State responsibility the latter may have the power to interfere in matters of administration internal to a dependent State, if that power is not exercised in the particular case. In the Brown case, for example, the arbitral tribunal held that the authority of Great Britain, as suzerain over the South African Republic prior to the Boer War, “fell far short of what would be required to make her responsible for the wrong inflicted upon Brown”.295 It went on to deny that Great Britain possessed power to interfere in matters of internal administration and continued that there was no evidence “that Great Britain ever did undertake to interfere in this way”.296 Accordingly, the relation of suzerainty “did not operate to render Great Britain liable for the acts complained of ”. 297 In the Heirs of the Duc de Guise case, the Franco-Italian Conciliation Commission held that Italy was responsible for a requisition carried out by Italy in Sicily at a time when it was under Allied occupation. Its decision was not based on the absence of Allied power to requisition the property, or to stop Italy from doing so. Rather, the majority pointed to the absence in fact of any “intermeddling on the part of the Commander of the Occupation forces or any Allied authority calling for the requisition decrees”.298 The mere fact that a State may have power to exercise direction and control over another State in some field is not a sufficient basis for attributing to it any wrongful acts of the latter State in that field.299 69 especially of obligations to the international community, it is of much less significance. The essential principle is that a State should not be able to do through another what it could not do itself. (9) As to the responsibility of the directed and controlled State, the mere fact that it was directed to carry out an internationally wrongful act does not constitute an excuse under chapter V of Part One. If the conduct in question would involve a breach of its international obligations, it is incumbent upon it to decline to comply with the direction. The defence of “superior orders” does not exist for States in international law. This is not to say that the wrongfulness of the directed and controlled State’s conduct may not be precluded under chapter V, but this will only be so if it can show the existence of a circumstance precluding wrongfulness, e.g. force majeure. In such a case it is to the directing State alone that the injured State must look. But as between States, genuine cases of force majeure or coercion are exceptional. Conversely, it is no excuse for the directing State to show that the directed State was a willing or even enthusiastic participant in the internationally wrongful conduct, if in truth the conditions laid down in article 17 are met. Article 18. Coercion of another State (7) In the formulation of article 17, the term “controls” refers to cases of domination over the commission of wrongful conduct and not simply the exercise of oversight, still less mere influence or concern. Similarly, the word “directs” does not encompass mere incitement or suggestion but rather connotes actual direction of an operative kind. Both direction and control must be exercised over the wrongful conduct in order for a dominant State to incur responsibility. The choice of the expression, common in English, “direction and control”, raised some problems in other languages, owing in particular to the ambiguity of the term “direction” which may imply, as is the case in French, complete power, whereas it does not have this implication in English. (8) Two further conditions attach to responsibility under article 17. First, the dominant State is only responsible if it has knowledge of the circumstances making the conduct of the dependent State wrongful. Secondly, it has to be shown that the completed act would have been wrongful had it been committed by the directing and controlling State itself. This condition is significant in the context of bilateral obligations, which are not opposable to the directing State. In cases of multilateral obligations and 295 Robert E. Brown (United States) v. Great Britain, UNRIAA, vol. VI (Sales No. 1955.V.3), p. 120, at p. 130 (1923). 296 Ibid., p. 131. 297 Ibid. 298 Heirs of the Duc de Guise (see footnote 115 above). See also, in another context, Drozd and Janousek v. France and Spain (footnote 135 above); see also Iribarne Pérez v. France, Eur. Court H.R., Series A, No. 325–C, pp. 62–63, paras. 29–31 (1995). 299 It may be that the fact of the dependence of one State upon another is relevant in terms of the burden of proof, since the mere existence of a formal State apparatus does not exclude the possibility that control was exercised in fact by an occupying Power. Cf. Restitution of Household Effects Belonging to Jews Deported from Hungary (Germany), Kammergericht of Berlin, ILR, vol. 44, p. 301, at pp. 340–342 (1965). A State which coerces another State to commit an act is internationally responsible for that act if: (a) the act would, but for the coercion, be an internationally wrongful act of the coerced State; and (b) the coercing State does so with knowledge of the circumstances of the act. Commentary (1) The third case of derived responsibility dealt with by chapter IV is that of coercion of one State by another. Article 18 is concerned with the specific problem of coercion deliberately exercised in order to procure the breach of one State’s obligation to a third State. In such cases the responsibility of the coercing State with respect to the third State derives not from its act of coercion, but rather from the wrongful conduct resulting from the action of the coerced State. Responsibility for the coercion itself is that of the coercing State vis-à-vis the coerced State, whereas responsibility under article 18 is the responsibility of the coercing State vis-à-vis a victim of the coerced act, in particular a third State which is injured as a result. (2) Coercion for the purpose of article 18 has the same essential character as force majeure under article 23. Nothing less than conduct which forces the will of the coerced State will suffice, giving it no effective choice but to comply with the wishes of the coercing State. It is not sufficient that compliance with the obligation is made more difficult or onerous, or that the acting State is assisted or directed in its conduct: such questions are covered by the preceding articles. Moreover, the coercing State must coerce the very act which is internationally wrongful. It is not enough that the consequences of the