The Natural Law
Charles E. Rice
Professor Emeritus, Notre Dame Law School
Address, Canon Law Conference
Shrine of Our Lady of Guadalupe
August 9, 2011
What is the natural law and why do we need it? The “September Pope,” John Paul I, at his general audience on September 6, 1978, gave us a clue:
Once a man went to buy a motorcar from the agent. The latter talked to him plainly: “Look here, it’s a good car; mind that you treat it well: premium petrol in the tank, and for the joints, oil, the good stuff.” But the other replied: “Oh, no, for your information, I can’t stand even the smell of petrol, nor oil; I’ll put champagne, which I like so much, in the tank and I’ll oil the joints with jam.” “Do what you like: but don’t come and complain if you end up in a ditch, with your car!”
“The Lord,” he continued, “did something similar with us: he gave us this body, animated by an intelligent soul, a good will. He said, ‘this machine is a good one, but treat it well.’” And God did more: “God gave [the Commandments] to us not to satisfy a whim, not in his own interest, but solely in our interest.” The Commandments are specifications of the natural law. Together they constitute a set of manufacturer’s directions, given by our Creator “solely for our interest.”
When the seller warned the buyer to “treat it well,” he meant the buyer should do good by his car. Everything has a nature, built into it by its maker. The good is that which is in accord with the nature of the thing. It is good to put gasoline in the tank. It is not good to put champagne or sand in the tank because that violates the nature of the car. If you do put champagne or sand in the tank, you will be pro-choice, but you will also be a pedestrian. That is so because the natural law is the story of how things work. John Paul I reminds us that our culture is like the guy who puts sand in his gas tank and is surprised when the car doesn’t run.
An Impoverished Culture
On September 24, 2001, thirteen days after 9/11, John Paul II warned the leaders of Kazakhstan not to use the West as a model because, despite its technological progress, the West suffers from a “human spiritual and moral impoverishment” because of its “fatal attempt to secure the good of humanity by eliminating God, the Supreme Good.” We have rejected not only God, but also reason. “[M]ore than in any other historical period,” said John Paul II, “there is a breakdown in the process of handing on moral and religious values between generations.”1
The problem goes back a few years. As Fr. Francis Canavan, S.J., said, “we are living through the fag end of the Enlightenment.”2 The Enlightenment is the effort by philosophers and politicians over the past three centuries to organize society as if God did not exist. The Enlightenment premises are:
Secularism. God is non-existent or unknowable. But it is unreasonable not to believe in God. St. Thomas called it the proof from necessity: We know there has to be an eternal being—that is, God– because “if at one time nothing was in existence, it would have been impossible for anything to have begun to exist; and thus even now nothing would be in existence—which is absurd.”3 Or you might prefer the analysis of Julie Andrews in “The Sound of Music”: “Nothing comes from nothing. Nothing ever could.”
Relativism. We are living in what Benedict XVI calls “the dictatorship of relativism.” First of all, relativism is absurd. The statement, “All things are relative,” must mean that that statement is relative. Our universities are full of professors who are absolutely sure they can’t be sure of anything. Relativism leads to legal positivism in which law is not reason but the will of the State. Relativism arises from what Benedict calls “the self-limitation of reason to the empirically verifiable.”4 He called for the “concept of reason… to be broadened… to explore and embrace those aspects of reality… beyond the merely empirical.”5
Individualism. “I’m aboard; pull up the gangplank.” Under the social contract theory (Hobbes, Locke, Rousseau), the State derives its authority, not from God, but horizontally from the people. The person is regarded not as social by nature, but as sociable. He is an autonomous individual, having relation to others only if he so consents; that is the origin of “pro-choice.” Planned Parenthood didn’t think it up. Each person is his own moral authority, i.e., his own “god.” Conscience becomes a decision of the autonomous will of the individual rather than a judgment as to the rightness or wrongness of an act according to objective criteria founded in nature and the law of God.
These Enlightenment premises have shaped American culture in basic ways. The intentional infliction of death on the innocent is widely accepted as an optional problem-solving technique, as seen in Columbine-type shootings, legalized abortion and euthanasia. The legalized execution of Terri Schiavo through withdrawal of nutrition and hydration is replicated without notice every day whenever the family and caregivers agree that the incompetent patient would prefer to die or, in some states, that it would be in the patient’s best interest to die. The approval of same-sex marriage or its equivalent in “civil unions” shows we have lost sight of the nature of the person and the family. A society in which it makes no legal and social difference whether little boys grow up to marry girls or other boys is clinically insane.
The problem is one of reason as well as faith. “[P]rinciples which are not negotiable [including] protection of life in all its stages…. are inscribed in human nature itself and therefore they are common to all humanity.”6 Catholic social teaching, said Benedict in his first encyclical, Deus Caritas Est, argues “on the basis of reason and natural law” so as “to help form consciences in political life” and to “reawaken the spiritual energy” needed for justice to prevail.7
“Law” is defined by St. Thomas Aquinas as “an ordinance of reason for the common good, made by him who has care of the community, and promulgated.”8 When we talk about the natural law, we mean that law which is built into the nature of rational human beings. The first step in analyzing any law is to identify the lawgiver. Whose natural law? The Lawgiver of the natural law is God. Aquinas enumerates four kinds of law:
The Eternal Law. God’s concept of things. “[T]he whole community of the universe is governed by Divine Reason. Wherefore the very Idea of the government of things in God the Ruler of the universe, has the nature of a law.”9
The Natural Law. “[T]he light of natural reason, whereby we discern what is good and what is evil, which is the function of the natural law, is nothing else than an imprint on us of the Divine Light. It is therefore evident that the natural law is nothing else than the rational creature’s participation of the Eternal Law.”10 “ ‘[T]he natural law,” said John Paul II, “is itself the eternal law, implanted in beings endowed with reason and inclining them towards their right action and end.’”11
The Divine Law. In the very first question in the entire Summa Theologica, St. Thomas asserts that “It was necessary for man’s salvation that there should be a knowledge revealed by God, besides philosophical science built up by human reason.”12 He calls that revelation the Divine law. It includes the Old Testament, the New Testament, and Tradition.13 “Tradition” is the “living transmission” through which “the Church, in her doctrine, life and worship… transmits to every generation all that she herself is, all that she believes.”14 The Divine Law is necessary so that “man may know without any doubt what he ought to do and what he ought to avoid,”15 not only with respect to “things which are above reason, but also those which can be known by reason.”16
The Human Law. “[P]articular determinations, devised by human reason, are called human laws, provided the other essential conditions of law be observed.”17
What does the Natural Law Do?
The natural law has two functions: it is a guide to personal conduct and a measure of the enacted law of the State. In Calder v. Bull,18 Justice Samuel Chase said that natural law can be used to strike down an enacted law. Justice James Iredell argued instead that natural law could not be used because “[t]he ideas of natural law are regulated by no fixed standard: the ablest and purest men have differed upon the subject.” Iredell’s objection is still the major obstacle to acceptance of the natural law in both its functions.
Natural law as a guide to personal conduct
The answer to Iredell’s objection begins with St. Thomas. What can we know about the natural law? First, you have to ask what can you know about anything. St. Thomas distinguishes the speculative reason from the practical reason. The object of the speculative reason is being. The first, self-evident principle of the speculative reason is the principle of non-contradiction, that a thing cannot both be and not be at the same time under the same aspect. As St. Thomas put it, “the same thing cannot be affirmed and denied at the same time.”19 The object of the practical reason is the good. The first, self-evident principle of the practical reason is that “good is that which all things seek after.”20 That is the basis of the first, self-evident principle of the natural law, that “good is to be done and ensued, and evil is to be avoided.”21
The basic inclinations of human nature “are naturally apprehended by reason as being good”22:
In man there is first of all an inclination to good in accordance with the nature… he has in common with all substances: inasmuch as every substance seeks the preservation of its own being… whatever is a means of preserving human life… belongs to the natural law. Secondly, there is in man an inclination to things … according to that nature… he has in common with other animals; those things belong to the natural law, which nature has taught to all animals:… such as sexual intercourse, education of offspring and so forth. Thirdly, there is in man an inclination to good, according to the nature of his reason… : thus man has a natural inclination to know the truth about God, and to live in society:… to shun ignorance, to avoid offending those among whom one has to live, and other such things regarding the above inclination.23
Those basic inclinations can be variously described and subdivided. They can be enumerated as follows:
To seek the good, including our highest good, who is God.
To preserve oneself.
To preserve the species.
To live in community.
To know and to choose.24
What the Practical Reason Does
The practical reason makes deductions from the basic inclinations as to what actions are good and what are evil. How do we know, from reason, that it is wrong to steal? Because of the basic inclination to live in community. What kind of community would it be if it were open season on cars in the parking lot and anyone could take whatever car he wanted? Or if you could check out a library book and never return it? It is good to feed gasoline to a car. It is not good to feed it to a man. And it is not good, i.e., it is evil, to steal or murder, because such acts are contrary to the natural human inclinations to live in community, etc.
While we can affirm through reason the objective rightness or wrongness of acts, we generally have neither the right nor the ability to judge the subjective culpability of the person who commits that act. To be culpable, one must know the act is wrong and choose to do it.25 Habitual sin can reduce the ability of reason to make correct applications of the natural law. “[T]he systematic violation of the moral law… produces a… progressive darkening of the capacity to discern God’s living and saving presence.”26
The Ten Commandments are specifications of the natural law, given by God so that man, despite his fallen and damaged condition, could still know with certainty what he should do and not do.27 The positive precepts of the natural law may be seen, in prudence, not to apply in a specific situation “in view of other duties which may be more important or urgent.”28 A child is bound to obey his parents. But if they ordered him to steal he would be obliged to disobey them. “[T]he negative moral precepts, those prohibiting certain concrete actions or kinds of behavior as intrinsically evil, do not allow for any legitimate exception.”29 Such “kinds of behavior… can never… be a proper response… in conformity with the dignity of the person….[I]t is always possible that man… can be hindered from doing certain good actions; but he can never be hindered from not doing certain actions, especially if he is prepared to die rather than do evil.”30
The natural law is unchangeable in its general principles but its application may vary in particular cases. A proper conclusion of the natural law is that when you borrow something you should return it to the lender. But if you discover that the person who lent you a gun wants it back so he can murder someone, you are obliged not to return it to that lender, because that would be immoral cooperation in his sin. As Aquinas said, ‘it would be injurious, and therefore unreasonable, to restore goods held in trust… if they are claimed for the purpose of fighting against one’s country.’31
Our conscience is the act of our intellect by which we judge the rightness or wrongness of a particular act.32 Our duties to our conscience are three33:
Form the conscience. “Although each individual has a right to be respected in his own journey in search of the truth, there exists a prior moral obligation, and a grave one at that, to seek the truth and to adhere to it once it is known.”34
Follow your conscience if it is clear. “A human being must always obey the certain judgment of his conscience.”35 You may, however, be culpable for forming your conscience incorrectly.36
Never act on a doubtful conscience. “If a man acts against this judgment [of conscience] or, in a case where he lacks certainty about the rightness and goodness of a determined act, he stands condemned by his own conscience, the proximate norm of personal morality.”37 In other words, take the safer course.
“Moral truth is objective,” said John Paul II at the 1993 World Youth Day in Denver, “and a properly formed conscience can perceive it.”38 As St. Thomas tells us, “If… we consider one act in the moral order, it is impossible for it to be morally both good and evil.”39 But our intellects are weakened by original sin and sincere advocates can be found on both sides of most moral issues. Aristotle, who had a pretty good LSAT score, sanctioned infanticide. Some Christians of the nineteenth century upheld the morality of slavery. Today people differ on the morality of abortion. They can’t both be right.
An authoritative interpreter is needed if the natural law is not to degenerate into endless discussion and be useless as a standard for law and human conduct. John Paul II offers the solution: “Christians have a great help in the Church and her Magisterium. As the [Second Vatican] Council affirms: … ‘[T]he Catholic Church is by the will of Christ, the teacher of truth. Her charge is to announce and teach authentically that truth which is Christ… and confirm the principles of the moral order which derive from human nature itself.’… [T]he authority of the Church, when she pronounces on moral questions, in no way undermines the freedom of conscience of Christians. This is so… because freedom of conscience is never freedom ‘from’ the truth but always and only freedom ‘in’ the truth…. The Church puts herself … at the service of conscience, helping it to avoid being tossed to and fro by every wind of doctrine proposed by human deceit… and helping it not to swerve from the truth about the good of man, but rather… to attain the truth with certainty and to abide in it.”40
In his 1987 address to the bishops of the United States, John Paul noted “a tendency on the part of some Catholics to be selective in their adherence to the Church’s moral teachings. It is sometimes claimed that dissent from the Magisterium is totally compatible with being a ‘good Catholic’ and poses no obstacle to reception of the Sacraments. This is a grave error that challenges the teaching office of the Bishops of the United States and elsewhere.”41 Everyone has a pope, a visible authoritative interpreter of the natural law. If that interpreter is not the real Pope, it will be a pope of the person’s own choosing; whether Oprah, Chris Matthews, or the person himself. It makes sense to say that we have only one Pope, not seven billion and that his name is Benedict because he is the successor of Peter to whom Christ gave the keys.
If your new car got a flat on a country road, the first thing you would do is to look in the glove compartment for the manual to find out where the jack is and how to use it. Would you resent those directions? God is not merely a manufacturer. But the natural law, the Commandments, and the Magisterium as authoritative interpreter, are like the manufacturer’s directions in your glove compartment.
The Natural Law as a Measure of the Enacted Law of the State
“[T]he order of justice,” said Aquinas, “requires that subjects obey their superiors, else the stability of human affairs would cease.”42 But, as St. Thomas put it, if a human law “deflects from the law of nature,” it is unjust and “is no longer a law but a perversion of law.”43 Martin Luther King echoed Aquinas when he said, in his Letter from Birmingham Jail, that “An unjust law is a code that is out of harmony with the moral law.” Unjust laws are “acts of violence rather than laws.”44 As St. Thomas affirmed, we may be obliged, however, to obey an unjust law “to avoid scandal or disturbance,” but a law that is unjust because it would compel one to violate the Divine law must never be obeyed. St. Thomas explains that a law may be unjust in two ways:
First, by being contrary to human good… either in respect of the end, as when an authority imposes on his subjects burdensome laws, conducive, not to the common good, but rather to his own cupidity or vainglory;– or in respect of the author, as when a man makes a law that goes beyond the power committed to him;– or in respect of the form, as when burdens are imposed unequally on the community, although with a view to the common good. The like are acts of violence rather than laws; because as Augustine says,… “a law that is not just, seems to be no law at all.” Wherefore such laws do not bind in conscience, except perhaps in order to avoid scandal or disturbance, for which cause a man should even yield his right, according to Matth. v. 40,41.
Secondly, laws may be unjust through being opposed to the Divine good; such are the laws of tyrants inducing to idolatry, or to anything else contrary to the Divine law; and laws of this kind must nowise be observed, because, as stated in Acts v. 29, “we ought to obey God rather than men.”45
To obey or not to obey
A law “contrary to human good” would be the income tax, which is riddled with arbitrary and even oppressive features in its substance and procedures. Yet the injustice of the income tax does not provide a justification for refusing to pay it because an unacceptable disruption of the common good would result from the affirmation of such a right. Moreover, at least in principle, means are available within the law to change the system. A law “opposed to the Divine good” would be a law requiring a physician to perform an abortion. If there were such a law, the physician would be morally obliged to refuse even on pain of death.
Rosa Parks made an Aquinas-type statement when she refused to give up her seat on the bus in Montgomery, Alabama, on December 1, 1955. 46 As a violation of equality, that law was unjust because it was contrary to human rather than divine good. Unless you conclude that the law would have compelled her to violate the divine law by materially and proximately cooperating with an evil system, she was not obliged to disobey the law. That is why her action is regarded as heroic, because she did not have to do it. Imagine, however, a black man on such a bus, not during the demonstrations of 1955 but rather in a more restrictive atmosphere in, say, 1936. If he had reason to fear that, if he refused to give his seat to a white man, the goons with the white hoods would come to his house that night and do violence to him and his family, he could be obliged to obey that unjust law to avoid that greater evil.
An unjust law, such as a law permitting abortion, can raise the distinction between formal and material cooperation in evil. “One formally cooperates in another’s wrongful act,” said Archbishop John J. Myers, “when one participates in the immoral act in such a way that it becomes one’s own.”47 As John Paul II said in Evangelium Vitae, “Christians, like all people of good will, are called upon under grave obligation of conscience not to cooperate formally in practices which, even if permitted by civil legislation, are contrary to God’s law. Indeed, from the moral standpoint, it is never licit to cooperate formally in evil. Such cooperation occurs when an action, either by its very nature or by the form it takes in a concrete situation, can be defined as a direct participation in an act against innocent human life or a sharing in the immoral intention of the person committing it.”48 “One materially cooperates in another’s wrongdoing,” in Bishop Myers’ words, “when one’s acts help to make that wrongdoing possible, although one does not intend that wrongdoing. Material cooperation in abortion takes place… where one’s actions—although motivated by another purpose—nevertheless help to make an abortion possible. All formal cooperation in abortion is gravely immoral. So is most material cooperation in abortion. However, there may be limited circumstances under which certain forms of material cooperation are permissible. For example, a hospital worker responsible for cleaning and maintaining an operating room where abortions are sometimes performed may carry out his or her tasks without being implicated in the immoral act. The worker may oppose abortion and intend only to facilitate the morally upright, indeed laudable surgical procedures performed there. He or she merely accepts as an unintended albeit foreseen consequence that the well-maintained facility will enable physicians to perform abortions.”49 Or, as John Paul said in Evangelium Vitae, a legislator “could licitly support,” in some limited circumstances, “a more restrictive law, aimed at limiting the number of authorized abortions, in place of a more permissive law already passed or ready to be voted on.”50 A separate question is whether such cooperation, even if morally justified, is prudent.
Incidentally, Evangelium Vitae emphasized that the civil law should protect the right of “conscientious objection” to legalized abortion and euthanasia. “To refuse to take part in committing an injustice is not only a moral duty; it is also a basic human right…[T]he opportunity to refuse to take part in the phases of consultation, preparation and execution of these acts against life should be guaranteed to physicians, health-care personnel, and directors of hospitals, clinics and convalescent facilities.”51
Saint Thomas notes that a law does not have to be followed when noncompliance is required by the common good:
It happens often that the observance of some point of law conduces to the common weal in the majority of instances, and yet, in some cases, is very hurtful…. [I]f a case arises wherein the observance of that law would be hurtful to the general welfare, it should not be observed. For instance, suppose that in a besieged city it be an established law that the gates of the city are to be kept closed; this is good for public welfare as a general rule: but if it were to happen that the enemy are in pursuit of certain citizens, who are defenders of the city, it would be a great loss to the city, if the gates were not opened to them: and so in that case the gates ought to be opened, contrary to the letter of the law, in order to maintain the common weal, which the lawgiver had in view.52
This principle of necessity or justification is recognized in the common law and by federal and state statutes and decisions.
A law higher than the State?
The root question is epistemological: Can reason know an objective moral standard to which even the state is subject? There are only two answers. One is some form of natural law that would affirm such a knowable standard in human nature. The alternative to natural law is some form of legal positivism. Hans Kelsen, probably the leading legal positivist of the 20th century, rejected “philosophical absolutism,” the “metaphysical view that there is an absolute reality… that exists independently of human knowledge.” Instead, he adopted “philosophical relativism,” which “advocates the empirical doctrine that reality exists only within human knowledge, and that, as the object of knowledge, reality is relative to the knowing subject. The absolute, the thing in itself, is beyond human experience; it is inaccessible to human knowledge and therefore unknowable.”53 “Justice, he said, “is an irrational ideal.”54
Kelsen argued that philosophical absolutism leads to political absolutism, i.e., tyranny. He regarded Thomas Aquinas a philosophical absolutist. But he misunderstood Aquinas who was an advocate of limited government. Aquinas not only said that an unjust law “seems to be no law at all.” He also said that human law should not try to enforce every virtue or forbid every vice. It “leaves unpunished many things that are punished by Divine Providence.” 55 Contrary to Kelsen, John Paul II explained that relativism leads to totalitarianism: “[I]f there is no ultimate truth to guide and direct political activity, then ideas and convictions can easily be manipulated for reasons of power. As history demonstrates, a democracy without values easily turns into open or thinly disguised totalitarianism.” 56
After World War II, Kelsen conceded that his legal positivism would validate the Nazi and other totalitarian regimes: “The legal order of totalitarian states authorizes their governments to confine in concentration camps persons whose opinions, religion, or race they do not like; to force them to perform any kind of labor, even to kill them. Such measures may be morally or violently condemned; but they cannot be considered as taking place outside the legal order of these states.” Thus, “from the point of view of the science of law, the law under the Nazi-government was law. We may regret it but we cannot deny that it was law.”57
In Nazi Germany, wrote Heinrich Rommen, “all attempts at passive and active resistance to the regime were necessarily grounded on natural law ideas or on divine law, for legal positivism as such could offer no foundation.”58 The Nazi regime is but one of numerous examples to illustrate the reality that when the State rejects God and his natural law, that State will make itself the god.
In his third encyclical, Caritas in Veritate, Pope Benedict XVI said, “[T]he natural law…. provides a sound basis for all cultural, religious and political dialogue, and it ensures that the multi-faceted pluralism of cultural diversity does not detach itself from the common quest for truth, goodness and God.”59 “Without God,” he concluded, “man neither knows which way to go, nor even understands who he is.”60
1 John Paul II, March 16, 2002.
2 Francis Canavan, S.J., Commentary, Catholic Eye, Dec. 10, 1987, p. 2.
3 Summa Theologica (ST) I, Q. 2, art. 3.
4 Pope Benedict XVI, Address at the University of Regensburg, Sept. 12, 2006.
5 Pope Benedict XVI, Address, June 24, 2007.
6 Pope Benedict XVI, Address, March 30, 2006.
7 Deus Caritas Est, no. 28 (b).
8 ST I, II, Q. 90, art. 4.
9 ST I, II, Q. 91, art. 1.
10 ST I, II, Q. 91, art. 2.
11 Veritatis Splendor (VS), no. 44, quoting Pope Leo XIII, Libertas Praestantissimum (1888). 12 ST I, Q. 1, art. 1.
13 ST I, II, Q. 91, art. 4; See CCC, nos. 1961-86.
14 CCC, no. 78.
15 ST I, II, Q. 91, art. 4
16 ST II, II, Q. 2, art. 4.
17 ST I, II, Q. 91, art. 3.
18 3 Dall. 386, 399, 1L. Ed. 648 (1978)
19 ST I, II, Q. 94, art. 2.
23 ST, I, II, Q. 94, art. 2
24 See ST, I, II, Q. 94, art. 2; Heinrich Rommen, The Natural Law (Liberty Fund ed., 1998), 43-45; Thomas E. Davitt, S.J., “St. Thomas Aquinas and the Natural Law,” in Origins of the Natural Law Tradition (1954), 26, 30-31.
25 See VS 63; CCC, nos. 1750-61.
26 Evangelium Vitae (EV), no. 21.27See VS, no. 79.
28 VS, no. 67.
30 VS, no. 52.
31 ST I, II, Q. 94, art. 4.32 VS, nos. 54-64.
33 See VS, nos. 57-64.
34 VS, no. 34.
35 Catechism of the Catholic Church (CCC), no. 1800.
36 See CCC, nos. 1791-92.
37 VS, no. 60. See also, Address, Joseph Cardinal Ratzinger at 10th Workshop for Bishops, Dallas, TX, February 1991.
38 The New York Times, Aug. 15, 1983. Sec. 1, p. 12
39 ST I, II, Q. 20, art. 6.
40 VS, no. 64.
41 32 The Pope Speaks 381 (1987); see also VS, nos. 113-16.
42 ST II, II, Q. 104, art. 6.
43 ST I, II, Q. 95, art. 2.
44 ST I, II, Q. 96, art. 4.
45 Ibid.46 See Juan Williams, Eyes on the Prize: America’s Civil Rights Years, 1954-55 (1967), 61-73.
47 John J. Myers, “The Obligation of Catholics and the Rights of Unborn Children,” 20 Origins, June 14, 1990.
48 EV, no. 74.
49 See note 41.
50 EV, no. 73.
51 Ibid., see also EV, no. 89.
52 ST I, II, Q. 96, art. 6.
53 Hans Kelsen, “Absolutism and Relativism in Philosophy and Politics,” 42 Am. Pol. Sci. Rev. 906 (1948).
54 Ibid. at 913.
55 ST I, II, Q. 96, art. 2.
56 Centesimus Annus, no. 46, quoted in VS, no. 101.
57 Quoted in translation in F.A. Hayek, Law, Legislation and Liberty, Vol. 2, 56 (1976.).
58 Heinrich Rommen, “Natural Law in Decisions of the Federal Supreme Court and the Constitutional Courts in Germany,” 4 Natural Law Forum, 1, 11, n. 26 (1959).
59 No. 59.
60 No. 78.
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