In re Meunier

Facts

• Meunier, a French anarchist, placed bombs in a cafe near a military barracks in Paris and separately at the Cafe Very
• The attacks were indiscriminate, targeting ordinary members of the public
• He fled to England
• France sought his extradition
• Meunier claimed the bombings were political acts motivated by anarchist ideology

Issue

1. Whether indiscriminate anarchist bombings directed against society at large qualified as political offences exempting the accused from extradition.

Held

• The court ordered extradition
• Anarchist acts directed against society as a whole are not political offences
• For the political offence exception, there must be two or more parties contending for political power
• Anarchism targets the entire social order, not a rival political faction
• The Castioni incidental-to-uprising test requires an identifiable political conflict between rival groups

Ratio Decidendi

The political offence exception requires the existence of two or more parties in the state, each seeking to impose its own government. Where acts of violence are directed against the body politic as a whole and against society in general, rather than against a rival political faction, they are not political offences. Anarchist violence, which rejects all governmental authority and targets civilians indiscriminately, cannot satisfy this requirement.