Shofar FTP Archive File: people/i/irving.david/libel.suit/transcripts//Closing_Address.Rampton
This text is excerpted from Day 32 of the trial.
MR RAMPTON: My Lord, I start with this, that if one had read
some of the media reports of this trial, which I realize
that your Lordship probably has not, one might have
supposed that Mr Irving had been dragged into this court
to defend his freedom of expression as an historian.
In fact, of course, that is not so. The history
of the matter is quite the reverse. Professor Deborah
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Lipstadt, an America academic, wrote a book called
"Denying the Holocaust", which was first published in the
United States in 1993. It was then republished by Penguin
Books in this country in 1994. The book contained
trenchant criticisms of Mr Irving's historiographical
methods and his political views and associations.
Mr Irving then issued legal proceedings claiming
aggravated damages for libel and an injunction against
Professor Lipstadt and Penguin. This trial has taken
place only because they decided to defend their right to
publish the truth.
The principal accusations made against Mr Irving
by Professor Lipstadt in her book were, in summary:
first, that Mr Irving deliberately falsified history in
order to make it conform with his ideological leanings and
political agenda, and, in particular, in order to
exonerate Adolf Hitler of responsibility for the Nazi
persecution of the Jews.
Second, that in order to achieve his objective,
Mr Irving distorted historical evidence and manipulated
historical documents.
Third, that Mr Irving had become one of the most
dangerous spokespersons for Holocaust denial.
Last, that he himself held extremist views and
allied himself, with other right-wing extremists, in
particular Holocaust deniers and anti-Semites.
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My Lord, those were undoubtedly serious charges
and, had they been untrue, Mr Irving would clearly have
been entitled to a large sum of money and an order of the
court preventing the Defendants from repeating their
accusations. But, as it turns out on the evidence before
this court, the accusations are true, in every significant respect.
Mr Irving had in the past claimed that there was
a chain or series of documents which showed that Hitler
was innocent of the persecution of the Jews, and in
particular their mass-murder during the War; indeed, that
he was, in fact, "the best friend the Jews ever had in the
Third Reich.
The Defendants decided to put that claim to
the test. They asked a professional historian, Professor
Richard Evans of Cambridge University, to investigate it.
His findings were astonishing. Upon
examination, virtually every single one of the links in
Mr Irving's chain crumbled in his hands, revealing a
falsification of history on massive scale. Equally
revealing was the discovery that each of Mr Irving's
falsifications led to the same end: the exculpation of
Hitler.
In addition, in order to test Mr Irving's
historiography by reference to his work on a topic other
than Hitler -- in a sense, a control sample -- Professor
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Evans examined a number of successive editions of one of
Mr Irving's most successful works, his book on the Allied
bombing of Dresden in February 1945. Here again Professor
Evans found deliberate falsification on a grand scale, all
of it tending to the same result: a gross inflation of
the numbers of German civilians killed in those raids.
The long written submission of the Defendants
which is before your Lordship contains a detailed account
of Professor Evans' findings and the evidence which
supports them. By the Defendants' estimate, there are, in
relation to Hitler alone, as many as 25 major
falsifications of history, as well as numerous subsidiary
inventions, suppressions, manipulations and
mistranslations employed to support the major
falsifications. If those relating to Auschwitz, Dresden
and other matters are added in, the number goes well over thirty.
My Lord, in order to illustrate the
extraordinary nature and extent of these falsifications,
I will give but two examples.
On the evening of 9th November 1938, and through
the night until the following morning, there was an orgy
of violence and destruction against Jews and Jewish
property throughout Germany. This was Reichskristallnacht.
It had been prompted by the assassination in
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Paris of a German diplomat by a young Polish Jew. The
Nazi leadership in Berlin exploited it to the full. It
was orchestrated by the SA and the SS, and the police were
ordered, by Hitler, not to intervene.
Mr Irving has described this pogrom in various
places, but most particularly in his book "Goebbels:
Mastermind of Third Reich", which was published in 1996,
where he devotes a whole chapter to it. In summary, his
account of it is that the whole thing was initiated and
orchestrated by Goebbels, without Hitler's knowledge or
participation; and that when, in the early hours of 10th
November 1938, Hitler found out what Goebbels had done, he
was "livid with rage" and took immediate steps to put a
stop to it. This account purports to be based partly on
the postwar testimony of former Nazis, but principally on
the contemporary documents. On examination of those
documents, Mr Irving's account turns out to be
completely bogus. His use of two of those documents will
suffice to illustrate the point.
On page 276 of his Goebbels book, Mr Irving
writes this:
"What of Himmler and Hitler? Both were totally
unaware of what Goebbels had done until the synagogue next
to Munich's Four Seasons Hotel was set on fire around 1
am. Heydrich, Himmler's national chief of police, was
relaxing down in the hotel bar; he hurried up to Himmler's
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room, then telexed instructions to all police authorities
to restore law and order,; protect Jews, and Jewish
property, and halt any ongoing incidents. I emphasise the
last part of that sentence, to restore law and order,
protect Jews, and Jewish property, and halt any ongoing
incidents.
The reference given by Mr Irving in his book as
his source for this is a telex sent by Heydrich at 1.20 am
on 10th November 1938. In fact, so far from ordering "all
police authorities to restore law and order, protect Jews
and Jewish property, and halt any ongoing incidents", it
read as follows:
"(a) Only such measures may be taken as do not
involve any endangering of German life or property (e.g.
synagogue fires only if there is no danger of the fire
spreading to the surrounding buildings).
(b) The shops and dwellings of Jews may only be
destroyed, not looted. The police are instructed to
supervise the implementation of this order and to arrest looters.
(c) Care is to be taken that non-Jewish shops in
shopping streets are unconditionally secured against damage.
(d) Foreign nationals may not be assaulted even if they are Jews."
That was what Heydrich stayed at 1.20 a.m. on
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10th November 1938.
Then, on page 277 of his book, after a colourful
account of Hitler's supposedly furious intervention,
Mr Irving writes this: "At 2.56 am Rudolf Hess's staff
also began cabling, telephoning, and radioing instructions
to gauleiters and police authorities around the nation to
halt the madness", and I emphasise those words.
The source given by Mr Irving for this is a
report made by the Nazi Party Court about the pogrom in
February 1939. It records this order from Hess's office,
made on Hitler's authority. This shows that, in truth,
all that the order forbade was the continuing of arson
attacks on Jewish shops. Synagogues, houses, apartments,
cemeteries, and, in particular, Jewish people were left to
the mercy of the continuing violence.
As your Lordship knows, there was an aftermath
of Reichskristallnacht. Mr Irving describes one aspect on
page 281 of Goebbels in these terms:
"Hess ... ordered the Gestapo and the party
courts to delve into the origins of the night of violence
and turn the culprits over to the public prosecutors".
Thus Mr Irving gives the impression that those
who had perpetrated the violence were to be brought to
justice and properly punished.
Nothing could be further from the truth. As the
contemporary documents, and in particular the Party Court
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report of February 1939, which Mr Irving himself used as a
principal source for his account of Reichskristallnacht, reveal:
First, the Ministry of Justice ruled, on 10th
November 1938, that those who had "merely" caused damage
to Jewish shops, synagogues and the like should not be
prosecuted at all.
Second, other more serious offences, such as
looting, rape, assault, murder and the destruction of
Jewish homes for selfish motives were to be referred to
the Party Court, which would first decide whether any of
the offenders should be referred to the ordinary criminal
courts or acquitted by order of the Fuhrer.
Third, in the event, as was no doubt intended,
the proceedings of the Party Court were a farce. Of 16
cases dealt with in the report of February 1939, 14 were
disposed of with little more than a rap on the knuckles
for the culprits, including 13 cases of murder involving
the deaths of 21 Jews. The two cases which were referred
to the criminal courts were sexual offences against Jewish
women - not because of their gravity, however, but because
the offenders had been guilty of "racial defilement" (Rassenschande)!
Finally, the reason the Party Court gave for its
leniency in the other 14 cases was that the criminals were
in fact "only carrying out the unclearly expressed but
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properly recognized will of the leadership" - that is, Hitler.
Mr Irving knows all of this, but suppresses it entirely in his book.
The second striking example, amongst many, of
Mr Irving's shocking falsification of history relates to 1943.
By the beginning of 1943, many of Europe's Jews
had already been murdered. Hungarian Jews, however, of
whom there were perhaps 600 to 700,000, had, so far,
escaped the destruction. The reason was that the ruler of
Hungary, Admiral Horthy, although Hitler's ally, had
steadfastly refused to deliver up Hungary's Jews. There
was much agitation about this in Berlin. Eventually, on
16th and 17th April 1943, Hitler and his Foreign Minister,
Ribbentrop, summoned Admiral Horthy to Klessheim, near
Salzburg, in order to put pressure on him to surrender the
Hungarian Jews into Nazi hands. The notes of the meetings
were taken by a man called Paul Schmidt and are agreed by
Mr Irving, who used them for his own accounts of these
meetings, to be very reliable.
According to Schmidt's notes at the first
meeting on 16th April, Horthy protested at the Nazi
leader's demands. "But they" (the Jews) "can hardly be
murdered or otherwise eliminated", he said. Hitler's
response was palliative: "There is no need for that", he
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said, and added that they could be sent to remote work
camps or down the mines."
The next day, 17th April 1943, Hitler's and
Ribbentrop's demands became a good deal cruder. Horthy
again protested that he "surely couldn't beat the Jews to
death". Ribbentrop replied that they "must either be
annihilated or taken to concentration camps. There is no
other way". Hitler then followed up with this:
"Where the Jews are were left to themselves, as
for example in Poland, gruesome poverty and degeneracy had
ruled. There were just pure parasites. One had
fundamentally cleared up this state of affairs in Poland.
If the Jews there didn't want to work, they were shot. If
they couldn't work, they had to perish. They had to be
treated like tuberculosis bacilli, from which a healthy
body could be infected. That was not cruel", said Hitler,
"if one remembered that even innocent natural creatures
like hares and deer had to be killed so that no harm was
caused. Why should one spare the beasts who wanted to
bring us Bolshevism once more? Nations who did not rid
themselves of Jews perished".
Mr Irving's account of this exchange in his 1977
edition of "Hitler's War" (at page 509) is extraordinary.
First, as an invented pretext for Hitler's remarks, he
introduces the Warsaw Ghetto uprising, which did not in
fact begin until two days later. Then, immediately
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following Hitler's brutal assertion of the need to kill
the Jewish "beasts", Mr Irving adds this:
"Horthy apologetically noted that he had done
all he decently could against the Jews: 'But they can
hardly be murdered or otherwise eliminated', he
protested. Hitler reassured him: 'There is no need for
that'. But just as in Slovakia, they ought to be isolated
in remote camps where they could no longer affect the
healthy body of the public; or they could be put to work
in the mines, for example. He himself did not mind being
temporarily excoriated for his Jewish policies, if they
brought him tranquillity. Horthy left unconvinced."
As, my Lord, will immediately be apparent, this
was a quite brazen piece of manipulation: as Mr Irving
knew perfectly well, because he was familiar with
Schmidt's notes, this exchange had, in fact, occurred on
the previous day (16th April), not 17th. It is apparent,
therefore, that Mr Irving quite deliberately transferred
it to 17th April in order to mitigate the chilling impact
of Hitler's stark observation about the need to kill the
Jewish "beasts".
The account given in the 1991 edition of
"Hitler's War" (at pages 541 to 542) is no better. True,
the spurious reference to the Warsaw uprising has been
removed. But so, too, has Hitler's repellant analogy
between the need to kill animals which cause damage and
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the need to kill the Jewish "beasts". And the brazen
transfer that Hitler's palliative remark on 16th April to
this meeting on 17th is perpetuated.
My Lord, these two examples are but the tip of a
large iceberg imposed of numbers of other equally
egregious falsifications by Mr Irving in his written work
and in his public utterances.
I conclude here, my Lord, with this, that the
Defendants say, on this part of the case: "Case proved:
Mr Irving is, as was proposed at the outset of this trial, a liar".
My Lord, it might be thought that that would be
enough to dispose of Mr Irving's claim, given the emphasis
he places on the damage to his reputation as an historian
which he says was caused by Professor Lipstadt's book.
But the evidence in the case has covered a lot of other
topics as well, and I shall, therefore, briefly mention
them too.
Until 1988, Mr Irving had accepted the
historical reality of Holocaust, but denied that Hitler
authorized it or, until late on in the War, knew anything
much about it. This position, for an historian, was
described by Sir John Keegan, the well-known military
historian, who was called on subpoena to give evidence in
this court by Mr Irving, it was described as "perverse"
and as "defying reason." Dr Peter Longerich, a
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distinguished historian of the period, who gave expert
evidence for the Defendants, called it "absolutely absurd".
And so it was, for reasons which can be stated
quite shortly.
The Holocaust - that is the systematic mass
murder of millions of Jews, gypsies and others - took
place in stages.
The first stage, beginning in the autumn of
1941, after Hitler's invasion of the Soviet Union,
consisted of mass shootings carried out specially-formed
SS groups and their local allies. This continued through
into 1942 and resulted in the deaths of up to 1.5 million
Jews living in Russia and the Baltic states.
The second stage, which began in December 1941
and continued through into 1943 or later, consisted of the
gassing of the Jews of the Warthegau and Poland. This
resulted in the deaths of probably as many as 2.6 million
Jews (300,000 in the Warthegau and 2.3 million in
Poland).
The third stage, beginning with mass
deportations to the East in the autumn of 1941, culminated
in the deaths by gassing, mostly at Auschwitz, of Jews
from Central, Western and Southern Europe. This stage
lasted until late 1944. Reliable recent estimates of the
numbers gassed at Auschwitz/Birkenhau give a figure of
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about 1.12 million.
Thus the total achievement of this horrendous
exercise in systematic mass murder was probably somewhere
between five and six million innocent lives.
The whole of this gigantic operation was
orchestrated by Heinrich Himmler, the Reichsfuhrer SS, and
his able subordinates, such as Heydrich, Globocnik and Eichmann.
As Dr Longerich explained in court, Hitler and
Himmler were long-time intimate associates. Himmler had
been with Hitler during the 1923 putsch and Hitler
appointed him Reichsfuhrer SS in 1929. Throughout the
War, and certainly while the Holocaust was underway, they
met frequently, sometimes two or three times a week, often
for hours at a time and often alone together. It is,
therefore, wholly inconceivable that during the whole
three and a half years for which the killing lasted,
Himmler could, or indeed would, have concealed from Hitler
the enormous, systematic operation that he was directing.
This becomes all the less credible when it is
remembered, as the documents show, that Hitler was the
mainspring and driving force of Nazi anti-Jewish policy
from 1923 onwards and that his anti-Semitism became
noticeably more radical, if that were possible, from the
date that he declared war on America (11th December 1941).
Thus, leaving aside all the specific evidence to
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be found in the contemporary documents, including
documents written by Himmler himself, which, fairly read
by an open-minded, careful historian, plainly implicate
Hitler, the overall picture is compelling: the Holocaust
could not possibly have happened without Hitler's
knowledge and authority. It takes only a moment's light
reflection to realize that the contrary idea is both
absurd and perverse: suppose, say, in July 1942, when
Himmler went to Lublin and Auschwitz to review and advance
the mass killing in Poland, and on his return had lunch
with Hitler (as he did) that Hitler, previously in a state
of complete ignorance, and in any case opposed to any
Final Solution that involved any more than deportation of
the Jews to Siberia or Central Africa after the War, had
suddenly found out what Himmler was doing. What, one
wonders, would have happened to Himmler? Well, of course,
it didn't, not then or at any time thereafter.
In 1988 Mr Irving's position changed
dramatically. Not only did Hitler not know about the
Holocaust, the Holocaust did not happen (which is why, of
course, Hitler did not know about it).
The question is why? Why this change in
Mr Irving's position? The one-word answer is: Leuchter.
In April 1988, Mr Irving went to Canada, for reasons best
known to himself, to give expert evidence at the trial in
Toronto of a man called Ernst Zundel, a dedicated
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Holocaust denier, and since 1988, one of Mr Irving's
staunchest allies and promoters. While he was in Toronto,
he met a man called Fred Leuchter, also proffered by
Zundel, but rejected by the Canadian court, as an expert
witness. Leuchter was, it seems, some kind
of consultant on execution facilities in the USA. He'd
been to Auschwitz and Birkenau to seek "scientific"
evidence of the existence of homicidal gas chambers. He
made a report on his findings.
Mr Irving gave this report a cursory reading.
His conversion was instantaneous. Even as he gave
evidence to the Canadian court, the Holocaust had suddenly
never happened.
In June 1989, Mr Irving gave a press conference
in London, triumphantly announcing the English publication
of the Leuchter Report, with a foreword written by
himself. In his foreword, Mr Irving trumpeted the virtues
of the Report, with particular emphasis on the chemical
analysis of the samples which Leuchter had brought back
from Auschwitz/Birkenau. "Forensic chemistry" proclaimed
Mr Irving, "is an exact science".
And, my Lord, indeed so it is. Fred Leuchter
had taken samples from the remains of the gas chambers and
one sample from the delousing facility in the women's camp
at Birkenau. The samples from the gas chambers showed
small, but significant, traces of cyanide, the active
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element in the Zyklon-B pellets used for the gassings, the
sample from the delousing facility, relatively high
traces. Therefore, concluded Leuchter, the "gas chambers"
could never have been gas chambers, because, according to
Leuchter, the concentration of hydrogen cyanide needed to
kill humans was higher than that needed to kill lice.
The Leuchter report (as Mr Irving has accepted
during this trial) was riddled with numerous errors of
various kinds, but this error was colossal. As the
material contained in the Leuchter report itself showed,
the concentration of hydrogen cyanide required to kill
humans is, in fact, some 22 times lower than that required
to kill lice. Thus, so far from disproving the existence
of homicidal gas chambers at Auschwitz, the Leuchter
Report actually succeeded in proving the opposite.
Despite this, Mr Irving continued to cling, and
still clings, to Leuchter's "forensic chemistry" as the
flagship of his Holocaust denial. In consequence,
Mr Irving has, ever since 1988, used the Leuchter Report
as the foundation not only for his denial of the existence
of any homicidal gas chambers at Auschwitz, but also,
quite illogically, for the existence of any gas chambers
anywhere.
In the end, at the trial of this action,
Mr Irving has been driven, in the face of overwhelming
evidence presented by Professor Robert Jan van Pelt,
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Professor Christopher Browning and Dr Longerich, to
concede that there were indeed mass murders on a huge
scale by means of gassing at Chelmno in the Warthegau and
at the Reinhardt camps of Belzec, Treblinka and Sobibor;
and even that there were "some gassings" at Auschwitz.
His last remaining defence against the evidence
showing that the crematoria at Birkenau were used to
murder vast numbers of Jews by means of Zyklon B was to
make the slippery concession that the gas chambers --
known as Leichenkeller I at crematoria II and III at
Birkenau -- were, indeed, gas chambers, but for gassing
only (I quote Mr Irving's words) "objects and cadavers".
This last proposition is ludicrous. If this
were not such a serious matter, it would be hilarious.
For the evidence, clearly explained by Professor van Pelt,
is that the gas-tight doors in Leichenkeller I at both
those crematoria were equipped with thick glass spyholes,
protected by metal grilles. Why, it was asked of
Mr Irving, should these be required for the observation of
the gassing of lice-infested "objects" and corpses? Faced
with this, Mr Irving retreated to the position that
Leichenkeller I had been intended to serve an alternative
purpose as an air-raid shelter. This last refuge will be
dealt with shortly below. Meanwhile, Professor van Pelt
also explained that when the plans of crematoria II and
III were redesigned in late 1942 and early 1943, the
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corpse-slides or chutes appearing on the original plans
were removed, and the entrance to the basement moved to
the other side of the building. Thus, if the re-design
was intended to facilitate the gassing of corpses, people
who are already dead, it had only succeeded in compelling
those who were carrying the corpses to negotiate a series
of small rooms, narrow passages, and staircases to reach
the gassing-space. Moreover, the plans were re-designed
at that time so as to change the way in which the doors of
the gassing-space opened from inwards to outwards, thus
further impeding the carrying of corpses into the space.
Mr Irving's air-raid shelter proposal is equally
absurd. It is obvious that the Leichenkellers could never
have served as air-raid shelters for an inmate population
of 100,000 or more, even if it thought likely that the SS
should have wanted to protect the inmates against
air-raids. Therefore, if the Leichenkellers were ever
intended to be used as air-raid shelters, they must have
been intended for the SS. In fact, crematoria II and III
are about one and a half miles from the nearest SS
barracks. The picture of SS personnel running from their
barracks, round the perimeter wire, in full gear, one and
a half miles to the crematoria, under a hail of bombs, is
just plain daft.
Mr Irving's concession that Leichenkeller I was
indeed a gas chamber is, of course, entirely inconsistent
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with his continued adherence to Leuchter's chemical
analysis as being conclusive evidence that Leichenkeller I
never was a gas chamber. It is also wholly inconsistent
with his final line of defence, which is
that Leichenkeller I could never have been a gas chamber
because the remains of the roof that can be seen at
Birkenau do not show the holes through which the gas
pellets were thrown.
This last line of defence, which emerged at a
very late stage in Mr Irving's Holocaust denial, is, in
any case, easily demolished. In the first place,
Professor van Pelt, who has subjected the remains of the
roof of Leichenkeller I at crematorium II to careful
examination (which Mr Irving has never done), told the
court that the remains are so fragmentary that they do not
allow any firm conclusions to be drawn as to the existence
or non-existence of the holes. Second, if, as Mr Irving
accepts, Leichenkeller I was a gas chamber (for whatever
purpose) it would always have needed apertures for
inserting the Zyklon-B, since it never had any windows and
only one gas-tight door. Third, even if Mr Irving were
right that it was used for gassing objects and corpses,
the concentration of hydrogen cyanide required for this
would have been comparatively high, with the consequence
that the need for tight fitting apertures which could be
opened and closed quickly and easily, would, for the
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protection of those throwing in the pellets, have been all
the greater. Finally, leaving aside all the mass of
eyewitness testimony, there is a coincidence between two
pieces of independent evidence which demonstrates
conclusively the existence of these holes or apertures.
In 1945, a former inmate of Auschwitz, David Olere, an
artist, drew the ground plan of Leichenkeller I in
crematorium III. This drawing shows a zigzag alignment of
the gassing columns in Leichenkeller I. These are the
columns which would have ended in the apertures through
which the gas pellets were inserted. It happens that that
zigzag alignment is precisely matched by an aerial
photograph taken by the Allies in 1944, which was not
released to the world until 1979. There can, therefore,
be no possibility of any cross-contamination
between Olere's drawing and the aerial photograph. No
doubt recognizing this, Mr Irving sought to suggest at
this trial that the aerial photograph had been faked by
the CIA. Professor van Pelt, however, explained to the
court that he had had the photograph tested by Dr Nevin
Bryant at NASA and that the result of those tests showed
conclusively that the photograph was authentic.
In the light of Mr Irving's concession that
Leichenkeller I was indeed a gas chamber and of the fact
that it is clear that it was never intended for the
gassing of corpses or other inanimate objects, or for use
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as an air-raid shelter, the stark conclusion can only be
this: It must have been used for gassing people, live people.
One residual shred of this aspect of Mr Irving's
Holocaust denial remains. He disputes the numbers of
people murdered at Auschwitz/Birkenau. This last
barricade of Mr Irving's is based on three
distinctly unstable legs.
The first leg is the so-called "death books"
released in recent years from the archive in Moscow.
These are incomplete. They show a total of some 74,000
recorded deaths from various causes. They relate,
however, and could only ever relate, to the deaths of
prisoners registered upon arrival at Auschwitz, that is to
say, those destined to be accommodated in the camps at
Auschwitz and, more particularly, Birkenau, as workers
(for a time at least).
There was, however, a preliminary process at
Auschwitz, which involved separating those deemed to be
fit for work from the rest. This was called "selection".
The vast majority, including the old, young children, and
mothers with small children, were "the rest". They were
gassed immediately without ever being registered; their
deaths were never recorded.
There is a great deal of eyewitness evidence
about this from both sides, perpetrators and surviving
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victims. This evidence is confirmed by photographs taken
by the SS during the so-called "Hungarian action" in the
course of which, over a matter of months, some 400,000
Hungarian Jews were gassed, in the summer of 1944. Thus,
once again, eyewitness evidence is corroborated by
contemporary documentary evidence.
In the result, the fact that the "death books"
fail to record the deaths of perhaps 1 million people
killed on arrival is unsurprising and inconsequential.
The second leg of Mr Irving's last barricade
consists of German police radio messages decoded by the
British during the war. Some of these came from
Auschwitz, and of course none mentioned gassings. For
exactly the same reasons as the death books make no
reference to those murdered on arrival, it is not
reasonable to expect that the radio messages from
Auschwitz would: people who were not registered on
arrival at Auschwitz because they were not destined for
work in the camp but, instead, for immediate death in the
gas chambers, would obviously not be mentioned in messages
about recorded deaths.
The last leg in the barricade is Mr Irving's
contention that Auschwitz did not have sufficient
incineration capacity for all the corpses of those whom it
is generally held by historians were killed there. As
Professor van Pelt convincingly demonstrated, by reference
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to a letter of 28th June 1943, from Karl Bischoff, the
head of the building programme at Auschwitz, to Berlin,
the potential incineration capacity at Auschwitz/Birkenau
at that time far exceeded any possible mortality rate
amongst the registered inmates from "natural"
causes, including the possibility of a repeat of the
typhus epidemic which had struck the camp in 1942. This
means that the incineration capacity must have been
calculated and built, as it was in due course, to
accommodate the mortal remains of the hundreds of
thousands of people who were gassed on arrival.
Faced with this, Mr Irving's only possible
response was (as ever) to challenge the authenticity of
the Bischoff letter. This challenge, in the end, turned
out to be based on nothing more than the fact that the
administrative reference on the letter did not contain the
year date. In fact, copies of this document have been
retained in the archive at Moscow since 1945, when the
Soviets liberated Auschwitz and acquired the documents
which the SS had forgotten to destroy. Moreover, the
document was used at the trial of the Auschwitz
commandant, Rudolf Hoess, in 1948, and again at the trial
of the Auschwitz architects, Dejaco and Ertl, in 1971.
Not unnaturally, Professor van Pelt saw no reason
whatsoever to doubt the authenticity of the document.
Amongst other reasons for rejecting Mr Irving's proposal
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that the document might be a postwar communist forgery, is
the fact that the incineration capacity shown in the
document -- that is 4,756 corpses per 24 hours -- is
very significantly lower than that estimated by the
Soviets and the Poles (both communist regimes) shortly
after the War. It follows that if the document were a
communist forgery, it would be a very strange one.
Mr Irving's last challenge to the incineration
capacity was that the amount of coke delivered to
Auschwitz at the relevant time would not, in the ordinary
way, have been sufficient to meet the required rate of
incineration. As Professor van Pelt demonstrated, this
challenge is demolished by two considerations which
Mr Irving had evidently ignored: first, the procedure for
incineration at Auschwitz involved the simultaneous
incineration of up to four or five corpses even in every
muffle of the ovens; and, second, in consequence, the
corpses themselves served as fuel for the ovens, the more
particularly so if, as they generally did, they included
the comparatively well fed corpses of people recently
arrived on the trains and gassed on arrival.
Mr Irving's Holocaust denial is thus exposed as
a fraud. It originated with a piece so-called scientific
research which, on analysis, turns out, if it has any
value at all, to support the overwhelming historical
evidence that Auschwitz was indeed a gigantic death
. P-29
factory. Mr Irving's later adornments to his gas chamber
denial also turn out to be fragile conjectures based on no
significant research at all: it should be noted that
Mr Irving has never himself been to Auschwitz to examine
the archeological remains or the documentary evidence
contained in the archive. It follows that some other
reason must be sought to explain his devotion, over many
years, and even in this court, though his case has changed
and changed back again throughout the trial, to the
bizarre idea that no significant numbers of people were
murdered in the homicidal gas chambers at
Auschwitz/Birkenau. The reasons are not far to seek.
As the evidence in this court has shown,
Mr Irving is a right-wing extremist, a racist and, in
particular, a rabid anti-Semite.
Two examples, again, amongst many, will suffice
to illustrate this proposition.
In a speech which he made at Tampa, Florida, on
6th October 1995 to the National Alliance, a white
supremacist and profoundly anti-Semitic group, Mr Irving
said this about the Jews:
"You have been disliked for 3,000 years. You
have been disliked so much that you have hounded from
country to country, from pogrom to purge, from purge back
to pogrom. And yet you never ask yourselves why you are
disliked, that's the difference between you and me. It
. P-30
would never occur to you to look in the mirror and say
"Why am I disliked, what is it the rest of humanity
doesn't like about the Jewish people, to such an extent
that they repeatedly put us through the grinder?" And he
(a heckler whom Mr Irving said he had perceived to be
Jewish) went beserk, said Mr Irving. He said (the
heckler), "Are you trying to say that we are responsible
for Auschwitz ourselves"? And I, that is Mr Irving, said,
"Well, the short answer is yes". The short answer I have
to say is yes ... If you (the Jews) had behaved
differently over the intervening 3,000 years, the Germans
would have gone about their business and would not have
found it necessary to go around doing whatever they did to
you. Nor would the Russians, nor the Ukranians, nor the
Lithuanians, Estonians, Latvians, and all the other
countries where you've had a rough time. So why have you
never asked yourselves that question?" So much for the Jews.
As to the blacks (and homosexuals), Mr Irving,
in an entry in his private diary on 10th November 1987, on
the occasion of a visit to South Africa, recorded his own thoughts:
"God works in mysterious ways, but here (that is
South Africa) we agree he appears to be working
remorselessly towards a Final Solution which may cruelly
wipe out not only blacks and homosexuals, but a large part
. P-31
of the drug addicts and sexually promiscuous and
indiscriminate heterosexual population as well."
These examples, again the tip of, I am afraid, a
very large iceberg, demonstrate, beyond doubt, that
Mr Irving is a profound racist and a radical anti-Semite.
But this is not the end of the story. For many years,
Mr Irving has travelled about the world giving vent to his
views at gatherings composed of, and organized by, others
of similar opinion.
Until he was banned in 1993. Mr Irving's
energies were particularly devoted to the propagation of
his ideology in Germany, where pro-Nazi sentiment has not
only persisted but alas, since reunification, undergone a
significant revival, particularly in the East.
This is chilling exposed by a demonstration of
neo-Nazi boot boys, waving Nazi flags and chanting racist
slogans, which was addressed by Mr Irving at Halle in East
Germany in November 1991. In his diary Mr Irving
described his speech at this rally as "rabble rousing", no
doubt for good reason. The speech was greeted with
enthusiasm, not least, perhaps, because he predicted the
recreation of a greater Germany, by the reconquest,
through economic power, of the former Third Reich
territories in the East. This speech was greeted with
enthusiasm and, unsurprisingly, shouts of "Sieg Heil!".
Holocaust denial is forbidden in Germany
. P-32
(notwithstanding which Mr Irving has, from time to time,
managed to slip in direct statements that there were never
any gas chambers). Elsewhere, however, it has been a
constant theme of Mr Irving's public utterances. He has
expressed it, on numerous occasions, in terms which
variously attribute the blame for the Holocaust on the
Jews themselves, accuse Holocaust survivors of lying in
order to extort money from the German Government, and pour
scorn on the suffering of Holocaust victims, both alive
and dead. These utterances are often greeted with warm
applause and loud laughter by his audiences.
Given that Mr Irving has repeatedly falsified
history in pursuit of his obsessive desire to exonerate
Hitler of responsibility for the Nazi persecution of the
Jews and, in particular, of responsibility for the
Holocaust, and given that he has repeatedly denied the
Holocaust, without any historical foundation, and in the
face of overwhelming evidence that the Holocaust took
place on the scale and in the manner generally described
by reputable historians, the question now arises why
Mr Irving should have engaged so actively in the promotion
of these historical falsehoods.
The answers suggested by the evidence are:
Mr Irving is an anti-Semite; Holocaust denial, in the form
in which it is purveyed by Mr Irving, is an obvious
expression of anti-Semitism, and is music to the ears of
. P-33
the neo-Nazis and other right-wing extremists to whom he
purveys it; Mr Irving is a Hitler partisan, who has
falsified history on a staggering scale in order to
"prove" Hitler's innocence; this, like Holocaust denial,
is obviously very appealing to his fellow travellers --
after all, if the Holocaust were a "myth", then,
obviously, Hitler could have no responsibility for it.
How far, if at all, Mr Irving's anti-Semitism is
a cause of his Hitler apology, or vice versa, is quite
unimportant. Whether they are taken together, or
individually, it is clear that they have led him to
prostitute his reputation as a serious historian (spurious
though it can now be seen to have been) for the sake of a
bogus rehabilitation of Hitler and the dissemination of
virulent anti-Semitic propaganda.
MR JUSTICE GRAY: Mr Rampton, can I raise with you now the
points I think I need to clarify?
MR RAMPTON: Yes.
MR JUSTICE GRAY: I do not think it will take very long. There
is just one point that occurred to me as you were reading
out the statement, and it relates to paragraph 41, where
you are dealing with incineration capacity.
MR RAMPTON: Yes.
MR JUSTICE GRAY: The point you are making is that it is
strange to suggest that the Bischoff document is a
communist forgery, since it shows a rate of incineration
. P-34
lower than was estimated by the Soviets and the Poles. Am
I right in thinking that the estimate you are there
talking about by the Soviets and the Poles is the estimate
of the total numbers killed, rather than of incineration
capacity or rate of incineration?
MR RAMPTON: No, my Lord. Well, I think that is partly right,
if I may say so. But also on page 207 of Professor van
Pelt's report, there is rather a dense paragraph.
I cannot remember now off the top of my head how the
answers come out. There is rather dense paragraph from
which one can certainly work out, and I know Professor van
Pelt told me what the totals were by but I have forgotten
them. One can certainly work out that the 4,756 corpses
per 24 hours was significantly lower than the Russian and
Polish estimates for incineration. I think the Russian
figure was 50 per cent higher and the Polish figure about
30 per cent higher.
MR JUSTICE GRAY: Thank you very much. I did not know that.
You have given me the reference so that has dealt with
that. The other questions are really all rather broader
ones. Can I take them in what I hope is the sensible
order? The first one relates to deportation, and I will
ask Mr Irving the same question in due course. It is not
really clear to me what, if any, is the issue between the
parties as to that particular phase.
MR RAMPTON: No. I have never understood that there was.
. P-35
MR JUSTICE GRAY: No.
MR RAMPTON: Dr Longerich told your Lordship, and we accept, we
have to, he knows a lot more about it than we do, that in
the beginning the transportation of the German and other
central European, French and Greek, Italian Jews was just
to the East, where they were put into ghettoes which had
been vacated by the murder of the Polish Jews.
MR JUSTICE GRAY: A sort of two phase deportation exercise?
MR RAMPTON: Yes. Then eventually, probably sometime in 1942,
they started killing the arrivals. There is a notable
document your Lordship will remember from the Gestapo at
Lodz, explaining how they cleared one lot and made room
for the other lot.
MR JUSTICE GRAY: Yes. Leaving aside the extermination, which
is a separate issue and I understand what Mr Irving says
about that, you do not understand there to be any argument
or dispute between the Defendants and Mr Irving as to the
fact that the deportation took place, and indeed also as
to the fact that Hitler knew about it, because it is
Mr Irving's case that that was all that was involved.
MR RAMPTON: No question. Hitler gave the order for it. As
your Lordship will have seen, in one of the passages in
our long submission, we draw attention, I forget which
book it is, to a statement by Mr Irving where he says
Hitler was neither consulted nor knew anything about the
deportations. Why he should say that, I have absolutely
. P-36
no idea, but the fact is that Hitler gave the order.
MR JUSTICE GRAY: That was Hitler's preferred solution, as
opposed to extermination, according to Mr Irving's argument.
MR RAMPTON: In 1941 it may or may not be so, so far as the
German Jews are concerned.
MR JUSTICE GRAY: Yes.
MR RAMPTON: So far as the rest, anyway.
MR JUSTICE GRAY: I noticed something this morning which I had
not noticed before, which is that -- have you got your
more detailed written submissions?
MR RAMPTON: Yes, I have.
MR JUSTICE GRAY: Would you go to Tab 5 (i)?
MR RAMPTON: Yes.
MR JUSTICE GRAY: There is at page 56, paragraph 4, which seems
to continue over the page on page 57.
MR RAMPTON: Yes, it does.
MR JUSTICE GRAY: The next paragraph is 12. I see what I have
done. Yes, there is an 11 somewhere lurking way back.
MR RAMPTON: Paragraph 11 is on page 53. It has a large number
of subparagraphs.
MR JUSTICE GRAY: Yes. The next broad question is this. I am
really asking for perhaps a bit of assistance on this. It
is what we have called the genesis of the gassing
programme, or the extermination programme.
MR RAMPTON: Yes.
. P-37
MR JUSTICE GRAY: And what you have done, and this is your
(ii), is very helpfully to set out what you say are
gathered together from various files the various
documentary references which demonstrate the setting up of
the gassing in the Reinhardt camps and so on.
The slight problem I have with this way of
dealing with it is that one has to try to confine the
judgment within some sort reasonable bounds -- it is going
to be horrifically long anyway -- and I do not think it is
feasible to even begin to try to incorporate all those
references. It would just overload it.
MR RAMPTON: No, we were not expecting that your Lordship
would, of course not. It seemed to us, though, that now
that one -- I mean, I am only a lawyer too -- had the
chance to look at the thing with some considerable care,
that that table led the eye through the stages really
quite well; but if that is not so, then all I perhaps need
to do is to refer your Lordship back to the little summary
that I have given in this latest statement starting on page 10.
MR JUSTICE GRAY: Yes, but I think the problem is what I would
really ideally want to aim at myself in order to give
anyone reading the judgment a sufficient but not
overextended view of what the documents show to have
happened is something in between the two.
MR RAMPTON: I think what I am being asked ----
. P-38
MR JUSTICE GRAY: You will think I am by very awkward.
MR RAMPTON: No, of course not. I do not know how much time I
have, that is all. What I think I am being asked for and
will willingly supply -- I might even get Dr Longerich to
write it actually -- is really a chronological summary
with a bit more detail than I have put in here and a bit
less than I have put into the main submission.
MR JUSTICE GRAY: I think that is probably right. Really in a
way it perhaps will highlight the most significant
documents. I think it is right, I mean, as you realize,
I have been trying to sort of keep a tag on what the
evidence has revealed as it has gone on, so I think I have
quite a lot of them, but I suspect I am missing some of
the important ones and I would like to ----
MR RAMPTON: Yes, I mean, I do not say I have covered
everything either.
MR JUSTICE GRAY: Can I invite you to do that? Not at enormous
length, but I think it would be helpful.
MR RAMPTON: We will do it in the course of the rest of this week.
MR JUSTICE GRAY: And bearing in mind, if I may suggest it, the
issues that arise on the genesis of the gassing as opposed
to Auschwitz, which I will deal with separately, seem to
me to be, firstly, on what scale the extermination took
place, and that is not really much of an issue now, as I
understand Mr Irving's case.
. P-39
MR RAMPTON: Not an issue at all.
MR JUSTICE GRAY: But also Hitler's knowledge. So that is the
thing to concentrate on, and I appreciate to some extent
that may not any longer be as stark an issue as it was.
MR RAMPTON: That is covered specifically, not only with what
I said today in general terms, but there was an exercise
that I did in re-examination with Professor Longerich
which is referred back to in here, just that really the
month of July and into August 1942, which demonstrates in
Professor Longerich's view, which we obviously adopt, that
it is inconceivable that while Himmler was supervising the
mass extermination of goodness knows how many people in
the General Government Hitler did not know about it.
MR JUSTICE GRAY: Yes. One of the things I was going to ask
Mr Irving is whether he accepts the concessions that you
attribute to him at various stages of your submission.
MR RAMPTON: I have given the reference to it somewhere in here.
MR JUSTICE GRAY: You have, indeed, but I think it is right it
should be put to him.
MR RAMPTON: I mean, what he says now, his position has changed
throughout the case, but really the concessions, if I may
say this now, which we have listed in various places in
this long submission are those which were first driven out
of him by cross-examination, no cleverness on my part, but
by the evidence which was presented to him, and it was not
. P-40
selective, in cross-examination. His first reaction,
eventually in some case, sometimes quite quickly, was to
say, "Yes, are you right, it did happen".
MR JUSTICE GRAY: Yes, but I must find out what the up-to-date
position is because I think it is fair to say that
sometimes Mr Irving has fluctuated.
MR RAMPTON: As I say, I do not attach much weight to what
I might call back tracking.
MR JUSTICE GRAY: Right. If Professor Longerich can perform
that exercise, but also focus, if he would, on the extent
of Hitler's knowledge and the reason for saying that he
knew about the gassing at Chelmno and all the rest.
The next question is a very short one and
I think I know what your answer is, but I will ask it all
the same: part of your case against Mr Irving is that he
is a racist, leaving aside anti-Semitism, that he is a
racist and you have a number of quotations from his speeches.
MR RAMPTON: Yes.
MR JUSTICE GRAY: How does that bear on (a) the words
complained of, and (b) the meanings that you seek to justify?
MR RAMPTON: I suppose we seek to justify simply that he holds
extremist views in the written bit. In the statement of
case, I cannot remember. It says something ----
MR JUSTICE GRAY: There is a bit right at the back.
. P-41
MR RAMPTON: --- rather more specific than that.
MR JUSTICE GRAY: Perhaps my question really is, there is
nothing about racism, is there, in ----
MR RAMPTON: No.
MR JUSTICE GRAY: --- Professor Lipstadt's book?
MR RAMPTON: Perhaps I should ask her. There is some allusion to it, she says.
MR JUSTICE GRAY: I am not sure there is; if there is, I would like to know what it is.
MR RAMPTON: But, maybe your Lordship is right, there is this
to be said, perhaps, if a man is and out and out racist
which we would propose that it is obvious from his own
private jottings, never mind what he says publicly, that
Mr Irving is, and if anti-Semitism is a form of racism,
which it plainly is, then it is a bit like a case where
you accuse a man of grievous bodily harm and at trial
succeed in proving that he is a murderer.
MR JUSTICE GRAY: Yes. I thought that would be your answer,
that anti-Semitism is just one form of racism.
MR RAMPTON: Yes, indeed.
MR JUSTICE GRAY: And, therefore, it is relevant, you would
say, by way of justification of an anti-Semitic allegation
that there is a general streak of racism to be perceived
in what Mr Irving has said and done.
MR RAMPTON: It is evidence of his general disposition to
disparage and be hostile towards people of different
. P-42
colours, ethnic backgrounds and cultures.
MR JUSTICE GRAY: Yes. Now perhaps, for me, at any rate, the
most important question is to be absolutely clear about
what you are saying in the section which is section 9,
I think, or (ix) towards the back of your written
submission about assessing Mr Irving as an historian.
MR RAMPTON: Yes.
MR JUSTICE GRAY: Do you mind turning it up because I just want
to be absolutely clear about it this because I think it is
exceedingly important. You first refer back to your
historiographical criticisms, and I am right in taking it,
am I not, it is pretty obvious from what you there say by
way of criticism of Mr Irving that a number of the
criticisms are criticisms that he has deliberately
falsified the record.
MR RAMPTON: Every single one.
MR JUSTICE GRAY: All right, every single one. Now, you do not
expressly say so, but you may tell me it is implicit, that
when you deal with his partisanship for Hitler which is
(ii), you do not expressly say that that is all deliberate
distortion and manipulation and so on.
MR RAMPTON: No.
MR JUSTICE GRAY: But that I understand to be your case, am I right?
MR RAMPTON: No, what I say is that he has sought to exculpate
Hitler; that he has done that by a massive falsification
. P-43
of the underlying historical record on a large number of occasions.
MR JUSTICE GRAY: But going beyond what you have selected or
Professor Evans has selected as the historical criticisms?
MR RAMPTON: Then I say if one looks at the general evidence as
an objective, open-minded, careful, dispassionate
historian, that Hitler was, indeed, responsible, knew all
about it, and authorized it, the conclusion is
irresistible that he did. Mr Irving has shut that window,
as it were, and has got on with the shut window behind him
with the falsification of history so as to exculpate Hitler.
MR JUSTICE GRAY: Yes, so this is again another instance of
deliberate manipulation which kind of runs through ----
MR RAMPTON: It is a kind of deliberate blindness to the
evidence. What he does not like, he ignores.
MR JUSTICE GRAY: Deliberate blindness?
MR RAMPTON: Yes, it is deliberate blindness. He knows about,
he has known for years, about report No. 51, for example.
MR JUSTICE GRAY: So it is telescope to the wrong eye?
MR RAMPTON: Yes, and for years, despite report No. 51, until
we got him into this court, until he got us into this
court, he did not accept that Hitler sanctioned the mass
shootings in the East. It is that kind of phenomenon.
MR JUSTICE GRAY: So that the partisanship. Then Auschwitz,
. P-44
well I think it is pretty clear what your case is about that.
MR RAMPTON: Yes.
MR JUSTICE GRAY: You do not specifically rely on the denials
of the Holocaust, but, presumably, you say in relation to
those that they are denials which Mr Irving must have
known were false when he made them.
MR RAMPTON: No, again this is a bit like the sort of general
refusal to accept Hitler's knowledge. What I say about
that is that his denials of the Holocaust have been made
without any reference whatsoever to any reliable evidence.
They started to be made on Leichter which is an obviously
completely hopeless position for any kind of
self-respecting historian or, indeed, anybody else for
that matter. Then much later on down the road he adds in
one or two other things like the death books and the
decrypts. Finally, just before this trial or a year or so
before this trial, he comes to the runes. He has never
been to Auschwitz. He has never looked at any o the
documents or the plans. Such evidence as he knows about
he dismisses out of hand as being mere eyewitness
testimony. When he comes to see an aerial photograph
showing the holes in the roof, he says it is a forgery;
the incineration capacity document is also a forgery, and
so on and so forth. This means that his denial must have
another agenda because it cannot be the product of genuine
. P-45
bona fide historical research and contemplation.
MR JUSTICE GRAY: So his state of mind which is -- and it is
important that I am absolutely clear what it is that is
being suggested in relation to the various issues that
have arisen in the case -- this is an area where you put
it as being deliberately perverse blindness and acting in
pursuance of what is, effectively, a neoNazi agenda, is that right?
MR RAMPTON: Yes, I put it in two ways and I will say it as
shortly as I can. I put it forward as evidence of
somebody who cannot be regarded as a serious historian,
because what he has done is to allow his historical
apparatus to be distorted by something beyond -- extrinsic
or ulterior. Looking at the way in which he expresses
Holocaust denial and the audiences to whom he expresses
that denial and the things that he says on those
occasions, one is driven to the conclusion that the hidden
agenda, the reason for the historical incompetence, if I
can I call it that (though there is a much stronger word
that I could think of) is that he is at root deeply
anti-Semitic and a neo-Nazi, as your Lordship just said.
MR JUSTICE GRAY: Well, that raises the last question that
I wanted to canvass with you, and it is anti-Semitism and,
indeed, the racism and the extremism and all the rest of
it. I find it a little, and I find it throughout the
case, bit difficult to see how, if at all, those
. P-46
allegations against Mr Irving dovetail with the general
allegation that he falsifies to an extent deliberately the
historical record because it seems to me, and I just want
to know how you put it, that if somebody is anti-Semitic,
and leave aside racism, but anti-Semitic and extremist, he
is perfectly capable of being, as it were, honestly
anti-Semitic and honestly extremist in the sense that he
is holding those views and expressing those views because
they are, indeed, his views.
MR RAMPTON: Yes.
MR JUSTICE GRAY: Now, it seems to me that probably, if you
come down to it, that the anti-Semitism is a completely
separate allegation which really has precious little
bearing on your broader and perhaps more important case
that Mr Irving has manipulated the data and falsified the
record, or do you say that they are corrected in some way
and, if so, how?
MR RAMPTON: I propose that they probably are connected. I do
not have to do that, but I propose that they are
connected, and that the link between them, I have no doubt
at all he is genuinely anti-Semitic and all the more
defamatory it is of him to say so, and it is true.
I propose that certainly, that he is genuinely profoundly
anti-Semitic. But the bridge between the Holocaust denial
and the Hitler apology from anti-Semitism is a very easy
one to build, because what more would an historian who is
. P-47
an anti-Semite want to do in exculpation of Hitler which
he has been trying to do by telling lies about history for
years, what more would he want to do than to deny the Holocaust?
MR JUSTICE GRAY: Yes, but he might believe what he is saying.
That is the point. That is why it is important.
MR RAMPTON: Believe what he is saying about what?
MR JUSTICE GRAY: About the Holocaust.
MR RAMPTON: There is no way he could believe what he is saying
about the Holocaust if it ----
MR JUSTICE GRAY: I understand that, but that has nothing to do
with his anti-Semitism. I am not sure I am making my
point clear to you that ----
MR RAMPTON: No, I take a profound anti-Semite, I see that he
has denied the Holocaust without any historical
justification whatsoever.
MR JUSTICE GRAY: But I understand all of that.
MR RAMPTON: Then I ask myself, what is his reason for denying
the Holocaust because he has not got a good historical
one, there must be another one? And the most obvious
thing for a profound and genuine anti-Semite to do because
it suits his book is to leap into Holocaust denial without
any proper evidence at all, any evidence at all, and cart
it around the world in front of him and to audiences at
other anti-Semites and neofascists.
MR JUSTICE GRAY: That is another agenda, you would say?
. P-48
MR RAMPTON: Yes, that is the other agenda; the promotion of anti-Semitism.
MR JUSTICE GRAY: Yes.
MR RAMPTON: And given that there is, as I say, absolutely no
historical foundation, no proper historical foundation,
for Holocaust denial, and given that there is evidence
that Mr Irving is an anti-Semite, as I say, the bridge
between the one and the other is very easy to build indeed.
MR JUSTICE GRAY: Yes, thank you.
MR RAMPTON: And the same goes for Hitler exculpation.
MR JUSTICE GRAY: Thank you very much. Now, Mr Irving, it is your turn.
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