Between May 15-16, 2020, the International Conference on Law, European Studies and International Relations took place in Bucharest with the theme “Romanian Law 30 years after the collapse of communism”.
Apart from a total embargo of the "free" press in Romania on this brand event that condemns communism, security and justice in Romania so far - I have only discovered a book in English that deals extensively with this topic:
“Romanian law, 30 years after the collapse of communism”.
In this book we drew attention to the work "Crimes against humanity committed by Romanian state officials in the communist era and ignored by justice", a complex work designed by one of the most professional prosecutors in Romania, Magistrate Vasile Doana.
The work confirms the revelations of the Incisiv de Prahova newspaper regarding the “Revolution”, “Mineriadei” files, the “Sibiu” file, etc., treated extensively and professionally by our editorial office.
We give you this exceptional work. (Ec Adrian Radu).
Thus far, Romanian justice has not initiated investigations to hold accountable those responsible for committing crimes against humanity during the communist period, thus being able to state that, on this matter, I.V.Stalin’s principle still applies, respectively: “The death of a man is a tragedy but the death of a million people is a mere statistic“.
Keywords: crimes against humanity, the forcibly displaced, deportees, persons who illegally crossed the border, peasantry repression.
On 01.02.2014 the New Penal Code entered into force, which incriminates, in Title XII, “Crimes of genocide, against humanity and of war”, to be specified that in chapter I of this title, art. 438-439, the crimes of genocide and against humanity are foreseen, both criminal acts having imprescribtible character; the two offences were for the first time provided for by the Statute of the International Criminal Court of Nurnberg and subsequently legislated by international conventions to which Romania adhered , thus introducing its two offences into the national criminal law.
The crime of genocide has been incriminated in the Romanian criminal law, from 1960 until now , under the same title, while crimes against humanity  have been consecrated under this title only since 01.02.2014, with the specification that these have existed previously in the Romanian criminal law but under another title, respectively that of “inhumane treatments”, provided for by art.358 of the Old Penal Code, 1968, mentioning that the constitutive content of the two acts is the same.
For this reason, the High Court of Cassation and Justice has recently pronounced, the final conviction in the files of former penitenciary commanders, generically referred to as the “files of the torturers”, defendants Vișinescu Alexandru  and Ficior Ion , both were sent to trial for crimes against humanity, even though the acts held against them were committed between 1959-1963. The Supreme Court has ascertained the existence of the continuity of incrimination for this type of acts, from the date of their perpetration until the present moment, but made the application of art.5 Penal Procedural Code, which enshrined the principle “mitior lex”, thus applying the most favorable law to the defendants, identified by the supreme court as being the Penal Code of 1968.
Arising from the text of the genocide crime is the legislator’s intention to protect, both during time of peace and during war, entire segments of the population against manslaughter, physical and mental injury, preventing births, submission to conditions of existence which are likely to lead to physical destruction of certain ethnic, religious, racial or national groups.
In the case of crimes against humanity, the legislator protects the civilian population in the event of a generalised and systematic attack aimed against them, during which a series of acts are committed, such as: manslaughter; deportation or forced transfer, with the violation of the general rules of international law, of persons legally present in a given territory, by expelling them to another state or to another territory or by using other measures of constraint; imprisonment or other form of deprivation of liberty in violation of the general rules of international law.
In current regulation, the texts of the two international crimes have been taken up, in the romanian criminal law, from the provisions of the Statute of the International Criminal Court.
The efforts made from 1990 until now by the romanian judicial bodies to investigate criminal cases regarding the commission of these imprescriptible crimes, have a sporadic character, being located in time (except for the files of the Ceausescu couple, of Nicu Ceausescu and the case in which the former members of the Executive Political Committee of the Romanian Communist Party were convicted, all these files being dealt with in the early 1990’s ), only after the appearance of the New Penal Code.
This sporadic character is due to the fact that, until now, starting from 01.02.2014 only six criminal cases bearing as subject crimes against humanity, were investigated and prosecuted, as follows: the cases regarding former penitentiary commanders, Vișinescu Alexandru, Ficior Ion, Petrescu Marian; the files named generically, “The Mining File of 13-15 June 1990”, and “The Revolution File”, as well as the criminal file drawn up by the security officers who investigated the dissident, Gheorghe Ursu.
In fact, the judicial bodies had the legal obligation to perform, besides these six cases, the investigation of all the criminal acts generically called “Crimes of Communism”, as long as they are imprescriptible and the estimated number of victims is two million people .
In antithesis with this almost general state of “non-combat” of the Romanian justice, the Polish justice instrumentalised around 22,000 criminal cases which had as object the crimes of genocide but also against humanity, generically also called in Poland “crimes of communism” .
Coming back to the political efforts made in Romania regarding the official recognition of the existence of crimes in the communist period, in 2006 the Presidential Commission for the analysis of dictatorship in Romania prepared a Final Report which was presented, in the same year, in the plenary session of the Parliament, by the President of Romania.
According to the documents supporting the preparation of this report, it is clear that during the communist dictatorship, in Romania, entire segments of the population were subjected to a regime of terror and even extermination by the repression forces of the totalitarian state, the repression in question having at its basis mainly Stalinist political criteria, the victims being considered “enemies of the people“.
At the end of the report, the President of Romania formally asked the judicial bodies to conduct investigations on the commission of crimes against humanity regarding all the victims that were: killed, physically and mentally injured, deported, forcibly displaced, forcibly hospitalised in psychiatric institutions without suffering from any illness, arrested and convicted without breaking the state criminal laws, arrested and subjected to forced physical labor for five years, their detention being in the absence of a legal mandate issued by a prosecutor or judge, as provided for in the Constitution.
In the introductory part of this report, a brief enumeration is given of the acts which may fall under the category of “crimes of the communist regime“, as being imprescriptible crimes which require to be investigated by the romanian judicial bodies, as follows: “The historical and moral culpability of the Romanian Communist Party and of the Security seems to us to be fully proven today. When we talk about hundreds of thousands of victims (arrested, imprisoned, deported, killed), there is no doubt that the regime committed crimes against humanity. It turned Romania into a huge prison colony, populated by delators, collaborators and Security officers…it has prowled national minorities, while claming that their rights are protected. It declared insane, the people who dared to doubt the benefits of socialism. The system used psychiatry as a political weapon. It cruelly persecuted those who dared to demand free trade unions. The most perverse diversions possible were used to compromise the opponents of the regime. It attacked the anti-communist exile and tried to counter in all ways the free radio stations in the West and first of all, the Romanian section of the radio station “Free Europe”. And all these were done in the name of the ” the singing dawn“.
Following the research on this topic it was revealed that the generic category of victims of communism actually falls into several categories of such victims, such as: political prisoners and forcibly displaced; dissidents illegally hospitalised in psychiatry wards; the peasantry, as a result of forced collectivisation; clergy; those tortured in arrests or places of detention; people killed while trying to cross borders; institutionalised children; the participants in the student and worker uprisings, the women suspected of having caused an illegal abortion, etc.
The most numerous category of victims is considered to be the deportees
From the documents in the archive of the National Council for Studying the Security Archives (CNSAS), regarding the procedures used by the repression bodies in order to select the opponents of the system for the relocation and submission of the extermination regime through forced labor, it turns out, for example, that the people in management of the Black Sea Danube Canal demanded a certain number of workers for its construction; The Interior Ministry entrusted this task to the Directorate of Investigation, which, in its turn, transmitted the order to the Security Regions, the latter made lists of “reactionaries”, “parasites”, “enemies of the people” who were to be arrested, deported and thus compelled, for five years, to forced labour.
After analysing the information and documents made public from the concerned archives, it was found that for the implementation of such a policy of extermination by displacement and submission to forced labour, on political criteria and not only, of entire segments of civilian population, the judicial bodies of the totalitarian communist state issued a series of normative acts of lower rank (decrees, orders, etc.), all of them secret, all unconstitutional and contravening all international conventions in the field, to which Romania was or was to become a party, through which Romanian citizens could be detained, arrested, deported and forced to work by the mere decision of the security bodies, without the respective citizens having violated any laws of the country, without having committed criminal acts and without having a criminal case against them filed by a prosecutor or judge.
Thus, at the beginning of 1950, the Presidium of the Grand National Assembly of the Socialist Republic of Romania adopted a secret decree  for the establishment of work units, thereby opening the way for abuses that are difficult to imagine today. The decree stipulated that the following would be sent to work units:
– “those who by their acts or manifestations, directly or indirectly, endanger or attempt to jeopardize the regime of popular democracy, make it difficult or attempt to impede the construction of socialism in the Romanian. P.R., as well as those who, in the same way, defame the state power or its bodies, if these acts do not constitute or cannot constitute, by analogy, crimes. “
Under the mentioned decree, The General Directorate of People’s Security within the Ministry of Internal Affairs issued a secret order that specifically established the categories of citizens which were to be the subject of the security forces alongside with proposals for sending them to work units, as follows :
– “all those who launch or spread alarmist, tendentious, hostile rumors; listen to and broadcast deprived propaganda from imperialist radio stations”;
– “all those who insult the Romanian Labour Party, its leaders and the countries with popular democracy”;
– “all those Romanian citizens who maintain friendly relations with foreign legacies, who attend or have frequented libraries, concerts and in general the propagandistic manifestations of imperialist legacies as well as all those who are in relation with the families of the officials of the imperialist embassies”;
– “instigators of non-compliance or non-execution … especially regarding: collectivizations, collections, cultural plans …”;
– “those who by domestic or international correspondence take a hostile attitude, transmit tendentious, alarmist, hostile news, reactions, instigate.”
In the same order it was stated that: “The following shall be sent in the work units, those elements that commit certain hostile acts, and their activity does not fall under the law”.
The aberrant nature of these provisions led, for example, to the arrest of three hundred medical students from Bucharest who, while in the examination session, lacking textbooks, attended the French Library that held these textbooks, thus preparing for the examination. Only for this reason the students were arrested by the security and incarcerated at Jilava Penitentiary .
In 1952, the Council of Ministers of the Romanian People’s Republic adopted a secret decision for the establishment of labour colonies, compulsory domicile and labour battalions , thus completing the infernal Stalinist type of extermination mechanism of all those who opposed, or could have opposed, the communist regime.
By this normative act, all the categories of persons established by Order 100/1950 were being maintained, which had been forcibly displaced and subjected to compulsory work in the “work units“, now transformed into „work collonies”, to these adding other categories, such as:
„- officers in duty of the bourgeois-landlord parties
– relatives of the country’s traitors and spies, who fled abroad since 1945 (father and children over 18, men);
– relatives of the elements which are enemies of the regime, who fled abroad before 1944 ( the main members of the former bourgeois-landlords parties … father and children over 18, men);”
The new normative act also regulated that internment in labour colonies shall be done by a Special Commission within the Ministry of Internal Affairs, which would make decisions based on the proposals of the General Directorate of State Security.
Furthermore, this normative act regulates the institution of “compulsory domicile and compulsory place of work“, establishing also the categories of persons who were to be subjected to such measures, of which we exemplify:
– former tradesmen, former bankers, former big merchants who traded wholesale or retail, who were expropriated or whose goods were nationalised according to the laws in force, former manufacturers whose enterprises were nationalised ”
The same normative document also set the competent bodies to order the establishment of compulsory domicile and employment :“a regional commission formed by the party secretary, the head of the state security region and the head of the militia region; the proposals of this regional commission were to be sent for validation to the Central Commission of the Ministery of Internal Affaires.”
The order also regulated the measure of establishment of the labour battalions where the following categories of persons were to be sent:
– “traders, small speculators, craftsmen without authorization and unemployed, those who live from the sale of accumulated personal objects and who do not fit into the field of work, etc.”
Regarding the selection of the persons who were to be subjected to such measures, the document in question establishes that the same regional committees are competent, which in turn shall send their proposals to a second commission composed of: a representative of the regional popular Council, a representative of the security and a representative of the militia.
After observing other normative acts, also of lower rank (instructions), it was found that in the prisons or in the colonies of forced labour, a large number of persons were not released, although the criminal conviction or the so-called administrative measure had expired according to the law.
Thus, by strictly secret instructions, the Council of Ministers of the Romanian People’s Republic ordered the formation of a Central Commission consisting of the Minister of State Security, the Minister of Internal Affairs, the Minister of Justice and also the Attorney General of the R.P.R., who would coordinate the activity of the other regional committees set up under the same instructions, all these committes having the task of immediately releasing all prisoners from prisons and labour colonies who had served their sentence, but a series of categories of persons would still not be released, although their period of detention had ended, they belonged to the category of the enemies of the people, respectively :
– “the detainees who served the penalties but held the function of prefect, mayor in municipalities or urban communes, former senior officials …”;
– “… also those who held positions in the management of historical parties, including up to the county committee “;
– “the prisoners who were part of the bourgeois security apparatus and other information and counter-intelligence bodies”;
– “those detainees who were dignitaries of the bourgeois regime (ministers, undersecretaries of state, general secretaries or with similar functions) as well as senators and deputies“.
The same instructions also refer to a category of prison inmates for whom there had never been a sentence of conviction, thus being imprisoned illegally, demanding that they be released.
The cases of Vișinescu Alexandru and Ficior Ion, the only ones solved by a final ruling in Romanian justice. Legality of incrimination.
According to previous statements, after the entry into force of the New Penal Code (February, 2014) which incriminated for the first time crimes against humanity, the Romanian judicial bodies investigated and prosecuted only six cases that had as object this international crime. Of these, until now, the national courts issued final rulings in only two cases, respectively in the cases of former penitentiary commanders Vișinescu Alexandru  and Ficior Ion , convicting them to imprisonment.
Given that the two defendants committed the acts between 1956 and 1963, when the Penal Code of 1936 was in force, which did not incriminate crimes against humanity, it is interesting to analyse how the courts resolved the issue of legality of incrimination, so as not to violate the two basic principles of criminal law, namely “nullum crimen sine lege” and “nullum poena sine lege“.
It is understandable that the reasoning identified by the two courts in order to be able to comply with these principles in both cases, is applicable to all cases involving criminal acts which are generically called “crimes of communism”.
From the comparative analysis of judgments and decisions in both cases, we also found that the reasoning and arguments put forward by the courts, on the legality of the incrimination, in both cases are identical.
After studying the documents drawn up for the criminal investigation, it was also found that, in both cases, the prosecutor’s office, when sending the two cases to court, legally classified the acts of the two offences, as crimes against humanity, according to art. 439 of the New Penal Code.
In both cases, however, the courts first changed the legal classification of the acts in the crime of inhuman treatment, incriminated in art. 358 of the Old Penal Code, thus finding that from the commission of the acts until the conviction of the defendants, a succession of laws in time intervened, and the law most favorable to the defendants was identified as the criminal law of 1968, applying the principle “mitior lex “.
Thus, in their reasoning, the courts consider that the defendants committed the acts in a continuous form, in several repeated material acts and that regarding the material acts that began in 1956, in the case of defendant Vişinescu ( at the same time, the defendant, taking over the position of commander of the Penitentiary Râmnicu-Sărat,), which ended on June 17, 1960 (when the provisions of Decree no. 212/1960 came into force, to be mentioned later), their incrimination was provided for by art.245, art.248, art .471 and art.4641, paragraph 1 and paragraph 2, in conjunction with art.463 of the Penal Code of 1936 (republished in 1948), these making up the constitutive content of the offences of abuse of authority, abusive conduct, injury to bodily integrity or health and, respectively, manslaughter.
Therefore, according to art.245 , Title III “Crimes and offences against public administration” Book II , Penal Code of 1936 (republished in 1948), the crime (offence) of abuse of authority, punishable by correctional imprisonment from 2 to 10 years or a fine, is the act of the civil servant who, by exceeding or by abusive use of his attributions or by violating or not respecting the obligations imposed by legal provisions, among others, causes a damage to the legal interests of the citizens.
According to art. 248 of the same title, Penal Code of 1936 (republished in 1948), the act which constitutes the crime (offence) of abusive conduct, punishable by correctional imprisonment from one to 3 months, is the act of the civil servant who, while in exercise of his function, uses violence against a person, if the act does not constitute a more serious crime.
Pursuant to art.471 of the Penal Code of 1936 (republished in 1948), the crime (offence) of injury to bodily integrity or health, punishable by correctional imprisonment from 2 months to 1 year, is the act of the person who harms, in any way, bodily integrity or health of a person.
Furthermore, art.4641 paragraph 1 and 2 in conjunction with art. 463 of the Penal Code of 1936 (republished in 1948 and amended by Decree no.469 / 1957), incriminated, as a crime (murder) of manslaughter, the act of killing, inflicted upon a person using cruelty or torture or upon two or more persons, either at once or by different actions, the punishment provided by this norm of incrimination being death.
The completion of defendant’s Visinescu acts, incorporating similar material acts, in this case, occurred on April 13, 1963 (at the same time with the transfer of the last batch of political detainees from Râmnicu-Sărat Penitentiary). This moment occurred after the amendments and completions brought to the Penal Code of 1936 by Decree no. 212/1960.
Thus, in the Penal Code of 1936, Book II, a new title was introduced, Title no. I bis, referring to crimes against peace and humanity (art. 2311 – art. 2315), including the crime of inhuman treatment. (art. 2314).
According to art. 2314 , paragraph 1, Penal Code of 1936 (amended and supplemented by Decree no.212 / 1960), the submission to inhuman treatment of any person under the power of the opponent, shall be punished with forced labor from 5 to 20 years, and, in paragraph 3, an aggravating variant of the crime is set out, consisting of the murder, mutilation or extermination of those provided for by paragraph 1, for which the punishment is death.
Material acts prior to June 17, 1960 and similar acts committed as from that date, based on a single criminal resolution and directed against the same group of political detainees, while under the power of the defendants being considered “enemies” (opponents), constitute a legal unit of crime, in continuous form, according to art.107, Penal Code of 1936 (republished in 1948), thus achieving the constitutive content of a single crime, provided for, at the moment of its exhaustion, by art.2314 para.1 and para.3 of the same Code, which establishes, for this, the death penalty, the same as the one provided for in the regulation under whose rule the first material acts were committed, for the crime of murder (in the aggravating variants to which those acts which resulted in the death of three political prisoners are circumscribed).
The courts’ finding regarding the existence of this adversity report, as a prerequisite for the crime of inhuman treatment, is in accordance with the jurisprudence of the High Court of Cassation and Justice, which, in the recital of Decision no. 2579/2009 (issued by the Criminal Section in File no. 61/81/2008), referring to the same crime, holds that, regarding the historical-political period during which the acts that are subject of the trial in the two cases were committed, the existence of a situation of conflict between the state agents working in places of detention, whom the communist state authorities allowed or tolerated them to act as true torturers, on one hand, and the victims, deprived of their liberty, through their actions of physical and mental suppression, on the other.
The acts which resulted in the death of several political prisoners (in both cases) were considered by the courts to be more than mere acts of murder, thus being held as acts of extermination, since, as highlighted in the recitals of the two judgments, them being in reality the consequence of some unconcealed actions or inactions of the defendants who were performing their functions of commanders at that time, diligently pursuing that result, for the obtaining of which various means were used, causing lasting, intense and torturous suffering most of the time being combined (starting from cruel starvation and deliberate lack of medical assistance to beatings applied with the defendants’ direct participation or tolerated by them in total indifference).
Furthermore, crimes against humanity, regardless of their commission, in time of war or peace, were already defined and incriminated, at the time of commission of all material acts held against the two defendants (which could thus ensure their liability for such crimes), by the Statute of the Nuremberg International Military Tribunal, adopted on August 8, 1945 (art. 6, letter c).
Taking intro account all the above considerations, the two courts concluded that the acts (actions and inactions) charged against the defendants were provided for in the criminal law in force at the time of their commission, thus realizing, in relation to the date of exhaustion, the constitutive content of the crime of inhuman treatment, in continuous form, provided for by art.2314 para.1 and para.3 in conjunction with art.107, Penal Code of 1936 (amended and supplemented by Decree no.212 / 1960), which entails their criminal liability, a fact that they themselves could have anticipated, with a minimum effort of reflection, as the provisions of that law in question were predictable and accessible .
The crime of inhuman treatment was acquired “ad literam“, also as a crime against peace and humanity, in Title XI, Special Part of the Penal Code of 1968, which entered into force on January 1, 1969.
According to art.358 paragraph 1, Penal Code of 1968, subjecting any person while under the power of his/her opponent, to inhuman treatment, is punishable by imprisonment from 5 to 15 years, and in paragraph 3, an aggravated variant of the crime is stipulated, consisting in the torture, mutilation or extermination of those provided for by paragraph 1, punishable by death or imprisonment from 15 to 20 years.
Continuing this line of reasoning, the two courts compared by examining the constitutive content of all crimes under previous laws which punished the defendants’ acts with the constitutive elements of crimes against humanity, incriminated by the entry into force of the New Penal Code, on 1’st of February, 2014, finding that those are similar enough to be considered absorbed into each other, in the order of their succession, by indicating that the last operation of this kind, took place at the moment of the entry into force on 1 February 2014 of the new criminal law, at which point, the crimes against humanity incriminated by the new law in art. 439, absorbed the crimes of inhuman treatment that was provided for by art.358 of the Old Penal Code.
This is not for the first time in the modern history of the Romanian justice when it is faced with such a situation related to the legality of the incrimination in the matter of crimes against humanity.
Let us remember that, externally, crimes against humanity were first defined and established in international law on 8 August 1945 by the Statute of the International Military Tribunal in Nuremberg.
Towards the end of the Second World War, as a defeated power, Romania agreed to sign the Armistice Convention on September 12, 1944, in Moscow.
The text of this convention reveals for the first time, enshrined in a Romanian normative act, the notion of war crimes, as follows:. ”.. The Government and the Romanian High Command undertake to cooperate with the Allied (Soviet) High Command, in the arrest and prosecution of persons accused of war crimes ”.
According to the provisions of the armistice, the Romanian judicial authorities had the obligation to investigate and prosecute all persons who committed war crimes and crimes against humanity on the territory of Romania.
Judging by the contents of this paper, it results that at the time of conclusion of the armistice, neither internationally, nor on a national level were such acts defined in legislation or incriminated, therefore the Romanian judicial authorities were in the situation of apparent retroactive application of the content of the criminal law norms which were to be established by the future normative acts, necessary to be adopted for the fulfillment of the obligations assumed by Romania by art. 14 of the Moscow Armistice Convention.
Furthermore, prosecutors and judges of the International Military Tribunal in Nuremberg were in the same situation, respectively, having to prove that, even in such a case, the principle nullum crimen sine lege is not being breached.
Crearly, this situation was the strongest argument that the defendants’ lawyers in this trial were able to put forward, when demanding the acquittal of their clients.
Prosecutors appointed to represent the indictment, countered these defense claims by arguing that, although these crimes had been introduced in the Tribunal’s Statute in 1945, thus after the commission of the acts to be judged, a fact that had to be considered is that the incrimination of these international crimes was noted over time, in various conventions but also international customs, long before the outbreak of war and the commission of acts brought to trial, therefore it could not be argued in favour of the accused, that they would be judged for acts that were not incriminated at the time of their commission.
Judges of the international military court ruled in favour of the prosecution and convicted or acquitted the defendants, depending on the consistency of the evidence administered in relation to each of them, thus removing the defendants’ defense that they were being judged for criminal offences which were not incriminated at the time of their commission.
The solution presented above was also the one chosen by the Romanian judicial authorities when they proceeded to judge the war criminals, according to their obligations following the peace armistice.
In the same sense as already mentioned, is the case law of the European Court of Human Rights, which had been notified on the alleged breach of the provisions of Article 7 of the Convention for Protection of Human Rights and Fundamental Freedoms, judging from the perspective of the principle of legality of incrimination, regarding two cases in which the national courts handed down, after 1990, convictions for acts committed by state agents during the communist regimes in the respective countries (Streletz, Kessler, Krenz v. Germany and Polednova v. Czech Republic cases), found that the considered provisions were not breached, that the fact of not conducting investigations, criminal prosecution and conviction at that time, after the restoration of democratic regimes, does not mean at all that the established acts did not constitute crimes under the national law of each of those states, at the moment of their commission.
 London Convention for the Adoption of the Statute of the Nuremberg International Military Tribunal, 08.08.1945. Convention on the Prevention and Punishment of the Crime of Genocide, United Nations, 1948. Convention on the Imprescriptibility of War Crimes and Crimes against Humanity, United Nations General Assembly, 26.11.1969. European Convention on the Imprescriptibility of Crimes against Humanity and War Crimes, 1974, Strasbourg, etc.
 Decree no. 212, 1960, Official Bulletin of the Grand National Assembly of the R.P.R., No.8/17.06.1960.
 Bucharest Court of Appeal, July 24, 2015, 20 years imprisonment, final judgement after the trial of the appeal by the High Court of Cassation and Justice, February 10, 2016.
 Bucharest Court of Appeal, May 2016, 20 years of imprisonment in first instance, sentence remaining final by rejecting the appeal by the High Court of Cassation and Justice
 Final Report of the Presidential Commission for the Analysis of the Romanian Dictatorship, 2006, p.634. )
 Newspaper „Revista 22„, 05.05.2015, interview given on 05.05.2015 by Mr. Lukasz Kaminski, President of the Institute of National Memory of Poland.
 Final Report of the Presidential Commission for the Analysis of the Romanian Dictatorship, 2006, p.19.
 Decree no. 6/1950 for the establishment of work units, adopted on 14.01.1950, by the Presidium of the Grand National Assembly of the Socialist Republic of Romania.
 Order no. 100/1950 (secret) 03.04.1950, issued by the General Directorate of People’s Security within the Ministry of Internal Affairs.
 Information taken from an act of the State Security Council, called “DOCUMENTARY”, drawn up in 1968.
 Decision no. 1554 (secret) for the establishment of labor colonies, compulsory domicile and labor battalions, August 22, 1952, Council of Ministers of the Romanian People’s Republic.
 Strictly secret instructions, Council of Ministers of the Romanian People’s Republic, 1968.
 Bucharest Court of Appeal, Penal Section I, Penal Sentence no. 122/F, July 24, 2015, file no. 3986/2/2014 ( 2103/2014 ).
 Bucharest Court of Appeal, Penal Section II, Penal Sentence no. 58 / F / 30.03.2016, file no. 5202/2/2014.