Posted April 29, 1997.

Taiwan's Case for United Nations Membership


by Parris Chang* and Kok-ui Lim**


I. INTRODUCTION


         When Taiwan's Democratic Progressive Party (DPP) was established in 1986 in defiance of then existing martial law, it put the ruling Kuomintang party (KMT) on the defensive by openly advocating UN membership for Taiwan. It was only fifteen years earlier, in 1971, that the KMT (or the Chinese Nationalist) government left the United Nations in disgrace as the world body voted to award China's seat to the government of the People's Republic of China (PRC). The issue of Taiwan's entry into the UN has both galvanized a growing Taiwanese nationalism and framed the debate over Taiwan's status in new terms. It has brought into sharp relief a severe controversy in Taiwan's politics today: is the island a nation state? Or is it part of a divided China, as claimed by the KMT government? The resolution is crucial not only for Taiwan's bid for UN membership, but for the island's future political destiny as well.

         This article will first look at the evolution of customary international law, addressing self-determination, the criteria for statehood, and the UN's efforts at decolonization. It will then address Taiwan's transformation from an unresolved colonial territory to a democratic, de facto state, responding to both advocates for and opponents of Taiwan's UN membership as a "divided Chinese nation." Finally, this article will make a persuasive case for Taiwan's admission into the United Nations as a new state, arguing that the UN credo to free all peoples from colonialism, uphold human rights, and embrace the right of self-determination remains unfulfilled so long as Taiwan's 21 million people are denied a seat in the UN General Assembly.


A. The "Republic of China" Government on Taiwan

         In October 1971, the Kuomintang government1 was compelled to remove its delegation from the UN General Assembly as the communist regime founded in 1949 finally succeeded in replacing the KMT authority as the legal government of China in the General Assembly and Security Council.2 In the late 1960s and early 1970s, many member states, including the United States, Canada, Italy, and Saudi Arabia, sought a compromise that would have allowed Taiwan and the PRC to be represented in the UN under a two-China formula. Both the PRC and the KMT government, based in Taipei, rejected the notion of divided representation, forcing the UN to decide which government represented China.

         Due to the Cold War and other factors, the KMT government was permitted to represent China in the UN for twenty-two years, despite the fact that it had lost the Chinese civil war and ruled only Taiwan. In effect, the KMT regime was calling Taiwan "China" with the acquiescence of the UN.


B. Credentials for Chinese Representation

         When the People's Republic of China was founded in 1949, the communist government in Beijing discovered that recognition was not forthcoming from most major western nations. Forty-three UN members, including the United States and France, still recognized the KMT regime as China's legitimate government, while the PRC was supported by only fifteen members, most of them communist states. Beijing's intervention in the Korean War in 1950 on the side of North Korea and against UN forces was an additional obstacle to its UN bid. The PRC did not try to enter the UN as a new member; instead, it sought to evict the KMT government from China's seat.

         The United States was able to protect its Nationalist ally by keeping the issue of Chinese representation off the agenda of the General Assembly until 1961, when Third World states increased in large numbers in the UN and China gained a greater number of sympathizers. Subsequently Washington continued to block China's admission to the UN by having the issue classified as an "important question," thus requiring a two-thirds majority vote in the General Assembly to place it on the UN agenda for discussion.3 Washington's use of this parliamentary maneuver blocked Beijing's entry to the UN for more than two decades.

         In mid-1971, however, U.S. President Richard Nixon's rapprochement with Beijing quickly undermined Taiwan's precarious position.4 On October 25, 1971, with seventy-six countries in favor, seventeen abstentions and thirty-five against, the People's Republic of China was seated in the UN.5 It should be emphatically noted that Resolution 2758 (XXVI) only determined China's legitimate government, not whether this representation included Taiwan. In other words, the actual representation of Taiwan and its people was not addressed and remains in legal limbo to this day.


II. INTERNATIONAL LAW


A. Background

         In 1945, United States President Harry Truman hosted an unprecedented international gathering of nations to inaugurate the United Nations and address the decolonization of territories, especially those belonging to the defeated Axis powers.6 Although customary international law addressing decolonization and statehood for territories was a new area of law,7 subsequent resolutions of territorial disputes contributed to its development. "Custom," in legal theory, has generally been accepted to mean a "usage felt by those who follow it to be an obligatory one."8 State practice at the time showed that "major colonial powers confirm that they regard the principle of self-determination for colonial peoples as binding."9 Since 1945, the application of international law to unrecognized states has flourished.

         At the same time, the UN's contribution as a non-state actor in balancing the universal right of self-determination with the principle of sovereign domain is recognized as an important one.10 The UN's early decision to adopt the Universal Declaration of Human Rights in December 1948 furthered the cause of individual rights.11 And even though the 1948 Declaration does not expressly mention self-determination, subsequent resolutions passed by the UN indirectly rely on the Declaration in affirming the right of self-determination.12


B. Principles of Law

         International law and its pronouncements on self-determination and statehood are a body of compelling "principles, customs, and rules . . ." imposing obligations on sovereign states and non-state or international organizations in their mutual relationships.13 Sources of international law are set forth in Article 38 of the Statute of the International Court of Justice, a body which serves as an integral component of the UN Charter. The sources are: treaties, custom, general principles of law, judicial and arbitral decisions of previous cases involving international law, writings by scholars in journals, and reviews of international law by similar authoritative sources.14 Nevertheless, compliance with international law is contingent on a voluntary willingness of states to abide by international legal decisions or previous determinations on similar legal disputes.15


C. Requirements for Statehood


         1. Traditional Requirements

         The Montevideo Convention of 1933 lays out the four requirements for de facto status as a state under principles of customary international law.16 These requirements are: (1) the existence of a stable population; (2) a defined territory;17 (3) a functioning government; and (4) a government that engages in foreign relations on behalf of the territory.18


         2. Democracy as an Additional Standing Requirement

         Democracy has emerged in both practice and academia as a non-traditional fifth requirement.19 An unrecognized state strengthens its claim for statehood if there exists a constitutional democracy with political office determined by open elections. The UN's 1960 Resolution on the Granting of Independence to Colonial Peoples and Countries appears to validate a state that, seeking recognition, adheres to democratic elections.20 Professor Chen Lung-chu observes that free elections are "the very essence of 'popular sovereignty' of people: authority comes from people and rests upon the people as a whole, not a handful of purported rulers. Such popular will can be best expressed in free and genuine elections."21 Professor Chen cites the Universal Declaration of Human Rights as "declar[ing] that '[t]he will of the people' forms the bedrock of a government's legitimacy."22

         Of course, the additional requirement of democracy is controversial due to the subjectivity involved in determining whether a particular government is representative.23 For example, China has a totalitarian government which nonetheless enjoys full international legal recognition. Czechoslovakia is another striking example. In 1948, Czech communists overthrew the legitimate government of Czechoslovakia at the instigation of the Soviet Union. Czech ambassador Jan Papanek had his credentials revoked and had to appear before the Security Council in a personal capacity despite the obviously illegitimate foreign interference in his nation's change of regime.24 Nevertheless, the new criterion of democracy is a persuasive factor in the determination of statehood.


D. Self-Determination and Limitations

         Following the end of World War I, U.S. President Woodrow Wilson and the League of Nations believed that self-determination was the moral foundation for a global peace. Self-determination was premised on the right of a people to declare and establish its own sovereign state freely. The definition of a "people" could be based on several criteria: a common history, language, culture, ideology, and/or ethnic and geographic considerations. However, self-determination for a people need not have statehood as its ultimate goal.25 For example, political or religious autonomy might be a common goal in lieu of political independence from an existing state.

         Some states oppose the right of self-determination, fearing that their own minority ethnic groups would be encouraged to seek political independence. This is a legitimate concern based on public policy considerations.26 For example, peace and stability are legitimate arguments for maintaining the integrity of states. But this implies an equally valid corollary: where peace and stability would be enhanced by the recognition of a state, recognition must be extended. In other words, where a central government is no longer capable of substantially upholding law and order on behalf of all of its nationals, then the subcomponents of that failed state should do what is necessary to secure law and order, superseding the central government's desire to maintain integration.27 Alternatively, where a state has lost control of its component "provinces," it has no enforceable right over that disputed territory in international law since it ipso facto does not control or administer the territory.


III. THE UNITED NATIONS


         The United Nations is a representative organ empowered to lay down rules addressing the entire international community. While national sovereignty is the foundation on which international law is built, it is not absolute. Philip Jessup has made a poignant argument for the international rule of law and limitations on absolute sovereignty:

There must be basic recognition of the interest which the whole international society has in the observance of its law. . . Sovereignty, in its meaning of an absolute, uncontrolled state . . . is the quicksand upon which the foundations of traditional international law are built. Until the world achieves some form of international government in which a collective will takes precedence over the individual will of the sovereign state, the ultimate function of law, which is the elimination of force [war] for the solution of human conflicts, will not be fulfilled.28

         To this end of balancing states' rights and international concerns that transcend such rights, the UN has recognized the limits of its authority vis-à-vis the domestic jurisdiction of states.29 But state sovereignty has its limits as well. Judge Kotaro Tanaka of the International Court of Justice wrote that the UN Charter "recognizes the existence of human rights and therefore the concomitant duty to protect and guarantee these rights."30 And, as recently as 1992, UN Secretary-General Boutros Boutros-Ghali reminded the world community that the UN has a central role in preventive diplomacy, peacemaking and peace-keeping that overlaps with state sovereignty.31


A. Colonies and the Trusteeship Council

         The United Nations moved quickly in its early years to end all colonies, whether under trusteeship or other mandates. The first major step taken by the UN was its adoption of the Universal Declaration of Human Rights in December 1948.32 The 1948 Declaration attempted to regulate international behavior and establish obligatory legal norms with regard to the rights of the individual.33 Notable among the UN's sincere attempts to end colonialism is Chapter XI of the UN Charter, which in relevant part reads:

Members of the UN which have or assume responsibilities for the administration of territories whose peoples have not yet attained a full measure of self-government recognize the principle that the interests of the inhabitants of these territories are paramount, and accept as a sacred trust the obligation to promote to the utmost...the well-being of the inhabitants of these territories . . . to this end . . . to develop self-government . . . according to the particular circumstances of each territory and its peoples. . . .34

         In addition, Chapters XII and XIII of the UN Charter specifically address the decolonization of territories. They encourage the promotion and development of a people's livelihood in the goal of "progressive development towards self-government or independence...."35 Any lingering doubt about the gravity with which the UN viewed colonialism was put to rest by its adoption of the Declaration on the Granting of Independence to Colonial Countries and Peoples in 1960.36 It was precisely because of the failure of many reluctant colonial powers to respect the rights of the colonized peoples adequately that the UN adopted the 1960 Declaration.37 Article 2 of the Declaration specifically states that a people have the right to freely determine their political status, among other indivisible rights of self-determination. More recently, a broader interpretation of self-determination based on the 1960 Declaration addresses racial and other forms of discrimination. For example, in the 1977 UN General Assembly Resolution 32/42, racial discrimination and apartheid were condemned as unacceptable behavior impeding the goals of self-determination laid out in the 1960 Declaration.38 In essence, the UN was declaring that racist minority governments were colonial in nature, demonstrating strong international support for multilateral action against authoritarian governments that repress their own people.39


B. UN Membership

         Article 1, paragraph 2 of the UN Charter lists the following among the UN's purposes: "To develop friendly relations among nations based on respect for the principle of equal rights and self-determination of peoples. . . ."40 To date, the UN has accumulated a respectable record in its long campaign to address the injustices of colonization and welcome new member states into its fold. The UN's goal of maintaining international peace and security through mutual understanding and peaceful resolution of conflict is one of its key attributes. As for the admission of new member states, the procedure is straightforward: UN membership is open to any "peaceloving" state that "accepts the obligations of the Charter, and is able and willing to carry out those obligations."41 However, approval by the General Body is contingent on the recommendation of the Security Council.42 In effect, this means that any sitting member of the Security Council can exercise a veto over new membership for any reason. In the past, the rivalry between the United States and the former Soviet Union often carried over to the UN, where each sought to block the other's allies from entry.43 Since 1971, China's objections have precluded Taiwan's membership.


IV. TAIWAN'S HISTORY: UNSETTLED OWNERSHIP


         Taiwan and its outlying islands of the Pescadores, Kinmen, and Matsu comprise an area of roughly 14,000 square miles. The population of 21 million people includes four main ethnic groups: the aborigines, the Hoklo (Fukienese Chinese descent), the Hakka (Chinese descent), and the "[Chinese] mainlanders."44 Archaeological evidence suggests that humans lived on Taiwan as long as 15,000 years ago. The first settlers were aborigines who likely arrived from Polynesian islands and Austronesia. Today, the members of the nine main aboriginal tribes make up one to two percent of the population. Chinese immigration to Taiwan began in the 14th century and peaked in the 1600s. Most of these immigrants came from Fujian (Fukienese) and Canton (Hakka). The Fukienese and Hakka account for roughly 70% and 15% respectively of the current population. Together with the aborigines, these three ethnic groups are collectively referred to as "native Taiwanese"45 based on their long history of settlement in Taiwan. The remaining 15% of Taiwan's population is composed of refugees who fled China with Chiang Kai-shek when Chiang lost the Chinese civil war in 1949.46 These people, and their children born in Taiwan, are known as "Chinese mainlanders." For most of the last fifty years, this "mainlander" minority has enjoyed exclusive political control of the island.


A. Colonial Period

         Taiwan's history since the 17th century has been one of continuous colonial rule by the Portugese, Dutch, and Japanese. For brief periods, Taiwan was also occupied by Chinese forces. There are competing interpretations about how long and in what capacity China has held jurisdiction over Taiwan. But one fact is clear: Taiwan did not become a formal Chinese province until 1887. Before that, the island was regarded by Chinese rulers as nothing more than an insignificant backwater.47 Taiwan's status as a province was short-lived. After suffering defeat in the Sino-Japanese War, the Ch'ing Dynasty surrendered Taiwan "in perpetuity" to Japan under the 1895 Treaty of Shimonoseki.48 Japan gave the Taiwanese a two-year period during which they were free to return to China if they wished. The overwhelming majority of Taiwanese--who numbered three million at the time--chose to stay and live as "resident aliens" in the Japanese empire.49

         Taiwan remained under Japanese control for half a century. Japan attempted to assimilate the Taiwanese by promoting Japanese customs, demanding the exclusive use of the Japanese language, and duplicating its educational and legal systems in Taiwan. During this period, the Taiwanese had no contact whatsoever with China. In essence, an entire generation of Taiwanese grew up knowing only Japanese rule.


B. Taiwan's Unsettled Status

         As discussed below, there is compelling evidence that the World War II Allied Powers intended to authorize the KMT government only as temporary trustees of Taiwan until a final determination on the island's status could be reached. The KMT's claim to have "liberated" Taiwan from Japan in 1945 was also at odds with the colonial treatment that followed under KMT rule.50 In fact, the "Republic of China on Taiwan" was a minority government, both politically and ethnically, for most of its history on Taiwan. Chiang Kai-shek's claim to legitimacy was made all the more ridiculous by his attempt forcibly to recreate an artificial China on Taiwan. Worse yet, the KMT breached its limited mandate on Taiwan by flouting international norms of human rights. The KMT government's systematic engagement in ethnic discrimination based on ethnolinguistic background and place of origin suggests that its rule was incompatible with the United Nations Charter, the 1948 Universal Declaration of Human Rights and the 1960 Declaration of the Granting of Independence.51


         1. KMT Custodianship

         In anticipation of Japan's defeat in World War II, the Allied Powers together affirmed, in the 1943 Cairo Declaration52 and later again in the Potsdam Declaration, 53 their intent to return Taiwan to China. Although important, these documents have no basis as binding law.54 The declarations have no legal authority to dispose of territory of a sovereign country, in part because the Allied Powers did not have the capacity to carry out such a transfer.55 At best, they serve as footnotes in the discourse over Taiwan's international personality. Moreover, as wartime declarations, their status is suspect.56 Consequently, neither document substantiates Chinese claims of sovereignty over Taiwan. Yale Law School Professor W. Michael Reisman summarized the view that the KMT was awarded temporary guardianship over Taiwan:

General MacArthur authorized the Nationalist Chinese authorities to undertake temporarily military occupation of the island as a trustee on behalf of the Allied Powers. Four years later, Chiang and the remnants of the Nationalist Chinese government fled to Taiwan and purported to establish a "free China." But despite Chiang's grandiloquent claims, the United States did not recognize any Chinese sovereignty over Taiwan, when it was U.S. policy to support Chiang as a fictitious China. . . . Secretary of State Dulles, a champion of Chiang and a respected international lawyer, stated that "technical sovereignty over Formosa and the Pescadores has never been settled."57

         Even though the KMT government took control of Taiwan in 1945, Japan did not formally surrender sovereignty over Taiwan until six years later in the Treaty of Peace with Japan, concluded in San Francisco between the Allied Powers and the defeated Japan on September 8, 1951.58 The treaty clearly dictated the terms of surrender of Japan. In particular, Article 2(b) of the treaty failed to assign sovereignty over Taiwan.59 The notable absence of representatives from either the KMT government or the PRC at the treaty signing aptly demonstrates that this was no accident on the part of the treaty's framers. In fact, contemporaneous statements by the Allied Powers involved in Japan's 1945 surrender suggest that Taiwan's status was to be decided in accordance with the United Nations Charter on self-determination. For example, Great Britain took the position that the Cairo Declaration was nothing more than an expression of intent, and that Taiwan's international status was still unresolved.60 Similarly, the 1952 peace treaty signed between Japan and the KMT as acting government of China includes no specific provision for or acknowledgment of the transfer of Taiwan to the ROC government.61

         Nor did the U.S. government intend to uphold the ROC government indefinitely, let alone support its claim as China's sole legitimate government.62 However, Cold War politics made it difficult for some states in the west to abandon Generalissimo Chiang and the KMT.63 At the signing of the Mutual Defense Treaty between the United States and Taiwan, acting U.S. Secretary of State, John Foster Dulles, expressly stated that despite Washington's commitment to protect Taiwan from Chinese aggression, it regarded Taiwan's international status as unsettled:

[T]echnical sovereignty over Formosa and the Pescadores has never been settled. That is because the Japanese peace treaty merely involves a renunciation by Japan of its right and title to these islands. But the future title is not determined by the Japanese peace treaty; nor is it determined by the peace treaty which was concluded between the Republic of China and Japan. Therefore, the juridical status of these islands, Formosa and the Pescadores, is different from the juridical status of the offshore islands [Quemoy and Matsu] which have always been Chinese territory.64

Well after the Chinese Nationalists established their exile government in Taipei, both Britain and France reiterated their official position that the KMT was a temporary guardian over Taiwan.65


         2. Colonial Behavior

         Chiang Kai-shek's army took control of Taiwan in 1945, following Japan's defeat in World War II. The Chinese Nationalist government behaved not as liberators but as conquerors and colonial masters, causing severe resentment among the Taiwanese.66 According to one U.S. State Department official's report:

Our experience in Formosa is most enlightening. Many were forced to feel that conditions under autocratic rule [Japanese rule] were preferable [to KMT rule]. . . . The [Taiwanese] people anticipated sincerely and enthusiastically deliverance from the Japanese yoke. . . However, [the KMT] ruthlessly, corruptly and avariciously imposed their regime upon a happy and amenable population. . . . There were indications that Formosans would be receptive toward United States guardianship and United Nations trusteeship.67

The Nationalist government's treatment of the Taiwanese people and its institution of a one-party dictatorship was witnessed by American officials, some of whom lost confidence in the KMT.68 All government positions were the exclusive domain of ethnic Chinese mainlanders.69 Individuals elected to the National Assembly, the Legislative Yuan, and the Control Yuan in 1947 and 1948 elections in China faced no reelection in Taiwan. The sinologist Thomas Gold observed, "Economically, politically, and culturally [Taiwan] was suddenly yanked out of the Japanese orbit and appended to China in another colonial relationship."70

         The KMT government moved swiftly to consolidate its power. For instance, the National Assembly promulgated the "Temporary Provisions in Effect During the Period of Communist Rebellion," on May 10, 1948, giving the executive, Chiang Kai-shek, unlimited powers in accordance with the Assembly's constitutional amendment powers under Article 174(1) of the constitution. This was illegal, however, since the Temporary Provisions gave Chiang powers by bypassing constitutional requirements for declaring martial law and then issuing him emergency decree powers.71


                   a. Human Rights Abuses

         In denying democratic rule, the KMT government intentionally insulated itself from popular proponents of democracy and Taiwanese independence.72 Indeed, the majority of human rights violations occurred during the martial law era and were political in nature.73 Violations included the jailing of political opponents, torture, executions, arbitrary censorship, and unlawful surveillance of political dissidents. In fact, acting U.S. Vice-Consul in Taiwan George H. Kerr called the travesty of administration on Taiwan an "economic rape."74 In the brutal pogrom carried out by occupying KMT soldiers on February 28, 1947, more than 28,000 native Taiwanese were killed.75 In the ensuing months, systematic looting, raping, and indiscriminate murder continued. According to one U.S. Central Intelligence Agency officer's "white paper":

The economic deterioration of the island and the administration of the mainland [KMT] officials became so bad that on February 28, 1947, popular resentment erupted into a major rebellion. In the ensuing days the Government put down the revolt in a series of military actions which cost thousands of lives. Order was restored but the hatred of the mainland Chinese was increased.76

         Unfortunately, the early indiscriminate human rights violations in Taiwan were not isolated events. Abuses continued throughout the 1950s and 1960s under Chiang Kai-shek and his son and eventual successor, Chiang Ching-kuo.77 Government persecution of political dissidents was aimed primarily at native Taiwanese, the people who were most resentful of KMT rule.78


                   b. Ethnic Discrimination

         The KMT government actively reinforced ethnic divisions, discriminating against the majority Taiwanese based on factors including language and place of origin.79 In Taiwan's case, subethnic distinctions are most visible in language or dialect: the ruling mainlanders spoke Mandarin while the native Taiwanese majority spoke either Hoklo (often called "Taiwanese") or Hakka.80 The debate over whether Hoklo and Hakka are separate languages or dialects of Chinese is to some degree based on political, economic and social considerations;81 but from a purely linguistic point of view, Hoklo, Hakka, and Mandarin are distinct languages.82

         Under international law, a systematic state policy of ethnolinguistic discrimination against a specific group of people is a violation of human rights.83 For example, South Africa for a long time faced UN censure because of its state policy of discrimination against the black majority population.84 One manifestation of apartheid was discrimination based on language, 85 in violation of a fundamental freedom affirmed by the UN Charter.86

         In Taiwan's case, the KMT government introduced and propagated a Mandarin language policy on Taiwan despite the fact that the majority of Taiwanese did not speak Mandarin.87 The policy was intended to suppress sentiment for independence, and eradicate any sense of Taiwanese identity.88 The government's methods included humiliating Taiwanese-speaking students in school, banning the Taiwanese languages from educational institutions, degrading Taiwanese-language speakers in the media through stereotyping, and even suggesting one was a communist for not speaking Mandarin.89

         Charges of apartheid and racial discrimination in any context are serious matters under international law. Because the KMT government relied upon ethnic factors such as language and place of origin in actively discriminating against the native Taiwanese over a period of more than forty years, its actions can be construed as a form of apartheid even under a narrow definition.90 Even assuming that the KMT regime could meet its burden of legitimacy on Taiwan, fundamental issues of human rights, like self-determination, are ipso facto and ipso jure "removed from the exclusive preserve of domestic jurisdiction."91 Human rights abuses of any sort are offenses subject to universal jurisdiction to proscribe and adjudicate.92


V. CHINESE TERRITORIAL CLAIM


         The PRC government has claimed sovereign domain over Taiwan, arguing that Taiwan is within its "domestic jurisdiction" and that the issue is not adjudicable under international law. 93 However, Beijing's attempt to unilaterally assert jurisdiction over Taiwan runs counter to international norms and principles addressing a people's right to self-determination. Furthermore, resolution of Taiwan's international status and its right to join the UN raises many issues under international law that cannot be ignored simply because of Chinese objection.


A. Legal Title

         Chinese legal authorities commonly assert that as the legitimate successor government of China, the PRC inherits all territorial boundaries of the previous government.94 While true, the argument makes broad assumptions about Taiwan's status in 1949. Beijing's legal title over Taiwan is contingent upon the KMT government's legitimacy in Taiwan. If the Beijing government is indeed the successor to the KMT and its actions, then it is also bound by the 1951 Treaty of Peace with Japan which does not pass legal title of Taiwan to China. As discussed earlier, there is substantial evidence to show that the KMT's mandate on Taiwan was to act merely as temporary custodian. The fact that the KMT abused its mandate only further weakens the argument for Chinese sovereignty over Taiwan.

         The PRC government is also obligated to uphold existing covenants that its predecessors have entered into on behalf of China, including the Treaty of Shimonoseki in which the Ch'ing Dynasty gave Taiwan to Japan. In international legal theory, a new regime inherits all the rights and obligations of its predecessors when a succession in national or governmental regimes occurs.95 For example, the PRC government cannot in good faith seek to have Hong Kong returned to it under the terms of the ninety-nine-year lease signed between China and Great Britain on the one hand, and disregard China's surrender of Taiwan to Japan under the 1895 Shimonoseki Treaty on the other.96

         Alternatively, China can try to assert sovereignty over Taiwan by a claim of prescriptive title, meaning effective and clear control in which others accede.97 Such a claim would have little historical basis, however, Beijing's control over Taiwan was tenuous before the island's official annexation as a province in 1887. Japan claimed the eastern half of the island as early as the 15th century.98 Portuguese and Dutch colonizers controlled parts of Taiwan throughout the 17th century, 99 although the Chinese admiral Koxinga established a regime on the island in 1662 that lasted for some twenty years.100 Even after Koxinga's rule, the Ch'ing Dynasty only nominally controlled the western half of Taiwan,101 with Japan still claiming the eastern half. In 1874, the Ch'ing Dynasty declared Taiwan to be outside of Chinese jurisdiction, in response to a legal claim brought by the Japanese.102 Japan's fifty-year occupation of Taiwan this century further refutes China's titular claim.

         Finally, established jurisprudence is unequivocal on the matter of self-determination: "A situation involving the international legal principle of self-determination cannot be excluded from the jurisdiction of the United Nations by a claim of domestic jurisdiction. International customary law is binding on all states regardless of consent; and in any event, states have bound themselves under the Charter to respect the principle."103


B. Domestic Jurisdiction

         China alternatively claims that Taiwan's status is purely a matter for the "Chinese" to decide. Granted, pronouncements in existing case law do put limitations on self-determination, and there is an equal and important right of sovereign jurisdiction under international law.104 But a committee of jurists appointed by the Council of the League of Nations tempered state domestic jurisdiction in what is known as the Aaland Islands case. The jurists, recognizing Finland's assertion of domestic jurisdiction, affirmed Finland's right to deny islanders the opportunity to join their parcel of Finnish territory with neighboring Sweden. They limited this right, however, stating that a "[t]ransition from a de facto situation to a normal situation de jure cannot be considered as one confined entirely within the domestic jurisdiction of a State."105 In other words, in the absence of actual possession or control over a territory, state domestic jurisdiction cannot be invoked. Such case law is consistent with developments in customary international law that bear directly on self-determination.106

         The Beijing government has not exercised control over Taiwan for a single day since the PRC's founding in 1949. Therefore, it cannot assert jurisdiction over Taiwan. Neither can Chinese jurisdiction be concluded from international recognition that Taiwan is a part of China, since, according to international law, countries not directly involved in a territorial dispute have no right to determine ownership.107 For example, Chinese recognition of Bangladesh as a part of India would be irrelevant. It is crucial to note that conflicts of territory are inevitably matters of international concern.108


VI. TAIWAN: DE FACTO INDEPENDENCE


         The discussion thus far has addressed Taiwan's unsettled international status. But Taiwan has changed dramatically since the KMT government's expulsion from the UN in 1971. Since 1986, a gradual democratization of the political process has changed the debate, culminating in this year's first-ever direct presidential election. Today, there is a new KMT leadership represented by native Taiwanese, a thriving economy, and most importantly, a government by popular consent. Does the fact that Taiwan is now in fact a democratic, independent country strengthen Taiwan's UN bid? If so, under what terms?


A. Taiwan Meets the Requirements for Statehood

         The legal criteria for statehood are (1) a permanent population, (2) a defined territory, and (3) a functioning government, (4) that engages in international relations on behalf of the territory.109 Taiwan has a stable population of 21 million people within an area of roughly 14,000 square miles, defined by Taiwan and its outlying islands of the Pescadores, Kinmen and Matsu.

         In addition, Taiwan has had its own independent government since 1945. Despite the fact that many states do not recognize Taiwan, the Taipei government alone represents Taiwan in bilateral and multilateral settings.110 Nor does non-recognition prevent governments from treating the Taiwanese government as the actual government of Taiwan.111 After all, international law is constructed on state practice.112

         For practical reasons, some countries treat Taiwan as a de facto state for purposes of enforcing Taiwan's rights and duties under international law.113 For example, over ten nations have entered into commercial treaties with the Taiwanese government despite an absence of diplomatic relations, when concluding landing rights and airspace agreements affecting Taiwan.114 In addition, Taiwan has reaffirmed its commitment to obligate itself to international laws as much as recognized states are bound to uphold it.115 If Beijing's claim of sovereignty were true, then China would be responsible for the negotiations and adjudication of matters occurring in Taiwan.116


B. A Democratic Taiwan

         Finally, Taiwan satisfies the non-traditional fifth requirement for statehood, democracy. It was only in 1986 that Taiwanese opposition to one-party rule succeeded in forming the island's first opposition political party, the Democratic Progressive Party (DPP). In the years before this, popular demand for political reforms increased, accelerating the end of one-party rule. For example, President Lee Teng-hui responded to the rapid social changes and public expectations by convening a forum to address political reforms in the 1990 National Affairs Conference.117 Institutional changes were also visible, as when the Judiciary began to assert its own independence118 in reaction to the changing political climate. For example, the Judicial Yuan's Council of Grand Justices issued the 1991 Interpretation No. 261, which forcibly retired the National Assembly and the Legislative Yuan members elected in 1947 and 1948. The same year, President Lee Teng-hui terminated the long-standing "Period of Communist Rebellion."119 Lee's action coincided with the National Assembly's repeal of the Temporary Provisions and the adoption of ten additional articles to the Constitution. Full elections to all the national government organs began in 1991.120 On July 28, 1994, the National Assembly voted to amend the constitution, clearing the way for presidential elections in March of this year.121

         The absence of international recognition and lack of diplomatic relations should not be a bar to Taiwan's UN membership. Taiwan has fulfilled the prerequisites for statehood, adhering to the rights and duties associated with states under international law. The added fact that Taiwan has fully implemented democratic reforms puts to rest any argument that it is not a full-fledged state.122


VII. TAIWAN'S PURSUIT OF UN MEMBERSHIP


A. Overview

         It was the pro-independence DPP that first argued for Taiwan's pursuit of de jure independence, if not an end to the KMT's own "One China" policy, to counter Beijing's alarming diplomatic isolation tactics against the island.123 As recently as 1988, Taiwan held official membership in only eight international organizations.124 In 1989, only 5% of its trade was with countries that had diplomatic relations with Taiwan.125 Today, Taiwan maintains diplomatic relations with fewer than thirty small countries. It was only after the KMT government acquiesced to an unprecedented 1992 televised debate on UN membership that it realized public opinion was on the side of the DPP.126

         On April 21, 1993, Foreign Minister Frederick Chien announced that Taiwan would formally apply to rejoin the UN. However, the government ignored DPP calls for Taiwan's application under the name "Taiwan," despite the fact that even some American observers believed UN membership potential would be enhanced--including U.S. support--if the "ROC" label was not used in the pursuit.127 Instead, the government made pronouncements on a new "One China--two governments" policy to accommodate its bid to enter the UN under a divided China proposition.128 At the same time, Taiwan's Mainland Affairs Council issued a July 1994 white paper, Relations Across the Taiwan Straits, in which it announced a formal change in government policy to the effect that Taipei would no longer compete with Beijing for the "right to represent China."129 Unfortunately, President Lee reaffirmed the KMT government's long-standing commitment to political unification with China despite the unlikelihood that such unification would take place on Taipei's terms.130 In effect, the KMT permitted Beijing to set the tone of the debate, foreclosing Taiwan's right to enter the UN as a sovereign state.


B. UN Precedents on "Divided Nation" Membership

         The KMT government proposes that Taiwan might join the UN under parallel representation alongside the PRC. It argues that China is currently divided and ruled by two separate and equal political entities: the PRC on mainland China, and the "ROC" on Taiwan.131 This will not succeed.132 Any attempt by Taiwan to enter the United Nations as a "divided country" modeled after the two Koreas or the former two Germanys will fail. Indeed, UN Resolution 2758 has already determined that there is only one China and that its legal government is situated in Beijing. In addition, admission to the UN as a divided country is contingent on (1) the competing governments' qualifications being relatively equal and (2) the rival governments' mutual acquiescence.

         The great discrepancy in physical size between Taiwan and what the KMT calls the "mainland" (in fact China proper) surely preempts any serious consideration of "parallel representation." Past efforts to seat North and South Vietnam simultaneously failed because the rival governments sought reunification on their own terms.133 In Korea's case, dual admission for Seoul and Pyongyang occurred simultaneously in July 1991, only after the rival governments did not object to each other's entry.134 Finally, UN admission for a divided German state occurred only after a détente was reached between the two rivals in 1973.135

         It should instead be argued that the examples of Korea and Germany reflect the UN's pragmatism. Taiwan, like Korea and Germany, has an important role to play in the international arena irrespective of its differences with other nations.


C. Taiwan's Argument for UN Membership


         1. "Status Quo?"

         The "status quo" argument put forth by many observers to dissuade Taiwan from more actively pursuing international recognition as a sovereign state wrongly assumes parity between Taiwan and China.136 China is actively pursuing long-range ballistic missile technology and modernizing its military, and hopes to create a blue-water navy by early in the next century. The country is even now asserting itself as the preeminent political, if not soon to be economic, power in the region.


         2. Historic Ties

         Historic ties should not be a consideration in Taiwan's right to UN membership either. It is the people, not the territory, that must determine Taiwan's destiny. Such sentiments were echoed by Great Britain's Lord Avebury, Chairman of the House of Lords Parliamentary Human Rights Group:

The fact that Taiwan had been declared a province of China nearly fifty years ago does not mean that it cannot be a sovereign state today, as the examples of Eritrea and Bangladesh show. In the case of Taiwan, because it has been de facto independent since 1949, there would be no grounds in logic for refusing it the same treatment....If the people of Taiwan decide that they want the international community to recognize their existence as an independent state, and they formally apply for UN membership, I hope that the People's Republic of China will gracefully acquiesce, even if they continue to feel emotionally that Taiwan is part of their state.137

         Indeed, there are many examples of successful peace-loving countries with populations that either speak the same language or are of the same race as their former colonial overlords.138 UN principles are unequivocal in affirming a people's right to self-determination; even military and strategic considerations are secondary to this right.139


         3. Taiwan Belongs in the UN

         Issues such as trade, security, nuclear nonproliferation, human rights, poverty, and environmental protection will require close multilateral cooperation among all nations. Therefore, the United Nations cannot afford to ignore the reality that Taiwan is an independent sovereign country. In addition, UN membership for Taiwan is long overdue for the following reasons: (1) Taiwan has a right to join the United Nations as a new state under the name "Taiwan," because it has met the qualifications for statehood as a de facto state for fifty years. Taiwan is a full-fledged democracy and its people wish to decide their country's future.140 They certainly do not need the Chinese communist regime to dictate their destiny to them.

         The resurgence of Taiwanese culture and identity since the end of martial law in 1987 has fueled the Taiwanese desire for recognition.141 The expression of sentiment for independence has become commonplace in Taiwan today,142 while UN membership enjoys the support of most, if not all, of Taiwan's citizenry. Regrettably, the international community is largely uninformed about Taiwan's democratic changes and the UN membership aspirations of its 21 million people, a population greater in number than those of three-fourths of current UN members.143

         (2) The UN principles of self-determination and universal respect for human rights remain unfulfilled so long as Taiwan is denied a seat in the General Assembly. The Taiwanese people deserve international status commensurate with their political and economic achievements.

         It is imperative for Taiwan to be represented at forums such as the United Nations. If Taiwan is denied UN membership, Beijing's paranoia that Taiwan could become hostile and align with other anti-China nations might well prove self-fulfilling. Not only would Taiwan have to fight for its survival, it would have no choice but to seek all available assistance from the international community. Taiwan belongs to the Taiwanese people, and that alone should be determinative for UN membership.

         (3) Finally, Taiwan's exclusion from the United Nations hurts the community of nations. Taiwan is willing to share its economic success with the world community and to contribute to international development. The country is the world's thirteenth largest trading nation, ranks twentieth in gross national product, is a major investor nation, and has used its foreign exchange reserves, among the largest in the world, to assist developing nations in emergency relief, technical training, and development projects.144 The UN can benefit from Taiwan's burden-sharing in the international arena.


D. Coexistence and Cooperation with China

         It should also be emphatically stated that Taiwan seeks peaceful coexistence and cooperation with China, not conflict or confrontation. Any objective observer will have noted that Taiwan has pursued a policy of constructive engagement toward China since 1987. One of the consequences of this has been that Taiwanese business people have invested more than US$50 billion in China, which has helped to fuel China's economic growth, and more than eight million Taiwanese have visited China in the past decade.

         In his inauguration speech on May 20, 1996, Taiwanese President Lee Teng-hui reiterated that Taiwan wants reconciliation and cooperation with China. As an additional gesture of goodwill, President Lee has proposed that he visit China to meet with top Chinese leaders in a journey of peace and reconciliation. The Democratic Progressive Party has also called for signing accords of non-aggression, respect for sovereign and territorial integrity, peaceful settlement of disputes, and security and economic cooperation between Taiwan and China.145 These accords would yield huge dividends for both countries, and Taiwan would be willing and able to provide economic and technical aid to assist China's modernization.


VIII. CONCLUSION


         In the coming century, the United Nations will continue to play a major role in international relations. Clearly, Taiwan is prepared to participate in the UN and undertake urgent problems of conflict resolution, peace keeping, and other matters of international concern. To these ends, Taiwan has already made vital contributions to the economic prosperity and political stability of the Asia-Pacific region and elsewhere.

         While Taiwan's political and economic achievements receive due recognition abroad, the world community continues to deny the Taiwanese people the political freedom to define their international identity because of China's objection. There can be no peace in Asia as long as there is instability across the Taiwan Strait. And instability across the Taiwan Strait will persist as long as the world community continues to deny Taiwan representation in the most important forum for conflict resolution. The world cannot afford to ignore the reality of Taiwan any longer.

         Can anyone say that Taiwan's sovereignty does not belong to the 21 million Taiwanese people alone? Of course not. The cultural, social, political, and economic changes resulting from over 100 years of separation between Taiwan and China are irreversible. As a result, Taiwan and China are two separate countries today. It is time for the United Nations to admit Taiwan.



         *Dr. Parris Chang is a professor of political science at Pennsylvania State University, a Democratic Progressive Party legislator, a ranking member of the Foreign Relations Committee in Taiwan's Legislative Yuan, and Director of the Taiwan Democratic Progressive Party Mission in the U.S. Dr. Chang is the co-author and co-editor of IF CHINA CROSSES THE TAIWAN STRAIT: THE INTERNATIONAL RESPONSE (1993); he is the author of several books, including POWER AND POLICY IN CHINA (3d ed. 1990) and ELITE CONFLICT IN THE POST-MAO CHINA (1983); he has also published numerous articles in professional journals in Asian affairs and international politics.

         **Mr. Kok-ui Lim is Legal Counsel to the Taiwan Democratic Progressive Party Mission in the U.S. J.D., University of Washington (1993); B.A., University of Michigan (1990); diploma, Waseda University (Tokyo, Japan) (1989).

         1The terms "Kuomintang," "Nationalist government," and "Republic of China" are used interchangeably in this Article to describe the Kuomintang government in Taipei. This usage is adopted merely as a convenient description and does not imply any legal recognition on the parts of the authors of any form of Chinese sovereignty over Taiwan.

         2G.A. Res. 2758 , U.N. GAOR, 26th Sess., at 358, U.N. Doc. A/L.630 and Add. 1 and 2 (1971).

         3PETER R. BAEHR & LEON GORDENKER, THE UNITED NATIONS IN THE 1990S 45 (1992).

         4Id. (National Security advisor Henry Kissinger visited Beijing in the second half of October 1971, to arrange President Nixon's forthcoming trip to China). See also AMOS YODER, THE EVOLUTION OF THE UN SYSTEM 37 (1993) (without the U.S.' sustained commitment to blocking China's ascension in the UN, Third World and non-aligned countries successfully put the issue of Chinese representation on the General Assembly agenda).

         5BAEHR & GORDENKER, supra note 3, at 45.

         6See generally YODER, supra note 4, at 29 (the UN gathering took place in San Francisco on April 25, 1945).

         7See generally WENDELL CHAFFEE GORDON, THE UNITED NATIONS AT THE CROSSROADS OF REFORM (1994).

         8J.L. BRIERLY, THE LAW OF NATIONS 59 (1963), cited in U.O. UMOZURIKE, SELF-DETERMINATION IN INTERNATIONAL LAW 189 n.51 (1972).

         9UMOZURIKE, supra note 8, at 189.

         10Lung-chu Chen, Self-Determination and World Public Order, 66 NOTRE DAME L. REV. 1287, 1301 (1991) ("[O]ne of the most remarkable developments in international law is the notion that international law is not centered on the nation state. The nation state remains the primary participant, but there are other actors, many other participants.").

         11BAEHR & GORDENKER, supra note 3, at 103 ("[The Declaration] has shifted some of the emphasis of international law from its concern exclusively with the state to greater attention to individual people.").

         12See G.A. Res. 2106, U.N. GAOR, 20th Sess., at 143, U.N. Doc. A/6181, A/L.479 (1965) (the General Assembly adopted the International Convention on the Elimination of All Forms of Racial Discrimination), cited in UMOZURIKE, supra note 8, at 51 n.29.

         13YODER, supra note 4, at 111.

         14BAEHR & GORDENKER, supra note 3, at 3-4. The UN Charter itself is a primary source of international law, "described by jurists as a multilateral convention, a treaty that makes binding law . . . . [it] received the task of progressively developing international law." T. Olawale Elias, Modern Sources of International Law, in TRANSNATIONAL LAW IN A CHANGING SOCIETY 34-69 (Friedman, et al. eds., 1972).

         15BAEHR & GORDENKER, supra note 3, at 3-4 ("[I]nternational law was to be applied and developed on the basis of a freely reached consensus of governments."). Colonel House, President Woodrow Wilson's foreign policy advisor on the League of Nations, the precursor to the United Nations, recognized that enforcement of international legal decisions required cooperation among states, saying, "I believe the most vital element in bringing about a worldwide reign of peace is to have the same stigma rest upon the acts of nations as upon the acts of individuals. When the people of a country are held up to the scorn and condemnation of the world because of the dishonorable acts of their representatives, they will no longer tolerate such acts." YODER, supra note 4, at 115-16.

         16Convention on the Rights and Duties of States (Montevideo Convention), Dec. 26, 1933, art. 1, 49 Stat. 3097, 3100, T.S. No. 881.

         17See RESTATEMENT (THIRD) OF FOREIGN RELATIONS LAW § 10 (1987) (the territorial requirement is met even if rival claims are asserted over the same territory) [hereinafter RESTATEMENT] .

         18Requirements three and four suggest that a foreign power cannot in any form exercise influence in the de facto territory independent of or concurrent with the de facto state government. See 112 LEAGUE OF NATIONS O.J. 56 (1933) (special committee findings on the status of Manchuria). In 1931, the League of Nations rejected Manchuria's declaration of independence from China due to Japan's involvement in Manchuria's secession.

         19See J.E.S. Fawcett, Security Council Resolutions on Rhodesia, 41 BRIT. Y.B. INT'L L. 103, 112 (1965-66) ("to the traditional criteria for the recognition of a regime as a new State must now be added the requirement that it shall not be based upon a systematic denial . . . [of] the right of every citizen to participate in the government . . .") cited in M. Kelly Malone, The Rights of Newly Emerging Democratic States Prior to International Recognition and the Serbo-Croatian Conflict, 6 TEMP. INT'L & COMP. L.J. 81, 87 n.27 (1992); James Crawford, The Creation of States in International Law, 48 BRIT. Y.B. INT'L L. 93, 106 (1976-77) ("[i]t appears then that a new rule has come into existence prohibiting entities from claiming statehood if their creation is in violation of an applicable right of self-determination"), cited in id.

         20See G.A. Res. 1514, U.N.GAOR, 15th Sess., at 188, U.N. Doc. A/L.323 and Add. 1-6 (1960).

         21Chen, supra note 10, at 1290-91.

         22Id. at 1290 n.18 (Universal Declaration of Human Rights art. 21, para. 3).

         23See YODER, supra note 4, at 114-15.

         24THOMAS M. FRANCK, NATION AGAINST NATION 60 (1985).

         25UMOZURIKE, supra note 8, at 3 (self-determination is much more narrowly construed today to express a political future of a group and their right to freely pursue it as they see fit).

         26Although Chapter XI of the UN Charter takes into due account the political aspirations of a people in the development of self-government, it is not an explicit endorsement of independence. See UNITED NATIONS CHARTER, signed June 26, 1945, entered into force Oct. 24, 1945, art. 2 (7), 59 Stat. 1031, T.S. No. 933, 3 Berans 1153 (1969) ("Nothing contained in the present Charter shall authorize the UN to intervene in matters which are essentially within the domestic jurisdiction of any state or shall require the Members to submit such matters to settlement under the present Charter; but this principle shall not prejudice the application of enforcement measures under Chapter VII.") [hereinafter U.N. CHARTER]. See also YODER, supra note 4, at 14-15 (Hugo Grotius, a recognized leader in international legal theory, believed that intervention is an unlawful interference in state sovereignty); BAEHR & GORDENKER, supra note 3, at 21 (non-self-governing territories "were to be brought at least to self-government and some perhaps independence").

         27 Malone, supra, note 20, at 103-05 (the 1991 collapse of the Yugoslavian federal republic created a vacuum which required the component republics to assert independence in order to halt the economic and political crises).

         28GORDON, supra note 7, at 165-66, quoting PHILLIP C. JESSUP, A MODERN LAW OF NATIONS 20-23 (1948).

         29U.N. CHARTER art. 2 (7).

         30Kotaro Tanaka, Some Observations on Peace, Law and Human Rights, TRANSNATIONAL LAW IN A CHANGING SOCIETY 255 (Friedman et al. eds., 1972). Kotaro Tanaka is a former judge of the International Court of Justice and an Associate of the Institut de Droit International.

         31GORDON, supra note 7, at 212 (In Boutros-Ghali's June 17, 1992 report entitled, "An Agenda for Peace: Preventive Diplomacy, Peacemaking and Peace-Keeping § 17," the UN Secretary-General affirmed the respect for state sovereignty and integrity in the international process but added, "[t]he time of absolute and exclusive sovereignty, however, has passed; its theory was never matched by reality.")

         32See note 12 concerning the implicit endorsement of self-determination in the Declaration as affirmed in subsequent UN resolutions.

         33BAEHR & GORDENKER, supra note 3, at 103 ("[The Declaration] has become the foundation for establishing obligatory legal norms to govern international behavior with regard to rights of individuals.").

         34U.N. CHARTER art. 73.

         35Id., art. 76(b).

         36See G.A. Res. 1514, U.N. GAOR, 15th Sess., at 188, U.N. Doc. A/L.323 and Add 1-6 (1960).

         37GORDON, supra note 7, at 135 (because of difficulties in realizing Chapters XII and XIII of the Charter, the General Assembly in frustration adopted the 1960 Declaration calling for a speedy end to colonization). See also BAEHR & GORDENKER, supra note 3, at 121.

         38The resolution reads in part: "that the total eradication of racial discrimination, apartheid and violation of the human rights of the peoples in colonial territories will be achieved most expeditiously by the faithful and complete implementation of the Declaration . . . and by the speediest possible complete elimination of the presence of the racist minority regimes therefrom." G.A. Res. 32/42, U.N. GAOR, 32d Sess., at 498, U.N. Doc. A/32/L.36 and Add 1 (1977).

         39See Leslie H. Gelb, Foreign Affairs: Why the U.N. Dog Didn't Bark, N.Y. TIMES, Sept. 25, 1991, at A23.

         40The UN Charter makes mention of the right to self-determination and self-government in other chapters as well, most notably Chapter IX (art. 55), Chapter XI (art. 73), and Chapter XII (art. 76).

         41U.N. CHARTER art. 3.

         42See generally UNITED NATIONS DEPARTMENT OF PUBLIC INFORMATION, BASIC FACTS ABOUT THE UNITED NATIONS (1992). In 1965, membership on the Security Council was increased from 11 to 15 (U.N. CHARTER art. 23); all matters require nine affirmative votes, including the concurring votes of the five permanent members (U.N. CHARTER art. 27). The General Assembly is the main deliberative organ composed of representatives of all Member States each having one vote. Decisions on important questions and new Members require a two-thirds majority.

         43See BAEHR & GORDENKER, supra note 3, at 44.

         44See generally GOVERNMENT INFO. OFF., ROC, 1995 THE REPUBLIC OF CHINA YEARBOOK (1995) [hereinafter ROC YEARBOOK], MARC J. COHEN, TAIWAN AT THE CROSSROADS vii (1988).

         45The authors use the term "native Taiwanese," and "Chinese mainlanders" in a historical context only to distinguish between the Taiwanese who immigrated to the island before 1945 and those who arrived between 1945 and 1949.

         46Peter R. Moody, Jr., The Democratization of Taiwan and the Reunification of China, 5 J.E. ASIAN AFF. 144, 147 (1991). The term "mainlanders" refers to the roughly two million ethnic Chinese families and their descendants (12 to 15% of the total population of Taiwan), mostly soldiers, officials, politicians, capitalists, scholars, and ordinary people loyal to Chiang or fearful of communist reprisals.

         47See Letter from Lord Avebury, Chairman of the Parliamentary Human Rights Group, House of Lords, to Ma Yuzhen, Ambassador to the United Kingdom (Sept. 27, 1994) (on file with the UCLA Journal of International Law and Foreign Affairs) (as early as AD 603, Taiwan is referred to in Chinese annals as a foreign country. Later, in the thirteenth century, Yuan Dynasty official works refer to Taiwan's inhabitants as "eastern Barbarians," tung fan). See also Gary Klintworth, Taiwan's International Identity: 400 Years in the Melting Pot, 10 J.E. ASIAN AFF. 373, 379 n.20 (1996) citing Christine Vertente, Hsu Hsueh-chi & Wu Mi-cha, The Authentic Story of Taiwan 130 (1991) (Taiwan was seen as a lawless, "trifling place" of rebellious peasants, so much so that the Ch'ing Emperor K'ang Hsi thought "relinquishing it would not be a loss."); Moody, supra note 46, at 145 ("Taiwan was long a frontier area and before the 1880s was only poorly integrated into the traditional Chinese state."). See generally Michael Reisman, Who Owns Taiwan, NEW REPUBLIC, Apr. 1, 1972, at 22 (Li Hung-Chang, Viceroy of the Ch'ing government, responsible for negotiating the surrender of Taiwan to the Japanese in 1895: "[T]his land of Brown Robbers [Taiwan] was a vile spot, in which no man . . . would ever care to live. . . . It may not be known generally, but as early as 1873, when complaints came to Tientsin from British traders, I earnestly memorialized the Throne to offer Taiwan to the English Government to do with the wretched island as they saw fit.").

         48See 1 AM. J. INT'L L. 378 (Supp. 1907).

         49Art. V of the Treaty of Shimonoseki in Chen Lung-chu and W.M. Reisman, Who Owns Taiwan: A Search for International Title, 81 YALE L.J. 599, 610 n.37 (1972) (only 0.16% of the Taiwanese population chose Chinese nationality). See also Ng, Japan's Occupation of Taiwan: Her Internal and International Measures (I), 69 KOKUSAIHO GAIKO ZASSHI (THE JOURNAL OF INTERNATIONAL LAW AND DIPLOMACY) 63, 89-90 (1970), cited in Chen & Reisman supra at 610 n.38; MING-MIN PENG, A TASTE OF FREEDOM: MEMOIRS OF A FORMOSAN INDEPENDENCE LEADER 7 (2d ed. 1994).

         50See ROBERT G. SUTTER, CONGRESSIONAL RESEARCH SERVICE, TAIWAN-MAINLAND CHINA RELATIONS-IMPLICATIONS FOR THE U.S. (Cong. Res. Service Rep. Aug. 6, 1992). See also Moody, supra note 46, at 147 ("They [the KMT] treated Taiwan more as an occupied enemy than as a liberated province. The [KMT] arrogated to themselves the privileges and perquisites of the Japanese imperialists but without the Japanese competence and efficiency.").

         51See Anna Michalska, Rights of Peoples to Self-Determination in International Law, ISSUES OF SELF DETERMINATION 79 (William Twining ed., 1991) (the 1977 UN General Assembly Resolution 32/42, addressing racial discrimination and apartheid, affirmed that, "continuation of colonialism in all its forms and manifestations, including racism, apartheid, the exploitation by foreign and other interests of economic and human resources . . . is incompatible with the Charter of the United Nations, the Universal Declaration of Human Rights and Declaration of the Granting of Independence.").

         529 DEP'T STATE BULL. 393 (1943). The Declaration, issued on December 1, 1943, was made by President Franklin D. Roosevelt, Prime Minister Winston Churchill, and Generalissimo Chiang Kai-shek.

         5313 DEP'T STATE BULL. 137 (1945).

         54George H. Kerr, U.S. Vice-Consul in Taiwan during the early years of KMT occupation on Taiwan wrote, "It should be remembered that the Cairo Declaration was not a binding treaty, but in essence a ploy to keep Chiang in the war against Japan," in GEORGE H. KERR, THE TAIWAN CONFRONTATION CRISIS 43 (1986).

         55Reisman, supra note 47, at 22.

         56See Chen & Reisman, supra note 49, at 636. Such declarations are intended mainly to mobilize and propagandize in times of exigency, as in war. They are rarely construed as long-term policy intentions or formulations.

         57Reisman, supra note 47, at 22.

         58Treaty of Peace with Japan, Sept. 8, 1951, 3 U.S.T. 3169; 136 U.N.T.S. 46.

         59Article 2 of the Treaty only states that "Japan renounces all right, title and claim to Formosa and the Pescadores." 3 U.S.T. 3170.

         60See CONFERENCE FOR THE CONCLUSION AND SIGNATURE OF THE TREATY OF PEACE WITH JAPAN: RECORD OF PROCEEDINGS (Dep't of State Pub. 4392, 1951) at 93, cited in Chen & Reisman, supra note 49, at 643 n.155 (The UK Representative at the Conference said, "The treaty itself does not determine the future of these islands [Taiwan and the Pescadores]. In due course a solution must be found, in accord with the purposes and principles of the Charter of the United Nations.").

         61See Treaty of Peace, Apr. 28, 1952, P.R.C.-Japan, 138 U.N.T.S. 3. His Excellency Mr. Isao Kawada, Plenipotentiary of Japan signed the treaty on behalf of Japan. The treaty only refers to the terms in the 1951 Treaty of Peace.

         62See Moody, supra note 46, at 148. Prior to the outbreak of the Korean War, the U.S. had been prepared to recognize Peking.

         63For a thorough account of the dilemma faced by some states in the West and some former Allies after World War II in whether to recognize the Communist victory in China, see Chen & Reisman, supra note 49, at 641-44.

         6431 DEP'T OF STATE BULL. 896 (1954), cited in Chen & Reisman, supra note 49, at 645 n.163.

         65See Sir Anthony Eden, Great Britain, Parliamentary Debates (Hansard), House of Commons, vol. 536, col. 159, Feb. 4, 1995 cited in J.P. Jain, The Legal Status of Formosa, 57 AM. J. INT'L L. 25, 27-28 (1963), cited in turn in Gary Klintworth, Taiwan's International Identity: 400 Years in the Melting Pot, 10 J.E. ASIAN AFF. 373, 383 (1996) (British Foreign Secretary, Sir Anthony Eden: "Formosa and the Pescadores are therefore in the view of Her Majesty's Government, territory the de jure sovereignty over which is uncertain or undetermined."). See also Self-Determination for Taiwan Is Suggested by French Premier, N.Y. TIMES, Apr. 24, 1964, at A4 (French premier Georges Pompidou reiterated that French recognition of the PRC on January 27, 1964 in no way explicitly or implicitly recognized Beijing's territorial claim over Taiwan, and the island's status "must be decided one of these days, taking the wishes of the Formosa (Taiwan) population into consideration.").

         66See Shiba Ryotaro, The Sadness of Being Taiwanese: An Interview with President Lee Teng-hui, SHUKAN ASAHI May 6-13, 1994, at 42-49 (President Lee Teng-hui conceded that the KMT was a foreign government on Taiwan in his now famous 1994 interview, saying, "Even the KMT is also a foreign regime."). See also TAIWAN ASSOCIATION OF UNIVERSITY PROFESSORS, PEACEFUL COEXISTENCE: TWO COUNTRIES, TWO SYSTEMS, POSITION PAPER, at 5-8 (Dec. 10, 1993) [hereinafter PEACEFUL COEXISTENCE]; Is Taiwan Really Part of China, ECONOMIST, Mar. 16, 1996, at 40 ("Many Taiwanese, wistful for independence, regarded the Nationalists as another occupying army, which was largely consistent with the army's behavior after the Japanese surrender in 1945.").          67DEPARTMENT OF STATE, UNITED STATES RELATIONS WITH CHINA 309 (1949).

         68See DAVID MAYERS, GEORGE KENNAN AND THE DILEMMAS OF U.S. FOREIGN POLICY 176 (1988), cited in Moody, supra note 46, at 151 n.9 (Although the U.S. did not intend to support the KMT government indefinitely, Washington did express concern over the future of Taiwan and its people. George Kennan strongly supported a U.S. takeover of Taiwan and return of ROC troops and refugees to China, "by force if necessary.").

         69Tak-wing Ngo, Civil Society and Political Liberalization in Taiwan, 25 BULL. CONCERNED ASIAN SCHOLARS 4, 5 (1993) ("By repressing political identities, and by denying freedom of speech, association, and other civil and political rights, the ruling party tried to destroy self-organized and autonomously defined political spaces, substituting for them a state-controlled public arena.").

         70THOMAS B. GOLD, STATE AND SOCIETY IN THE TAIWAN MIRACLE 49-50 (1986).

         71See R.O.C. CONST., Temporary Provisions Effective During the Period of Communist Rebellion [Temporary Provisions] (adopted 1948). The Temporary Provisions expressly annulled seven articles to the Constitution in Temporary Provisions art. 1 (39), (43); art.3 (47); art. 6 (26), (64), (91); art. 7 (27) (bypassed Constitutional articles in parenthesis).

         72Moody, supra note 46, at 152 (The KMT felt that "a democratic Taiwan would amount to an independent Taiwan. . . . The one China position thus allowed the regime to insulate itself from the people it ruled and to keep power by police state controls.").

         73For a detailed account of political oppression under "Free China," see generally Congressman Donald M. Fraser's speech, Political Repression in "Free China," 116 CONG. REC. 30419-22 (1970); see also Ming-Min Peng, Political Offenses in Taiwan: Laws and Problems, 47 CHINA Q. 471 (1971), cited in Chen & Reisman, supra note 49, at 613-14 n.48; Ngo, supra note 69, at 3-15.

         74KERR, supra note 54, at 52.

         75For a detailed account of the tragedy, see GEORGE H. KERR, FORMOSA BETRAYED (1965). See also DOUGLAS MENDEL, THE POLITICS OF FORMOSAN NATIONALISM (1970); Michael Rand Hoare, Taiwan Confronts Its Past, TODAY, May 1993, at 4-7; Nicholas D. Kristof, The Horror of 2-28: Taiwan Rips Open the Past, N.Y. TIMES, Apr. 3, 1993, at A4.

         76DEPARTMENT OF STATE, UNITED STATES RELATIONS WITH CHINA 308 (1949).

         77See Kristof, supra note 75, at A4 ("At that time, Chiang Kai-shek and Chiang Ching-kuo were in Taiwan and unmistakably bear direct responsibility.").

         78The most active opposition to one-party rule came from the disenfranchised native Taiwanese. As a result, many Taiwanese faced severe persecution for speaking out against the Nationalist government. See e.g., Phil Kurata, The Softline Prosecution, FAR E. ECON. REV., Mar. 7, 1980, at 22 (Eight of the leading Taiwanese political dissidents opposed to one party rule were arrested after a large protest in Kaohsiung on December 10, 1979. The trial, though controversial, is remembered more for its historic symbolism as a turning point in Taiwanese nationalism and government oppression: "the evidence presented in the bill of indictment appears to lack a solid foundation in facts.").

         79See Hill Gates, Ethnicity and Social Class, THE ANTHROPOLOGY OF TAIWANESE SOCIETY 255 (1981), cited in Alan M. Wachman, Competing Identities in Taiwan, THE OTHER TAIWAN: 1945 TO THE PRESENT 29 n.42 (1994) ("Ethnic group membership . . . is based on one's father's place of origin, and this information is a necessary item on the identity cards carried by all persons aged fifteen and over. Children are socialized by the state to accept ethnicity as a primary identity; in many elementary and high schools, children are asked publicly to state their province of origin at the beginning of the term, and the census of students by province is posted." But by 1991, the practice was revised to downplay ethnic/provincial origin.).

         80The term "Taiwanese" in a linguistic context is used by the authors for convenience to denote the collective languages represented by Hoklo (also known as Southern Min, Hokkien, or Fukienese), Hakka, and the Aboriginal languages. Today, Mandarin can legitimately be called a "Taiwanese language."

         81See Edward Tai Sun, Language Policy for a Multilingual Taiwan 15 (unpublished paper, 1995) ("[T]his may or may not explain why, in English, we do not refer to Polish, Czech, Bulgarian, Russian, Ukrainian and Belorussian as 'dialects' of 'Slavic,' even though they are more similar to one another than Cantonese, Taiwanese and Mandarin. . .").

         82Id. at 14 ("[T]he vast majority of Western linguists of Chinese who have written on the subject agree that the term 'language' more accurately describes those 'dialects' which are mutually unintelligible, such as Mandarin, Southern Min [Hoklo], and Hakka, as these forms of speech are as different from one another as German from English.").

         83RESTATEMENT, supra note 17, § 702 cmt. d (b) (Article II of the Convention on the Prevention and Punishment of the Crime of Genocide lists crimes of genocide to include actions which can cause serious mental harm to member of the group); see also U.N. General Assembly Resolution 32/42, which expresses the conviction that racism and apartheid are forms of colonialism in violation of the human rights of peoples and in violation of the UN Charter. G.A. Res. 32/42, U.N. GAOR, 32d Sess., at 498, U.N. Doc. A/32/L.36 and Add 1 (1977).

         84RESTATEMENT, supra note 17, § 702, Reporters' Notes 1, 7 (the General Assembly has in the past voted to condemn apartheid to be in violation of the UN Charter because of its systematic racial discrimination).

         85Patrick McDowell, South African School Fights Integration, WASH. TIMES, Feb. 8, 1996, at A14. English and Afrikaans were the only official languages despite the fact that Afrikaners make up only 3.5 million of the 43 million people. Moreover, riots followed in black townships when the government tried to make Afrikaans the only official language. Today there are 11 official languages. Coincidentally, some Taiwanese equated the distinction between themselves and the Chinese KMT mainlanders as a national difference, equal to white minority rule over black majority South Africa. See Moody, supra note 46, at 170.

         86U.N. CHARTER art. 55(c).

         87See Edward Tai Sun, supra note 81, at 25-28. The government commenced the "Mandarin Movement" by establishing the Taiwan Committee for the Promotion of Mandarin on April 2, 1946. In 1959, the Committee was incorporated as a unit of the Ministry of Education. But on November 26, 1970, the Committee was revived again. THE STRUCTURE OF TAIWANESE: A MODERN SYNTHESIS 362 (Robert L. Cheng & Shuanfan Huang eds., 1988) [hereinafter STRUCTURE OF TAIWANESE] (75% of the population still speak Taiwanese as the mother tongue while 10% speak Hakka as the mother tongue today).

         88See D.K. Jordan, The Languages of Taiwan, 1 MONDALINGVO-PROBLEMO 65-76 (1969) ("The reasons for the shift to a vigorous and exclusive Mandarin policy were the KMT's twin fears of Taiwanese independence and/or remaining Taiwanese allegiance to Japan") cited in Edward Tai Sun, supra note 81, at 26. See also Esther Figueroa, Evaluating Language Policy in Taiwan, in STRUCTURE OF TAIWANESE, supra note 87. ("[I]f one looks at the question in terms of Taiwan without taking Mainland China into consideration, then the motivation is extralinguistic, being simply a means of maintaining control of a majority by a minority. The reason for this being that the [purely] linguistic solution would have been for the minority to learn the majority language upon arrival."); ROC YEARBOOK, supra note 44, at 53 ("[M]andarin use in Taiwan is firmly established and [Hoklo and Hakka] pose no threat to its status.").

         89See Tai Sun, supra note 81, at 30 (Suppression of Taiwanese, Hakka and even Aboriginal languages came in three wide assaults: (1) cultural/psychological undermining through social ostracism and educational humiliation, (2) prevention of the native languages from standardizing, maturing, and developing written orthographies, and (3) usage restriction in media, television and public forums). For a detailed discussion of the impact schooling had on inducing shame among Taiwanese-speaking youth, see Li Liao & Bichuan Yang, Kongzhi ni de yuyuan, xiaomie ni de lishi [Control your language, wipe out your history], XINCHAOLIU, May 15, 1986, at 25, cited in Tai Sun, supra note 81, at 31. See generally STRUCTURE OF TAIWANESE, supra note 87.

         90RESTATEMENT, supra note 17, § 702, Reporters' Notes 7 (the International Convention on the Suppression and Punishment of the Crime of Apartheid defines it in Article II as being domination by a racial group of persons over any other racial group of persons by means including denial of life and liberty to member(s) of a racial group and the persecution of organizations and persons, by deprivation of fundamental rights and freedoms based on their opposition to apartheid); see also ROBERT G. SUTTER, CONG. RES. SERVICE, TAIWAN: RECENT DEVELOPMENTS AND U.S. POLICY CHOICES, (Cong. Res. Service Issue Brief, May 26, 1994) (for about four decades, power was concentrated in the 15% of the population who were mainlanders).

         91UMOZURIKE, supra note 8, at 90-91.

         92RESTATEMENT, supra note 17, § 72, Reporters' Notes 3. See also 2 Y.B. INT'L L. COMM'N 32, §§ 404, 423.

         93See Envoy to UN Reiterates China's Position on Taiwan Question, BBC Summary of World Broadcasts, July 25, 1996, available in LEXIS/NEXIS News library, Curnws file; China Reiterates Position on Taiwan, Xinhua News Agency, July 23, 1996, available in id. (letter from Chinese Ambassador Qin Huasun to UN Secretary-General Boutros Boutros-Ghali protesting Taiwan's petition for UN membership).

         94Professor Liu Wenzong of the International Law Research Institute, College of Diplomacy in China, is fairly representative of conservative academics in China on the issue of Taiwan. See Liu, U.S. Government Responsible for Consequences of Li Tenghui's Private Trip to the U.S., FAZHI RIBAO, June 2, 1995, at 4 (in Chinese).

         95The International Court of Justice has in the past affirmed that treaty interpretations are always matters of international concern, and once a nation accedes to a treaty it implicitly submits to international law. For example, in the Right of Passage case, the International Court of Justice sided with Portugal in its claim for relief based on a treaty with India which the latter chose to ignore in lieu of its own domestic jurisdiction, 1957 I.C.J. 125, 150, cited in Chen & Reisman, supra note 49, at 648-49 n.183.

         96Nor can China seek to invalidate the Treaty of Shimonoseki, because it is unprecedented for any nation to unilaterally revoke treaties involving the transfer of territories even under the defense of duress. See Trans-Orient Marine v. Star Trading & Marine, 731 F. Supp. 619, 622 (S.D.N.Y. 1992), rev'd 925 F.2d 566 (2d Cir. 1991), cited in RESTATEMENT § 203, Court Citations to Restatement, Third. (The government of Sudan moved for summary judgment on grounds that it was a successor state subsequent to two military coups and therefore not bound by contractual obligations of the prior sovereign. The court denied the motion, reasoning that there was a change in government, not in statehood.).

         97For a detailed argument on China's weak prescriptive claim to Taiwan, see Chen & Reisman, supra note 49, at 621-26.

         98Letter from Lord Avebury, Chairman of the Parliamentary Human Rights Group, House of Lords, to Ma Yuzhen, Ambassador to the United Kingdom, supra note 47 ("Bands of Japanese are said to have conquered portions of the island in the 12th century, and from the 15th century onward Japan regarded the eastern half of Taiwan as its possession.").

         99ROC YEARBOOK, supra note 44, at 80-81. See also NORTH AMERICAN TAIWANESE MEDICAL ASSOCIATION, A NEW TAIWAN (1995).

         100See ROC YEARBOOK, supra note 44, at 81.

         101Id. See also TAIWAN INTERNATIONAL ALLIANCE, TAIWAN, CHINA, AND THE WORLD 6 (1995) [hereinafter TAIWAN, CHINA, AND THE WORLD].

         102See TAIWAN, CHINA, AND THE WORLD, supra note 101, at 6 (In 1874 China refused to assume responsibility for the massacre of shipwrecked Japanese sailors killed by Taiwanese aborigines). See also Chen & Reisman, supra note 49, at 623 n.88. China's absence of control over Taiwan was amply demonstrated by at least 68 revolts in the 211 years that the Ch'ing nominally controlled the island. KERR, supra note 54, at 24.

         103UMOZURIKE, supra note 8, at 196.

         104See id., at 180-81 n.20.

         105Id. at 181, n.23.

         106Id. at 180-82.

         107PEACEFUL COEXISTENCE, supra note 66, at 15. In addition, many countries have deliberately used the words "understand," "acknowledge," or "notice" in referring to the "One China" policy. This falls short of endorsing China's claim that Taiwan is a Chinese province. Senior China specialist at the Heritage Foundation, retired Ambassador Harvey Feldman, has often noted that even the U.S. recognition of the PRC only "acknowledges" China's position that Taiwan is an integral part of China; it does not confer legal recognition of Chinese sovereignty.

         108See Chen & Reisman, supra note 49, at 649.

         109RESTATEMENT, supra note 17, § 201 (enumeration added).

         110Id. at § 203 cmt. b ("Formal recognition of a government, like formal recognition of a state, is not mandatory, but there is a duty to treat as the government a regime that is the government in fact, just as there is an obligation to treat as a state an entity that is a state in fact.").

         111Despite the absence of diplomatic relations and recognition of Taiwan as a country, U.S. federal law treats Taiwan as a state for enforcement of obligations and rights of Taiwan under U.S. law. Likewise, the applicable laws of Taiwan are the governing law whenever circumstances make application of U.S. law dependent on Taiwanese laws. Taiwan Relations Act, 22 U.S.C. §§ 3301-3316 (West 1996). The United States maintains unofficial relations with Taiwan through its American Institute in Taiwan, while Taiwan maintains a reciprocal office, the Taipei Economic and Cultural Representative Office. See Sutter, supra note 90, at 2.

         112PEACEFUL COEXISTENCE, supra note 66, at 15.

         113IVAN BERNIER, INTERNATIONAL LEGAL ASPECTS OF FEDERALISM 13 (1973); RESTATEMENT, supra note 17, § 203 cmt. a (unrecognized states are obligated under customary international laws as much as recognized states are bound to uphold it); § 203 cmt. b (although a state can withhold recognition of the entity's government, interaction with it creates rights and obligation for that unrecognized entity).

         114Cheri Attix, Between the Devil and the Deep Blue Sea: Are Taiwan's Trading Partners Implying Recognition of Taiwanese Statehood?, 25 CAL. W. INT'L L.J. 357, 382 (1985); Convention on International Civil Aviation, Dec. 7, 1944, art. 1, 61 Stat. 1180, U.N.T.S. 295 ("every State has complete and exclusive sovereignty over that airspace above its territory").

         115See Hungdah Chiu, Status of Customary International Law: Treaties, Agreements, and Semi-Official or Unofficial Agreements in Chinese Law, in 91 Occasional Papers/Reprint Series in Contemporary Asian Studies 2 (No. 2, 1989), cited in Winston Hsiao, The Development of Human Rights in the ROC on Taiwan: Ramifications of Recent Democratic Reforms and Problems of Enforcement, 5 PAC. RIM L. & POL'Y J. 161, 191 n.197 (1985).

         116See RESTATEMENT, supra note 17, § 702 cmt. b ("[A] state is responsible for acts of officials or official bodies, national or local, even if the acts were not authorized by or known to the responsible national authorities, indeed even if expressly forbidden by law, decree or instruction.").

         117C.L. Chiou, The 1990 National Affairs Conference and the Future of Democracy, 25 BULL. CONCERNED ASIAN SCHOLARS 17-32 (1993). The June 28-July 3, 1990 conference drew from segments of the student population, private individuals, academia, and the political opposition.

         118For a detailed account of governmental abuses in the Judicial Yuan and its Council of Grand Justices, the nation's highest court, see F. Frazer Mendel, Judicial Power & Illusion: The ROC's Council of Grand Justices and Constitutional Interpretation, 2 PAC. RIM L. & POL'Y J. 157 (1993).

         119See ROC President Lee Teng-hui Proclaims Termination of "Period of National Mobilization for Suppression of Communist Regime" PR Newswire, Apr. 30, 1991, available in LEXIS/NEXIS News library, Arcnws file.          120Sutter, supra note 90, at Summary (elections for the National Assembly occurred in December 1991 elections for the Legislative Yuan took place the following December, while county magistrates' and other local officials' seats were contested in 1994; in December 1994 the mayoral elections for Taipei and Kaohsiung took place alongside the gubernatorial race, and the presidential election was held in March 1996).

         121ROC CONST. art. II (amended Aug. 1, 1994).

         122Long-time Asia watcher Ian Buruma concurred that democracy is an "irrefutable argument" that Taiwan is a country ("a sovereign people cannot exist without a sovereign state."). See Ian Buruma, Taiwan's New Nationalists, 75 FOREIGN AFF. 90; Sutter, supra note 90, at Summary. Taiwan has in recent years gained the support of the U.S. Congress in its pursuit of membership, due in no small part to its democratic reforms.

         123See Sutter, supra note 90, at 9.

         124See Wei-chin Lee, Taiwan's Foreign Aid Policy, 20 ASIAN AFF. 43 (1993).

         125Id.

         126DPP Legislator Frank Hsieh challenged now acting Foreign Minister John Chiang to defend the government's reluctance to apply for the UN in the now famous 1992 televised debate.

         127See Sutter, supra note 50.

         128Premiere Lien Chan gave an address to the 85th Annual Convention of the Rotary International on June 12, 1994. See LIEN CHAN, GOV'T INFO. OFF., ROC, HEADING FOR THE 21ST CENTURY 106-10 (1994).

         129ROC YEARBOOK, supra note 44, at 144.

         130President Lee said in his inaugural address, "both sides pursue eventual national unification." See President Lee's inaugural address, reprinted in SINORAMA, July 1996, at 19.          131GOVERNMENT INFO. OFF., ROC, THE REPUBLIC OF CHINA ON TAIWAN & THE UN: QUESTIONS & ANSWERS, BROCHURE 4 (1994); See GOV'T INFO. OFF., ROC, THE REPUBLIC OF CHINA ON TAIWAN: A WORTHY NATION DESERVES A UN SEAT (1993). There the KMT government argues that "[Resolution 2758] has resolved the issue of UN representation for the Chinese people on the mainland, but it has by no means resolved the problems arising from China's division and separate rule."

         132China again protested the KMT government's attempt to have the UN consider the ROC's UN application. See letter from Chinese Ambassador Qin Huasun to Secretary-General of the UN Boutros Boutros-Ghali, supra note 93 (protesting Taiwan's petition for UN membership). In 1995 PRC Foreign Ministry spokesman Shen Guofang stated, "It should be pointed out that the moment the People's Republic of China was founded, the 'Republic of China' had become a thing of the past. However, the Taiwan authorities are still clamouring for UN membership under the usurped name of the 'Republic of China.'" See C.C. Kwok, No Compromise on Status of Taiwan, WINDOW, July 28, 1995, at 22.

         133See BAEHR & GORDENKER, supra note 3, at 45.

         134See YODER, supra note 4, at 37.

         135See BAEHR & GORDENKER, supra note 3, at 45.

         136"The old formula for avoiding conflict--agreeing there was one China, but agreeing to disagree over which was its legitimate government--is breaking down." Don't Even Think About It, ECONOMIST, Feb. 3, 1996, at 14.

         137Letter from Lord Avebury, Chairman of the Parliamentary Human Rights Group, House of Lords, to Ma Yuzhen, Ambassador to the United Kingdom, supra note 47.

         138Ross Terrill, Chairman Mao's Sacred Cow: "One China" Doesn't Make Sense Anymore, WASH. POST, Sept. 22, 1996, at C1-C2 (the British successfully recognized the independence of Canada, New Zealand, and Australia, despite the fact these countries had a population predominately of English descent, use a common English language and rely on established English institutions and culture for their political, social and economic foundation).

         139See UMOZURIKE, supra note 8, at 77. The French minority in Algeria was not permitted to obstruct that country's independence as determined in UN General Assembly Resolution 612 (VII) of 1952. A Turkish minority was likewise denied a right to delay Cyprus' independence, in a similar rejection of the argument that a minority community has a right to its own self-determination from the majority.

         140Julian Baum, Tough Mandate, FAR E. ECON. REV., Apr. 4, 1996, at 15. Some Taipei political analysts say the combined 75% votes represented "Taiwan first" sentiments. That is, either approving Lee Teng-hui's efforts at rebuking Beijing's isolation efforts, or supporting the DPP's separatist views. See The Day Taiwan Stood Up, ECONOMIST, Mar. 30, 1995, at 37-38 ("It is clear that almost three-quarters of Taiwanese now favor at least de facto independence. It is now the diehard 'mainlanders' who feel marginalised.").

         141See Problems of Togetherness, ECONOMIST, Apr. 13, 1996, at 31 ("[T]he presidential election in Taiwan was widely seen as a dramatic assertion of Taiwanese identity, and a possible step on the road to an eventual declaration of formal independence from China."); Philippe Le Corre, China Near, but Taiwan Films Go Own Way, WALL ST. J., Apr. 25, 1995 ("[I]n . . . areas of intellectual endeavor as well [as culture], differences with China are stressed over similarities."); Dorinda Elliott, Don't Stop the Music, NEWSWEEK (International) Mar. 18, 1996, at 16 ("Taiwanese culture is back in classrooms and homes...."); Mahlon Meyer, Class Politics: Taiwanese, Chinese Students Don't Mix, Even on U.S. Campuses, FAR E. ECON. REV., Dec. 1, 1994, at 56-57.

         142Besides the DPP, pro-independence endorsements have come from popular segments of Taiwanese society within Taiwan and abroad. See PEACEFUL COEXISTENCE supra, note 66. See generally FORMOSAN ASSOCIATION FOR PUBLIC AFFAIRS, TAIWAN: THE SILENCED MAJORITY--THE CASE FOR SELF-DETERMINATION (1984) (the Taiwan Presbyterian Church call for self-determination on December 30, 1971, and Statement by the World Federation of Taiwanese Associations, and the Taiwanese Association of America); Sam Seibert, Peter McKillop & Jeff Hoffman, Going Its Own Way, NEWSWEEK (International), Dec. 23, 1991, at 10 ("[T]he new generation no longer hides its quest for independent nationhood."); Ian Buruma, Taiwan's New Nationalists Vol., 75 FOREIGN AFF. (July/Aug. 1996) at Table of Contents Summary ("[the KMT's] dream of reunification has gone the way of their might, replaced by the native Taiwanese desire for an independent country.").

         143See Should Taiwan be Admitted to the United Nations: Joint Hearing Before the Subcomm. on Int'l Security, Int'l Organizations, and Human Rights, House Foreign Aff. Comm., 103d Cong., 2d. Sess. 93 (1994) (statement of John Bolton).

         144GOVERNMENT INFO. OFF., ROC, THE ROC ON TAIWAN: A WORTHY NATION DESERVES A UN SEAT, BROCHURE 3 (1993).

         145See Parris Chang, TOPICS, ISSUES ON INTERNATIONAL BUSINESS IN TAIWAN, August 1995, at 48 (published by the American Chamber of Commerce in Taipei).