Table Of Content~- EXTRA-MURAl PubliCATIONS
)q8" . UtE UNIVERSITY of THE WEsT INdiEs
ST. AUGUSTINE, TRINidAd, WEST INdiES
Y\~'{ ~ ~ 1UU~
GENERAl EditOR TliE GRENAdA FiLE:
MR. EsMONd D. IUMESAR!
DIREcTOR of ExTRA MuRAL STudiEs
litE UNiVERSITy of THE WEST INdiES
Sr. AUGUSTINE, TRINidAd, WEST INdiES THE-MEDIA,_LAW AND
POLITICS
AssociATE EditoR
DR. Nod WoodRoffE
AssiSTANT TO DIRECTOR of ExTRA MuRAL STudiEs
litE UNIVERSITY of ritE WEST INdiEs
Sr. AUGUSTINE, TRINidAd. WEST INdiEs'
RAMEsli 0EOSARAN
SIR ARclilbAld NEdd.
J.O.F. HAyNES
IAN RAMSAY
.,
RANdolpli MciNTOsli
• c;opyRI<;Iit JUNE 1989
Lloyd NOEl
. _ :ExtRA-MuRAl STudiES UNIT
THE UNIVERSITY of ri<E WEsT INdiEs
DAvid AdlER
Sr. AUGustl" CAMpus. TRINidAd
REpublic of TRINidAd ANd TobAGO. WEst INdiES
' I ' ,
All RIGHlS RESERVEd
ISBN No. 976-620-007-6
•
Co>i:R Drs/C/'1 1~ ANJ LA your by
GloRt.\ Y. FERGUSON· l rd.
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fJ ~. EdiTEd by RAMEslt DE:osARAN
PRINTEd N TRINidAd AN<J· TobAGO by I'
GloRt.\ Y. FERGUSON ltd. ' '
14 CocliolANE STREET, TLNAp<.~<A
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About the Author T~ ble o"f Contents \(\ I~ • \
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List of Contributors .............................................. iv
Dr. Ramesh Deosaran, Senior Lecturer in the Faculty of ~. '.1 j v •i ~ -•.::: ~- '
Social Sciences, The ,University of the West Indies, St. About the Author. ................................ ,·.··-''·'·''····'-· vi
Augustine, Trinidad, West Indies, obtained his B.Sc. (First
General Editor's Foreword
Class Hons.), M.A. and Ph.D. at the University of Toronto,
Esmond D. Ramesar ....................................... .ix
Canada. This research in the social psychology of law, the
~·
psychology of political power, mass communications, race
relations and education has been published, for example, in Introduction: Signals for Social Science
the Cunadian Journal of Behavioural Sciences, Caribbean I Ramesh Deosaran ........................................' : . .'.1
Quarterly, Revista/Reviews lnteramerican, British Journal of
lr. The Politics of Information and the People's
Criminology, Indian Journal of Political Science, and Plural
Revolutionary Government
Societies. He is also the author of Eric Williams: The Man,
Ramesh Deosaran .......................................... 10
His Ideas and His Politics, and Trial by Jury: Social and
Psychology Dynamics. ./2. The Grenada Supreme Court: Unconstitutional
but Valid Under the Doctrine of Necessity
Archibald Nedd ............................................. 34
I
I ..,3. The Doctrine of Necessity:
I The Politics and Philosophy
il
J.O.F. Haynes ............................................ 43
ix
viii
1 4. The Defence Replies
Ian Ramsay ...
ooooooooooooooooooooooooo ••••••• oooooooo .... ooll2 General Editor's Foreword
j5. Grenada Supreme Court and the
Governor-General: Mis-applications of the
Doctrine of Necessity
Randolph Mcintosh .................... •oo ........ 138
000 •••••
A number of publications have appeared on the subject of
I
u. The Search for Law and Stability in qrenadit
Grenada in relation to the People's Revolutionary
Lloyd Noel .. oo• oo• oo• oo• ool86
0000 000 000000 00 00 00 00 000000000000 Government (PRO) and on the subsequent armed
intervention by Marines and Army Rangers of the United
J 7. The Legality of the October 1983
Invasion of Grenada States of America.
David Adler ................................................ 194 The collection of papers represented by this volume is
different in that it focuses on some of the legal, social, and
political issues which have arisen in the wake of the
Index •oo••oo··········oo•oo••oo··········"·oo······oo·····•oo•oo231
aftermath. The debate will continue for a long time.
Hopefully, future considerations will be guided by the
ingredients of this book: The Grenada File.
., The Editorial Board of Caribbean Issues is pleased to
include The Grenada File among its list of publications, and
is grateful to Dr. Ramesh Deosaran for undertaking the
..I. ll •. . l ... f-.t 'lj t'
.; editorship of such an important document.
.., .. ,. l•
- '' I
l Esnwnd D. Ramesar
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I
Introduction: Signals for Social
Science
Ramesh Deosaran
;:;
The seven-papers in this book seek to provide a picture of
some communication, political and judicial issues which
arose from the four and a half years' reign by Grenada's
People's Revolutionary Government (PRG). This book
itself is part of a research project around the "Maurice
Bishop Murder Trial." On March 13, 1979, the New Jewel
Movement (NJM), a party in opposition to the ruling
Grenada United Labour Party (GULP) staged a successful
palace coup while the then Prime Minister Eric Gairy was
abroad. With the new name, the People's Revolutionary
Government, its leader, Maurice Bishop, then went on radio
and told Grenadians that "the constitutional government in
Grenada has been· interrupted as a consequence of. the
violations and abuses of democracy committed by the
administration of Eric Matthew Gairy under the guise of
constitutionality." ·
Bishop then pledged to "return to constitutional rule at a!J
early opportunity and to appoint a Consultative Assembly to
consult with all the people for the .purpose of the
establishment of a new constitution which will reflect the
wishes and aspirations of all the people of Grenada." He
said that this "new constitu.t ion wi"l'l be. submitted for -popular
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2 Ramesh Deosaran Introduction: Signals for Social Science 3
approval in a referendum so that all sections, classes and Opposition to the PRG also grew inside Grenada as the PRG
state will be involved." increased its moves against the private media.
The Grenada Parliament was then dissolved with the This struggle for information control played a central role
PRG assuming all executive and legislative powers. A series in eroding public confidence in the policies of the PRG and,
of People's Laws were brought into force. The eady as well, crystallised the political role of the media in the
promises for restoration of parliamentary democracy based Caribbean. Here the private media were seen as a private
upon open elections never materialised. Dissension grew commodity with a political function. The other six papers
within the ranks of the PRG. On October 19, 1983, Prime examined in different ways the political and constitutional
Minister Maurice Bishop together with .several other status of the PRG and then finally the status of the
ministers and citizens were killed as a result of a bloody controversial military action which put an end to the rule by
battle within the PRG. A Revolutionary Military Council that revolutionary group. Central to this discussion is the
(RMC) then quickly assumed power and placed the island status of the courts in which 18 PRG officials were tried for
under a four-day curfew until October 25, 1983, when a the murder of former Prime Minister Ml!urice Bishop and ten
joint attack by forces of the United States and the others. (Case No. 19 of 1984, Regina vs Andy Mitchell and
Organisation of Eastern Caribbean States (OECS} led to the Others*)
collapse of the RMC and the arrest of several RMC otficials. Five papers deal with the politics of the Grenada courts
Some of these arrested persons were then charged for the and the constitutional dilemmas which faced the PRG and
murder of Bishop and ten others. then the successor New National Party (NNP) which carne
In all, these papers bear a sustained linkage between the into power under"free" elections in 1984 with strong U.S.
operation of the legal system on one hand, and the probing support. In his paper, Sir Archibald Nedd, as Grenada's
challenges from politics, sociology and psychology on the Chief Justice, applied in the Caribbean for the first time "the
other hand. In this way, the status of law as a discipline doctrine of necessity." This has since been a fascinating
within the social sciences is enhanced and, as well, suggests topic for political and legal discussion in and outside the
several areas for further inquiry by students i~ the social Caribbean. Nedd's judgement was a response to several
sciences. This, in fact, is one of the major objectives of this defence challenges over the constitutional status of the
book. Grenada Supreme Court, that is the same court which had to
The first paper on Grenada entitled "The Politics of conduct the trial of these accused persons (Case No. 19 of
Information and the PRG" recalls the 1979-83 period which 1984 ). Nedd's paper is a lucid summary of the judgement he
witnessed cumulative animosities between the PRG and the delivered on November 19; 1984 in the Grenada High
privately-owned media across the Caribbean. Several Court. This summary formed his "Presentation Address" to
Caribbean states, especially Jamaica and the OECS, joined the 1985 Hugh Wooding Law School graduates. The
against the PRG in this struggle for information control. defence sought seven Declarations and three Orders from the
This alliance suggested the intrinsic ties between the right to Court. Among the Declarations were: That the Grenada High
private property and the Westminster model of government. Court was unconstitutional and that the Court was "not
Further, these Caribbean countries had also enjoyed a competent in law to hear, determine or try the above-named
conspicuously close relat(onship with the United States. In applicants in respect of the indictments/charges preferred
these circumstances, it was natural for the PRG to be against them."·One of the three Orders sought was that "all
opposed in its ov·n quest for a fuller measure of state further proceedings in the Court on the said
controlled media and a decrease in private ownership rights. indictments/charges be stayed until the said indictments can
Introduction: Signals for Social Science S
4 Ramesh Deosaran,
be heard and determined by a Court duly constituted under He, however, lamented: "It is regrettable that m.embers
the provision of the Courts Order, the West Indies of the Grenada Bar, save perhaps one, were too busy in the
Associated States Supreme Court (Grenada) Act 1971 and other courts to avail themselves of the opportunity of
the Constitution of Grenada." In other words, they were listening to the law in a manner which would have been
asking the court to say that it was indeed "unconstitutional possible after months of research." Nedd's paper therefore
and unfit" to try them. If the courts said "yes," would this affords both lawyers and the Caribbean public as a whole an
also mean that such a decision would in itself be void given opportunity to benefit not only from the research of counsel
the court's "unconstitutional and illegal" status? Haynes' in the "Maurice Bishop Murder Trial," but also from his own
paper is a judicial response to .the further appeal on the wisdom and legal experience. His concise summary of the
doctrine of necessity and the prevailing political
court's legality. · . . .
In the five papers wh1ch deal w1th these 1ssues, the circumstances is a welcome forerunner to the other learned
reader will have a good opportunity to see how .the social papers which follow. In this way readers will have a choice
and political relations in a small society make traditional to read as much as they fancy without losing the essence of
applications of the law very untidy. As the l.egal system the debate over the conflicts among the law, politics and
struggles to maintain its detachment and the ntuals of due sociology of Grenada. .
process, these social and political circumstances keep on Based on extensive motions filed by the defence, the
pulling and tugging at its shirt-tails. The attempt to forge a following two papers probed more deeply into the history
compromise between the law on one hand and the rather and politics of the Grenada revolution in order to justify the
extenuating social and political circumstances on the ot~er legal status of the Grenada Supreme Court. Grenada Appeal
I provides interesting reading fo~ s~uden~.s. o~ the soc1al Court Presidel)t, J.O.F. Haynes, in 1985 gave what the
sciences as well as those spec1ahsed w1thm the legal defence, the prosecution and other legal observers admit as
profession itself. Sir Archibald Nedd's paper, written for a one of the most outstanding judgements in Caribbean
general audience, is a good lead for the other papers on these ~istory. Even in the edited form in which Haynes'
JUdgement appears it uncovers much of the political and
issues.
The Commonwealth Caribbean had never before sociological circumstances which the law was driven to
experienced a coup subsequently defined by the Appeal. devise to promote and ensure a fair trial in the situation
Court as a "revolution" such as that staged on March 13, which faced and still faces Grenada. Again, this paper offers
1979 by the New Jewel Movement, afterwards called the Caribbean people an opportunity to witness an
PRG. After the October 1983 collapse of the PRG, the unprecedented convergence between the law, politics and
constitutional status o( Grenada's Supreme Court came into sociology of a small society.
In one of his conclusions, Haynes writes: "We in the
sharp question, especially by the defen~e of.the 18 ~ccused.
Sir Archibald's judgement, as Grenada s Ch1ef Justice then, jurisdictions with written constitutions of the Westminster
model realise that the Constitution does not and cannot
on November 19, 1984 was that while the Grenada Supreme
provide for every political' situation that might arise. It does
Court was unconstitutional it was still valid according to the
doctrine of necessity. Naturally, this position helped change not provide for extra0constitutional situations like this one at
all! We in the Caribbean judiciary must do so. We cannot
the psychology of jurisprudence in Grenada. Fu~e~ore,
find the solution in English cases." Haynes' ruling provides
this judgement provoked an unprecedented exarrunatton of
some insights into how the law was prepared to confront
the politics surrounding the courts in Grenada.
Grenada politics in establishing the rituals of due process.
lnlroduclion: Signals for Social Science 7
6 Ramesh Deosaran
Ramsay. The critical importance of this debate should not go
His paper also reveals some of the legal contentions posed
unnoticed by the Caribbean people.
by the defence, contentions which are more elaborately
I In fact, this is another of the objectives of this
presented by the leading defence counsel,. Ian Ra~~ay monograph, that i~ to provide the Caribbean with a snapshot
himself. It seemed as if the law in times of pomted pohucal
of one of its most historical events. Indeed, the rule of the
confrontation becomes a law unto itself. ..o f necessity. As ,,
PRO eventually collapsed in blood and tears and cast a dark
such, students of the sociology of law would find interesting
I shadow over the politics and psychology of Grenada.
thesis here for further Caribbean research.
When the joint military action against the Revolutionary·
The sixth paper by leading defence ~ounsel, ~an Ramsay, Military Council occurred on October 25, 1983, the
raises the question: Expediency or Ju~Uce? It disputes both Caribbean went into an uproar over the status of this military
Nedd's and Haynes' rulings. Summarising his arguments,
action. The paper by Professor David Adler questions the
Ramsay says: "These advances ... are ground for some
legality of President Reagan's order to send the United
hope in that they affirm that the idea of justice in the re~io~ is States army into Grenada on October 25, 1983. Though this
best served not by quick legal f'lip-flops as ~e O~Jec.uve was a joint operation with Jamaica and the seven-member
situation changes; but by adherence to unchangmg pnnctple.
Organisation of Eastern Caribbean States (OECS), the action
Only in this way can our stewards~ip of le_gal. ~nd itself resulted in a protracted controversy over its status. Was
constitutional principles as lawyers and Judges be JUStlfted.
it a rescue mission, an intervention or an invasion? Adler
Only in this way can we discharge our burden to the future."
produced historical accounts of several pieces of legislation
The seventh paper by Professor Randol_Ph Macintosh
and judicial rulings to show that President Reagan's decision
criticises both ·Grenada's Supreme Court Judges and ~e was a wrong interpretation of the law. This paper, however,
Governor-General Sir Paul Scoon for misinterpreting the
still produced accounts which showed presidential
status of the PRO and the doctrine of necessity. Macintosh
precedents for Reagan's decision.
concludes that "Their Lordships, having misconceived the
The ideological differences which VJere aired during the
jurisprudential issues raised by the applicants' motion and,
1979-83 "media war" now came across as heavier thunder
consequently, the relevance of the doctrine of nec~s.sity,to after October 1983 over this military invasion of Grenada.
the case delivered of themselves a deeply flawed declSion.
Professor Adler argues that President Ronald Reagan's
The final paper by Lloyd Noel, a former (Acting)
decision to send United States troops into Grenada at that
Attorney General and Minister of Legal Affairs of the PR;G,
time was "unconstitutional." Even with this conclusion,
is a concise rebuttal to Macintosh's arguments. After parting
Adler's citations provide the reader with a picture of the War
company, Noel had become a sharp critic of the P~G. N~l Powers Act and the difficulties which faced the United States
argues that the PRO and the Governor-General · had like
administration in arriving at that decision to send troops.
authority," something which seemingly escaped Mac!ntosh's
The compilation of these papers is therefore an attempt to
notice. Noel concludes: "Since the PRO created.tts own
form a record in the hope that they would .lend wisdom in the
ground norm on March 13, 1979, to the same extent the
continued ·search for fuller freedom and peace in the
Governor-General created his own on October 25, 1983."
Caribbean. It is also filled with research possibilities for
These two papers throw further light! in diffe~en~ way_s of Caribbean social scientists.
course, on the difficulties of constructing legal Justification~ Finally, I must express my very deep gratitude to the
upon shifting sociological and political circumstances, a
judge who presided at the trial, Justice Dehis Byron, and as
point made in the earlier paper by the defence col!nSCfl, Ian
well, to the Director of Public Prosecutions (Acting) •Ms.
8 Ramesh Deosaran
Introduction: Signals for Social Science 9
Velma Hylton. Without their kind cooperation, this work
Joseph, Andy Mitchell, Leon Cornwall, Liam James and
would not have been possible. They have both shown Callistus Bernard; Ms. Norma Lynton for Selwyn Strachan,
remarkable professionalism in dealing with my numerous
Dave Bartholomew and John Anthony Ventour; Glen
requests. I am deeply indebted to both of them.
Cruickshank for Ewart Layne, Lester Redhead and Raeburn
The kind cooperation of the Extra-Mural Studies Unit,
Nelson; A.J. Nicholson for Hudson Austin and Christopher
The University of the West Indies (St. Augustine) and in
Stroude; Delano Jacqueline Samuels-Brown for Cosmos
particular its Director, Mr. Esmond Ramesar is also Richardson.
gratefully acknowledged.
' I High Court Verdicts given on Thursday,
I
December 4, 1986:
11 Guilty ofM urder ofB ishop and ten others:
Rarnesh Deosaran, Ph.D. Callistus Bernard, Lester Redhead }
Editor. Christopher Stroude, Hudson Austin }
Bernard Coard, Leon Cornwall, }
Liam James, John Ventour, }Death
Dave Bartholomew, Ewart Layne, }Sentence
Colville McBarnette, Selwyn Strachan, }
PhYllis Coard, Cecil Prime }
Guilty of Manslaughter ofB ishop and ten others:
Maurice Bishop Murder Trial
Vincent Joseph, Cosmos Richardson }45 years each
in prison
*Case No. 19 of 1984 started out with 19 accused. One of
these, Fabian Gabriel, turned state witness, leaving 18 on Guilty ofM anslaughter ofB ishop and seven others:
trial. These were: Vincent Joseph, Callistus Bernard (Imam Andy Mitchell }30 years in
Abdullah), Cosmos Richardson, Lester Redhead, prison
Christopher Stroude, Andy Mitchell, Hudson Austin,
Not Guilty:
Bernard Coard, Liam James, Leon Cornwall, John Anthony
Raeburn Nelson }Freed
Ventour, Dave Bartholomew, Ewart Layne, Colville
McBarnette, Selwyn Strachan, Phyllis Coard, Cecil Prime
and Raeburn Nelson.
Appearances
For the prosecution: Karl Hudson-Phillips, Q.C., and
Ulric Dougan for the Attorney General, Ms. Velma Hylton,
Q.C. (Acting DPP) with Doodnauth Singh, Michael Andrew
and Keith Friday.
For the defence: Ian Ramsay, Q.C., Carlton Williams,
Enos Grant and Maurice Tennfor Bernard Coard and PhYllis
Coard; Howard Hamilton and Earl Whitter for Vincent
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The Politics of Information and the P.R.G ll
the background ofsimilarly fierce communication struggles
1. in Guyana, Jamaica and other Caribbean states.
The underlying theme is that the POM have little or no
tolerance for leftist or revolutionary groups which attack
private property and which fail to uphold the traditional
The Politics of Information and requirements of the Westminister model of Government for
example, a multiparty electoral system and the separatio~ of
the People's Revolutionary powers.
Government A Caribbean Review
The years 1978 to 1983 have witnessed severe tensions
between Caribbean Governments and the POM. For
example, both the ruling People's National Congress (PNC)
Ramesh Deosaran led by the late Forbes Burnham in Guyana, and the People's
Natwnal Party (PNP) led by Michael Manley (when he ruled
in 1979) have been engaged in protracted confrontations
with the POM. In some of the smaller states the
governments placed a series of restrictions on the media. In
Introduction Montserrat •. f<;>r example, the government (a budget of just
over $13 mtlhon) have proposed a Newspaper Registration
During the last 25 years, the Caribbean Commonwealth and Surety Ordi~ance (1981) which requires newspapers to
States (CARICOM) have been expexienciog mount[11g declare full detatls of proposed operations and lodge a bond
tenswns whtch, m many cases, are related to infiucnccs of $50:000 ":ith the government. In early 1981, the
emanating from outside countries, e.g. Cuba, Russia, the Domtntcan Government has had to unleash severe
United States, and the string of unsettled countries in Central censorship as a reaction to a coup threat.
and Latin America. These tensions have usually eru'ptcd In Trinidad and Tobago and Barbados, there have been
from sharp ideoldgical differences, at the centre of which skirmishes between the media and the respective
existed a sustained struggle over "freedom of the press." The Governments and while there have been government
successful coups in Grenada (1979) and nearby Surinam complaints of "press irresponsibility" no legislative or
(1982) and the murder on October 19, 1983 of Grenada's serious political actions had been taken against the POM in
these two countries. In fact, the Trinidad and Tobago
Priine Minister, Maurice Bishop2 have produced the most
Constitution specifically guarantees (Chapters I (4) (k))
dramatic manifestation of these tensions.
freedom.of the. press in addition to "freedom of conscience
This paper examines the bitter, prolonged confrontation
and expression.'!
which took place between 1979 and 1983 between Bishop
Since the successful coup by Bishop's New Jewel
and his People's Revolutionary Government (PRG) in
Movement (NJM) against Eric Gair/s oppressive and
Grenada on one h?'ld and the Privately-Owned Media
corrupt regime on ·March 13, ·1979, the constitution and all
(POM) in the Caribbean. This examination is done against
the POM there had been quickly disbanded. The ·PRG:s
liroken promises to reopen the POM and call early elections
10
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12 R_~p;tesh Deosaran The Politics of Information and the P.R.G 13
in Grenada-evoked very s_trong criticisms from the .f'OMJ Caribbean. The petition charged the PRG for violating the
across the Caribbean.- ~ .. ., . .. • ' . human rights of its citizens by:
Except for Guyan.a and Grenada under the ~RG,1the
POM jn the Commonwealth Caribbean were fatrly well 1. failing to allow them to participate in government
established. There we~ three major,regional bodies:. · ·· (through elections),
'f
1. the 27-member Caribbean Publishers and Broad-d 2. failing to respect the right of freedom of thought and
casters Association (CPBA) (including the POM an 1 expression by closing down the Torchlight and the
some government-owned media but excluding the. Catholic Focus newspapers (the Grenadian Voice
media in Grenada and Guyana), a· l was closed after the petition was filed),
2. the Caribbean News Agency (CANA), supported·byd 3. the confiscation of property without compensation of
the CPBA in the dissemination of regional- an • the Trinidad Express shares in the Torchlight.
international news, and ·' "'
The PRG, having previously informed the IACHR that
3. the Caribbean Press Council (CPC) supported by the they were seeking "a friendly solution" to the POM
CPBA as a "watch dog" for complaints against· the. complaints, not only failed to do so but eventually failed to
media. ' " appear before the IACHR to answer the charge.
The POM through the CPBA and on their own, h~d.a' The POM then issued a press release stating in part:
strong direct i~volvement in the Milllll!-based ~nter-Am:ncan
Press Association (IAPA). The most mflue~ual PO~ m the Their (PRG) failure to appear before this internationally regional
region are five dailies-the Gleaner m Jam~tca; the tribunal at this meeting indicates that they themselves recognise
Advucate and Nation in Barbad?s, and_ Guf!rdwn_ and that their refusal to hold free and fair elections and the continued
Express in Trinidad. With a combmed daily ctrculatlon of detention of over 100 persons is indefensible .... Pressure must be
almost 250,000, these are the media whic~ have l~d ~he brought on the Government of Grenada to allow a free and
struggle over the issue of· a "free press agamst t<?tahtanan independent press to be established in that country.
governments." Clearly, ideological differences extst~d over
But while it did not physically appear before the IACHR,
individual rights, freedom of expression, and the nght to
the PRG on July 31, 1981 (seven months after the POM
private property.
petition), issued a six-page written response to the POM
charges, in which it questioned the legality of the petitioners'
Grenada and Case 7578
standing (e.g. "None of the petitioners are citizens of
Grenada or reside therein"). Clause 2 of the PRG response
Case 7578 is based on a petition filed in December 1_980
further stated:
and brought against the ~RG before the Inter-Ame~tcan
Commission of Human Rights (IACHR), the human ng~ts
agency of the Organisation of Ame~~an ~tates to wh~ch The petitioners have not made or exhausted all reasonable efforts to
obtain redress by the judicial powers in Grenada .... Although the
CARICOM states ~ubscribe. The petition, filed by t_he ftve
fundamental rights clauses in the Constitution of Grenada have
POM mentioned in the preceding paragraph, crystalhs~s the
been suspended by the People's Revolutionary Government, the
persistent struggle. between the PRG and the POM the
II) Grenada Courts still apply British Common Law principles and
