to t he war.

a. VV-133; In his affidavit SUZUKI sto.tes that he never knew

that Ae waff called Vice Ch~ncellor, that the or der of r nnk at

official. events was determined by court !>rooedure and. that thC>re was

no sped.al , ersonnl. i:'ltbac~' betwoen TOJO e.nd h1'nsolf s1J.ch t\S r.ad

existed betw9en KO~~OS ai1d nhself. Ee declined t he i nvi t e.tion to

the investiture.

a. VV-134. SUZUKI was decorated by t be ~ a,anese Government for l'.ie

eervioes in the 1-ianchurian Incident and f or hie services in the China

I ncident. In jlis a ffidavit he state SJ t hat t:r.ese decorations \'•ere

conferred on all Colonels and r~njor--GeneraJ. e in active service v•i th-

out eny s:r>ecial merit.

n. IV-135. At the request of TOJO he l eft the Ce.biret nnd

reeie;ned t he ?reeidfucy of the Planning :Board on 8 October 1943. '

VV-136, Prior to this in April ~943 ho had been appointed

J~inistrative Inspector, his duties being to ensure t :;at producti?n

increases were me.de by i '1e) ecting the vad oue facto:o.·ieo a nd co·1ditione

in them and to take the ste~s neces~ary to i ncrease J r oductiou,

a . VV-137, I n December 1943 he wae ~9pointed Br.ouomic .\dviser '

to the Cabinet and in September 1944 Chief of t hA Gre~t j i Dp0n

In1uetry Patriotic Association,

VV-13~ . a. T, 35,2~-8-9 VV-136. a. ~. 35, 322

,"V-137, a. T, 35,323

VV-135, a. T. 35,323


Page VV-3a.

VV-138. To sum up, it is submitted that the Defendant SUZUKI

1e guilty 88 charged under the conspiracy lounta l to 5, inclusive,

of the Indictment. It has been shown in evidence that 88 early a8

1932 he participated in the overall cons~iracy charged in Count .1

and the evidence of his subsequent activities as 8 member of the

»ureau of Military Affairs, as Chief of the Political Section of the

China Affairs »oard, as President of the Planning ::aoard and as a

Cablnet Minister ma<:es it clear that ~1e is also guilty under Counts

4 and 5. In addition, the evidence of his aotiviti"e in China

eatablbhee hie guilt under ~"lt'lh 2 a :i 7 ir. r ee :eot of c?ntniraciee

relating to China.

VV-1'39. Counts 6 to 17, incluai~e, of the Indictment relate to

the planning and preparation for aggreeeive war. It is submitted that

being 8 Def end~nt who joined the overall coat13>iracy as early as 1932,

and 88 hie subsequent actions show did not withdraw from the con-

epiracy, he is guilty of all planning and ~reparing for war eubee~uent

to that date .. and is gu.il ty under all of the Counts 6 t o 17 inclusive.

In ad.di tion to planning and prO!'aring this overall ~rogram for

aggreeeive war there is direct evidence that as President of the

Planning »oard and a Cabinet i·~inister, SUZTJKI planned and prepared the

&ggreeeive ware referred to in Counts 6 to 17, inclusive, and is guil~

ae charged under those counts.

Oounte 18 to 26, inclusive, r~late t o initiating aggressi"? ware.

SUZUKI i8 not charged under Counts 18 and 23 of this group. It ie ...

aubmitted that there is direct evidence that SUZUKI is guilty of

initiating t he war of ~gression aa charged under Counts 20, 21, 22 and

24 and that in addition he is guilty as charged under Counts 19, 25 and ·

26 aa an accomplice instigator and 8CCeBBory by reason of hie guilt in


I

\

..

planniJl8 and !)reparint; the ~·are of aggression referred to in t he

said Oounte 19, 25 and 26.

It ie alao submitted that the evidence of t he activities of

SUZUKI in the appointments end offices held by him and referred to

above, show SUZUKI to be guilty of wagii'lg 96gressive war Wlder

Oounta ?fl to 32, inclusive, a nd Cnunts 34 to 36, inclusive.

Taia Defendant ie not chnrgcd under Count 33. In addition he i'8

guilty under Counts 28 to 32 and 34 to 36 because the evidence

referred to in t~ose counts.

The Defendant ~JZUKI is charged under Counts 37 to 47, inclusive,

·· · c\ ~· t~ntf' 61 t · ~. 5?. of the offe11ces contained in Gro\t!) II. of the

I nc.iot.11e .t ralflti•·.~ t o . 'i.•.rder. It '.. fl eubmi tted that being a Oabiuet

Minister during a : ltt.rt ·f ~~=e ex-ii) : " P. ~r. ~.or.ci·~ in t :· : count, SUZUKI

ie guilty under the conspiracy Counh 37 and 38 which therefore

eatabliehea hie guilt under Counts 39 to 43, inclusive. With regard

to the remaining counts in this group with which SUZUKI is charged,

i.e., Counts 45 to 47, i nclusive, and 51 and 52, it is submitted that

the Defendant ia guilty as charged under these counts by reason of the

f aot t hat the evidence establishes that he was a person who planned

and prepared t o commit t he offences c."larged under those counts.

The remaining counts in t~e Inclictment 54 end 65 are contained in

Group III and relate to conventional war crimes and crimes against . . humanity. :·.:t.Ue there ie no evidence that the Jiefendant S'JZ'JKt wae

directly concerned with the treatment of ~risonera of var, it ia

submitted that ) rieonera of war are in the po~er of the hostile

government and not of the individual• who capture t!lem and their

h


\

F '1?;~ ' t 'f -·~:I •

treatment becomes the responsibility of t~u1.t govornraent a .id the

Ministers of State ,m.o comprise that Government, which includes the

Defendant SUZUKI. It is also submitted as a Minister of State in

the Japanese Cabinet ho is guilty of tho conspiracy charged under

Count 54 and with r~sponsibility for the violation of the l aws of

var ae charged under Count 55. Ho has an additional r esponsibil ity

in that as i:las been shown by tho evidence , the Plan:1i ng Board at

the time the Defendant SUZUKI was President wae instrumental i n

allocat~ng prisoners of war to work which was directly connected with

the operation of the war. In t ho r csul t', 1 t is submit t od that t he

Defendant SUZUKI is guilty as charged.

I £ '

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Documents

a. ~. 35, rn.::a