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The Political and Cultural Roots of Negationism in France

Henry Rousso

South Central Review, Volume 23, Number 1, Spring 2006, pp. 67-88 (Article)

Published by Johns Hopkins University Press


DOI: https://doi.org/10.1353/scr.2006.0014

For additional information about this article


https://muse.jhu.edu/article/195543

Access provided at 5 Nov 2019 19:14 GMT from McMaster University Library
NEGATIONISM IN FRANCE / ROUSSO 67

The Political and Cultural Roots of Negationism in France


Henry Rousso, Institute of Contemporary History CNRS, Paris
Translated by Lucy Golsan and Richard J. Golsan

IN FEBRUARY, 2002, following repeated scandals concerning the Univer-


sity of Lyon III, Jack Lang, the Minister of National Education in the
administration of Prime Minister Lionel Jospin, created a commission
charged with shedding light on extreme right activities at the heart of
this institution. He appointed as president of the commission a histo-
rian, the author of this article, whose assignment was not to look for
those who were responsible or guilty—these names had been known
for a long time—but to trace the origins and development of the prob-
lem.1 The commission’s main concern was to examine the creation and
the development of a movement within Lyon III well known for its
right wing and extreme right wing politics, created in l973 following a
break with the University of Lyon II. The latter institution was known
as a left and extreme left-wing institution. The split itself was the out-
come of the disruptions and conflicts associated with May 1968. The
commission was especially interested in discovering why Lyon III had
been involved in nearly all of the French episodes of “negationism,” a
term created in 1987 by historians to avoid using the much abused term
“revisionist,” which identifies those who deny the existence of Nazi gas
chambers and, more generally, the reality of the Holocaust.2
After a lengthy investigation, the report was made public in October,
2004.3 Beyond the special case of Lyon III, it contributes to the history
of French universities following May 1968, and it presents an analysis
of the political and cultural roots of French negationism, underscoring
its major characteristics. The phenomenon itself did not develop exclu-
sively within marginal and isolated circles. Rather it mobilized first,
right-wing intellectuals who had already earned a certain academic stand-
ing, and it was able to express itself in several instances within certain
universities, of which Lyon III was one. The persistence of negationism
within French universities themselves is an almost exclusively French
phenomenon, seldom found in other countries. Second, negationism also
developed at the same time among postwar neo-fascists and on the ex-
treme right in general, and in certain small groups of the anti-Stalinist
extreme left—another uniquely French phenomenon. More recently, it
has manifested itself in a more massive and spectacular manner among
© South Central Review 23.1 (Spring 2006): 67–88.
68 SOUTH CENTRAL REVIEW

certain Islamic groups and within fringe groups of the French Islamic
population.
These three groups, which have all undergone changes over time, are
not identical, even though the ideas, the writings, and the individuals
associated with them have circulated among the groups. The link be-
tween negationism and the postwar far right is of long standing, the
denial of the Holocaust being one of the pre-conditions for the rebirth
of an extreme right wing in France following the failure of Vichy and
Collaboration with Nazism. On the other hand, support coming from
the “extreme left,” although indicative of hard-line Marxist divergences,
never spread beyond a few very isolated militants. The recent develop-
ment of an Islamic negationism is the result of a worldwide phenom-
enon, and attaches itself to the growth of an Arab-Muslim antisemitism,
a phenomenon not specifically French because it is linked to the broader
situation in the Middle East.
The importance of negationism for extreme right movements was
forcefully demonstrated when the commission’s report on Lyon III was
published in October, 2004. One of the accused members of the Univerity,
Bruno Gollnisch, a professor of Japanese, a European deputy from the
far right, and also a candidate to replace Jean-Marie Le Pen at the head
of the Front National, declared without even having read the text of the
Commission report:

I contest the legitimacy of this mission to police our thinking.


Henry Rousso is a politically biased historian, a Jew, a respected
figure, but his neutrality cannot be vouched for {. . .} there is
no serious historian who still agrees with the conclusions of the
Nuremburg Trials {. . .} I’m not denying the existence of con-
centration camps but, as to the number of dead, historians can
certainly differ {. . .) As for the existence of gas chambers, it is
up to historians to make up their minds{. . .} It is in the interest
of many to deny this debate in Israel in its endless discussions
over reparations.4

Later, Bruno Gollnisch contested the contents of these remarks, insist-


ing that no journalist present at his news conference had repeated his
complete statement, which should have read:

It is not unreasonable to fear that a Commission such as this


might not respect the adage ‘nemo judex in causa sua propria,’
“no one should judge his own cause.” M. Rousso, a formidable
historian of Jewish origin, Director of the Institute of Contem-
porary History (CNRS), a declared enemy of “revisionists” who
NEGATIONISM IN FRANCE / ROUSSO 69

has wrongly declared Lyon III to be riddled with them, should


have been considered a historian already engaged against what
he was asked to study. However, it seems that his report, if it is
not the mountain that gives birth to a mouse, is at least a dash of
cold water in the face of the persecutors of freedom of thought.5

In both versions of these remarks, Gollnisch denies a “Jew” the right


to talk about the Holocaust without a “contradictory position” being
presented by—an anti-Semite! This calls to mind the famous comment
by the filmmaker Jean-Luc Godard in talking about television: “Objec-
tivity is five minutes for Hitler and five minutes for the Jews.” Here we
are at the heart of the perversion introduced by negationism into the
contemporary democratic debates, which are respectful of pluralism and
equality. It is also a disquieting sign of how anti-Semitic insults have
become a commonplace in today’s France, some of these insults even
being advanced by high ranking representatives of a legal political party.
As for the remarks on the gas chambers, they only repeat what Bruno
Gollnisch had previously declared in several instances in the past.6
These pronouncements led Gollnisch to be expelled from Lyon III
for five years. He also became the object of legal proceedings which are
continuing. Even if Bruno Gollnisch did not expect such severe reper-
cussions for his remarks—repercussions which are very rare in French
universities and especially at Lyon III, which has long protected a small
faculty nucleus of the extreme right—he had nevertheless thoroughly
premeditated his statements, knowing that the context was highly vola-
tile. All the antiracist associations, the press, as well as the political
world itself had their eyes riveted on this university. If these remarks
highlight evidence of a form of provocation, this public use of
negationism, which is not without risk, also lies within the framework
of the Front National’s internal struggles, particularly within the con-
text of the struggle over who will succeed Jean-Marie Le Pen as the
party’s leader. For the past several years, two rival factions have vied
with each other for this role. One faction, led by Le Pen’s daughter,
Marine Le Pen, wishes to broaden and enlarge the base of the Front
National, since it had become a well established party on the political
landscape. This faction hopes to capitalize on the success of Jean-Marie
Le Pen in the second round of the presidential election on April 22,
2002, which caused a political earthquake in France. In official speeches
Marine Le Pen speaks to an enlarged electorate mindful of such themes
as immigration and insecurity. She attempts to present the Front Na-
tional as a “respectable” populist party by toning down the image of
political violence and racist nationalism which has characterized the
70 SOUTH CENTRAL REVIEW

extreme right since the 1930s. The other faction, led by Bruno Gollnisch,
seeks instead to emphasize the FN’s traditional extremism by appealing
primarily to the unyielding hard core militants of the party’s base. Ma-
rine Le Pen is looking for an electoral and popular legitimacy while
Bruno Gollnisch wants to be recognized as militant and partisan. His
“coming out” with regard to negationism in October 2004, thus has as
its objective getting the upper hand over his more “moderate” rival. In
this he has been at least partially successful, since Jean-Marie Le Pen
has unreservedly backed Bruno Gollnisch and disavowed his daughter
for criticizing Gollnisch’s remarks about the gas chambers.7 This gives
us an idea, then, as to what extent the expression of anti-Semitic and
negationist views serve the ends of those who wish to consolidate their
support among officials and militants of the FN. This fidelity to
negationist discourse at the highest levels of the party, and the fact that
it offers an internal rallying point, demonstrates that this heritage is
deeply rooted in the discourse of the French extreme right. As such, it
constitutes a continuation of fascism, Nazism and the collaborationism
sixty years after the end of World War II.

FROM CLAIMS TO DENIAL

The determined effort to deny the Holocaust began during the war
itself, following the Nazis’ attempts to hide the extent and erase the
most visible traces of the “Final Solution,” whose ultimate objective
was of course the physical disappearance of European Jewry. This is a
well known fact which does not need further elaboration. On the other
hand, another, less often repeated fact is that anti-Semitism, widespread
among collaborationists, notably in France, showed no significant or
tangible signs of a desire to hide the extreme violence done to Jews. Of
course, little precise and credible information filtered into the wartime
French press, which was under Nazi propaganda control.8 Certainly the
Vichy authorities, who had been actively collaborating with the depor-
tation of Jews since June 1942, remained silent as to the fate of the
populations rounded up and interned and then sent to Auschwitz. Nev-
ertheless, the collaborationist newspapers showed no special restraint,
whether they had been informed about the realities of the extermina-
tions taking place or not. Instead, they demonstrated a mounting verbal
aggression against Jews and openly expressed their satisfaction at see-
ing them excluded socially, economically, and physically. Two examples
can be cited from publications well known today.9 On 25 September
1942, several months after the first big roundup of Jews throughout
NEGATIONISM IN FRANCE / ROUSSO 71

France, Robert Brasillach published, in Je suis partout, a resounding


article in response to protests from Monsignor Saliège, Archbishop of
Toulouse, in a celebrated homily which condemned the arrests, espe-
cially in the Unoccupied Zone, where Jews were not threatened by the
Nazis: “The Archbishop of Toulouse {. . .} accuses the government and
the Marshall of imitating foreigners [the Nazis]. He speaks of brutality
and the breaking up of families. Of course we are all ready to condemn
the latter. But it is necessary to separate ourselves from the Jews in their
entirety. That includes Jewish children. In this instance, humanity and
wisdom are joined. {. . .}.”10 Written at the darkest moment of the anti-
Jewish persecutions, at the time of the arrest of thousands of children,
these words are hardly “euphemistic.” To the contrary, Brasillach ac-
cepts the violence done to Jews in France itself, independent of the fate
awaiting them at Auschwitz.
In April, 1944, when the deportations had already exceeded ninety
percent of the total number of Jews deported from France during the
war—76,000 men, women, and children—Maurice-Yvan Sicard, an-
other representative of French fascism and one of those in charge of the
Parti Populaire Francais of Jacques Doriot, wrote one of the most anti-
Semitic pamphlets ever published under the Occupation. His introduc-
tory editorial, accompanied by internment camp photographs, ends with
these words: “In our country there are patriots [the collaborators…HR]
who do not retreat in the face of anything. In our country, there are
Frenchmen who will never be defeated, no matter what happens. So, we
say to the Jews: Don’t get in their way. Don’t show yourselves to them.
Hats pulled down, in jackets, the way you came five years or five centu-
ries ago, leave. Leave quickly. Leave BEFORE.”11 Knowing full well
that the unfortunate victims had nowhere to go and that Doriot’s men
were participating in the Nazi roundups, Sicard here sounds a justifica-
tion of the deportations and suggests implicitly and fallaciously a way
for the Jews to save themselves since it proposes that they “leave.”
These brief reminders of anti-Semitism under the Occupation dem-
onstrate that this was a period of threats and denunciations, of incite-
ment to murder, and of enthusiasm over the arrests. But in no case was
it a denial of the fate reserved for the Jews. It is even more interesting
that these are the same people, or almost the same, who, several months
later, from 1945 on, would try to deny that there was a desire to exter-
minate the Jews shared by the Nazis as well as their accomplices.
Following the end of the war, and with the Axis defeated, the denial
of genocide did not figure in the defense arguments of the Nazi leaders.
For example, it was never used as a defense during the Nuremberg tri-
72 SOUTH CENTRAL REVIEW

als, nor in the trials of collaborators during the postwar purge in France.
Both groups argued, on occasion, that they “did not know,” that they
were not responsible, but not that the Holocaust had not taken place.
Reduced estimates of the number of dead aimed at minimizing the ex-
tent of the crime, and in fact the first manifestations of negationism
developed elsewhere, among a small minority of writers, intellectuals,
and university faculty who had not been implicated directly in the crimes,
even though they moved in circles with strong ties to wartime
collaborationism. For reasons essentially ideological and subsequent to
the war, these circles tried to develop an account based on the idea that
the extermination of the Jews was an “exaggeration,” “a lie,” a “myth,”
propagated by the Jews themselves. In France this argument was taken
up by the journalist Maurice Bardèche. Bardèche was Robert Brasillach’s
brother-in-law, a critic of the Purge, and a leading figure in postwar
neo-fascism. Another early champion of negationism was the former
deportee, Paul Rassinier, once a pacifist socialist deputy.
Initially, the motivations of these two men diverged sharply, although
they eventually merged. For Bardèche, the primary motivation was to
whitewash Nazi crimes—not only genocide, but other crimes as well—
in order to reinstate the values to which Nazism adhered. The first book
Bardèche wrote to this end was a long plea in favor of Nazi Germany in
the context of the beginnings of the Cold War:

The Allies had no choice. If they did not solemnly acclaim and
prove by any means available that they had been the saviors of
humanity, they were no more than murderers. If, one day, men
ceased to believe in German monstrousness, wouldn’t they de-
mand an accounting of the destroyed German cities?12

If a pure and simple denial of the facts concerning the Holocaust was
not yet explicit—it was too close to the shock of the opening of the
camps and the return of the deportees to plausibly deny the evidence—
Bardèche’s argument launched a tradition whose traces are found even
today, for example, in Jean Marie Le Pen’s infamous remark character-
izing the Holocaust as a detail of history to which we shall return shortly.
To continue with Bardèche:

It is inevitable now that the extermination of the Jews appears


to us as nothing more than one of the new tactics used in this
war that we have to judge as we judge other new tactics, such
as the extermination of the Slaves, and the bombardment of
Germany’s large cities, for example. It is useless naturally to
NEGATIONISM IN FRANCE / ROUSSO 73

point out that, like everyone else, we condemn the systematic


extermination of the Jews. But it is not useless to recall that, as
far as we can ascertain from the documents which have come to
us, the Germans themselves condemned it and most of those in
high places were ignorant of it. It is clear from parts of the trial
that the solution of the Jewish problem,13 which had had the
approval of National Socialist leaders, consisted only of a gath-
ering together of the Jews in a territorial zone which was called
the Jewish Sanctuary, a kind of European ghetto, a Jewish state
reconstituted in the East. That was what was anticipated in the
instructions known to ministers and important government of-
ficials, and that was all. Those accused at Nuremberg were able
to testify that, throughout the war, they were ignorant of the
massive executions which had taken place at Auschwitz,
Treblinka and elsewhere, and that they had learned about them
for the first time from their accusers. No trial document allows
us to affirm that Goering, Ribbentrop or Keitel lied in saying
that Himmler’s plan had been a completely personal one qui-
etly executed and for which he alone was responsible.14

A contradiction could be pointed out here between the first negationist


publications, which at times denied the facts and at other times consid-
ered the Holocaust a massive crime like many others, which is of course
a way of implicitly admitting it. It is not a question here of “cynicism”
on the part of figures like Bardèche, for they partly believed the lies
they were spreading. In any case, they strongly believed in the vital
interest of the denial, which allowed them to take part in an intellectual
world which appeared irrational to anyone not sharing their basic preju-
dices. In their case necessity became law and created belief. From this
standpoint any means—denial, banalization, underestimation—are ac-
ceptable in order to undermine established history and still have a mod-
est place in it.
Despite the presence of figures like Bardèche, without doubt the ac-
tual birth of negationist theory begins with Paul Rassinier. Rassinier
has been the subject of several works including two recent biographies,
so it is not necessary to elaborate further on him here.15 However, it is
necessary to keep in mind that he presents a special case: a socialist,
and close to the far left before the war, he was a militant in the socialist
resistance in the Occupied Zone during the Occupation, which resulted
in his deportation to Buchenwald and to Dora. After the war, still active
on the left, he undertook in a series of articles to cast doubt on the exist-
ence of homicidal gas chambers. He went so far as to elaborate a theory
74 SOUTH CENTRAL REVIEW

according to which the Jews, and the State of Israel, were the true “in-
ventors” of the Holocaust, since they were the first to profit from it.
Like Maurice Bardèche, one of his first supporters, Paul Rassinier de-
veloped his argument using a very special kind of truth. Caught up in a
logic of rejecting communism and the USSR, and hating war above all
else, he sought arguments aimed at exonerating Nazi Germany in order
to better spotlight the crimes of Stalin and of “capitalism.” Convinced
that the denunciation of Nazi crimes fed the risk of a new war, he de-
nounced the literature produced by former deportees:

One day I realized that public opinion had concocted a false


idea of the German camps, that the problem of the concentra-
tion camps remained despite all that had been said, and that the
deportees, even if they were no longer credible, had neverthe-
less greatly contributed to directing international politics onto
dangerous paths.16

This perspective comes close to the stance of the extreme right at the
end of the 1940s, which denounced a “justice of the conquerors.” It also
led Rassinier to restate a topos of Nazism: It is the Jews who were re-
sponsible for the war. Furthermore, in questioning the testimonies of
former deportees (actually those who survived the concentration camps
and not the extermination camps), Rassinier once more takes up a tradi-
tion which goes back to the days following the first World War, in par-
ticular the tradition introduced by Jean Norton-Cru, a former combatant
who questioned the truth of certain war reports which he judged exag-
gerated, romanticized, and “warlike” because they risked a new war.17
In a completely different context, Rassinier goes much further. For the
first time since 1945, his criticism of individual witnesses serves as a
foundation for a falsified interpretation of history in which the homi-
cidal gas chambers and the extermination of nearly six million Jews are
nothing but a “lie”:

With my argument concerning the bureaucracy of the concen-


tration camps in which I clarified this bureaucracy’s determin-
ing role in the systemization of the horror, it is the new light
I’ve shed on the gas chambers which has the most seriously
damaged sacred images of the concentration camps […]. I am
therefore justified in saying that all those who, like David
Rousset or Eugen Kogon, have offered detailed and heart
wrenching descriptions of their operation, based these descrip-
tions solely on gossip. This—let me be precise in order not to
NEGATIONISM IN FRANCE / ROUSSO 75

have any new misunderstandings—doesn’t mean in any way


that there had not been extermination by gas. The existence of
the installation is one thing, its purpose is another, and a third is
its actual utilization. In the second instance it is remarkable that,
in all the publications about concentration camps or at the
Nuremberg trials, no document could be produced proving the
fact that the gas chambers had been installed in the German
prison camps by government order with the purpose of having
them used for the massive extermination of detainees.”18 Wit-
nesses, for the most part officers and non-commissioned offic-
ers and seven simple SS soldiers, most certainly did say that
they had carried out exterminations by gas and that they had
received orders to do so. None of them was able to produce the
order they were hiding behind and none of these orders […] has
been found in the archives of the camps at the time of the Lib-
eration. It was thus necessary to take these witnesses at their
word. Who can prove to me that they did not testify in this way
in order to save their lives in the atmosphere of terror which
began to take hold in Germany the day after it had been
crushed?19

In this way, Paul Rassinier introduces a type of scientistic discourse,


“hypercritical in nature,” which reverses charge and proof; rather than
show that the Holocaust is a “lie,” it is incumbent on witnesses of His-
tory to prove that they are not lying. This position, very rare at this time,
led Paul Rassinier into an obsessive anti-Semitism, the former socialist
deportee being one of the very first to affirm that the Holocaust was a
lie which served above all the interests of Jews and the young state of
Israel.20
Considered the founder of French negationism, Paul Rassinier, by
taking this path, illustrates the double source of negationism, a nascent
neo-fascism and an anti-Stalinist pacifism. However, in the years l950–
l960, this movement remained discrete and marginal, without any echo
in public opinion.

THE RENAISSANCE OF 1970–1980

Beginning with the 1970s, negationist theories had a period of re-


newed success with more adherents and in a different context. The move-
ment spread to several countries with France being especially affected.
Without going into detail on each of these negationist incidents, which
have shaken the country for the last 30 years, it is possible to enumerate
76 SOUTH CENTRAL REVIEW

in a succinct manner the most important players and those who have
had an effect on public opinion, without necessarily establishing a di-
rect relation between the facts in each instance and their impact on the
public.
• On October 28, 1978, Louis Darquier, called “de Pellepoix,” former
Commissioner General for Jewish Questions at Vichy, a refugee in Spain
since the end of the Occupation, gave an interview to the important
weekly, L’Express, in which he declared, “At Auschwitz only lice were
gassed.” For several pages, he gave vent to his anti-Semitic hatred and
his bitterness as a former collaborator. The interview provoked consid-
erable emotion and accelerated an awakening interest among the French
regarding the Dark Years of the Occupation.21
• In November, 1978, another polemic erupted over Robert Faurisson,
an Associate Professor of contemporary literature, who had recently
been hired by the University of Lyon II, the left wing university. He was
known for his works on Lautréamont and Rimbaud, but he had already
spoken out on several occasions denying the existence of the Holocaust.
Siding with Darquier, he declared in several newspapers (Le Matin de
Paris, Le Monde), “The gas chambers did not exist!”22 This episode
launched the longstanding controversy over Faurisson, a controversy
which has had an important influence on negationist groups as well as
on the fringes of the extreme left and, later, among international Islam-
ist circles. It marked as well the beginning of a long controversy over
the role of the press, over the rights and duties of university faculties,
and on the extent of their “academic freedom.” This is not to be con-
fused simply with the freedom of expression of the average citizen, since
academic freedom is exercised within the framework of the university
and requires adherence to an ethics of scientific and factual objectivity.
• On June 15, 1985, a retired agricultural engineer and extreme right
militant close to Robert Faurisson, Henri Roques, successfully defended
a dissertation at the University of Nantes on the work of Kurt Gerstein.
Roques hoped that his dissertation would contribute to doubts concern-
ing the “official” truth of the Holocaust. The dissertation committee
was made up almost exclusively of extreme right militants who were
not experts on the subject. The committee was chaired by a specialist on
“Indo-European” studies, Professor Jean-Paul Allard, of Lyon III, a
known militant for the Group for Research and Studies of European
Civilization (GRECE), one of Europe’s “New Right” movements (cf.
infra). The Roques defense marked the first time the negationists had
tried in this way to have the university endorse a degree based openly
on the expression of negationist claims. The following year, after a year
NEGATIONISM IN FRANCE / ROUSSO 77

of disputes, the degree was invalidated, not on its basic premises (this
would have been impossible), but because of numerous incidences of
administrative irregularities leading to its presentation.
• On 13 September, 1987, Jean-Marie Le Pen declared, regarding the
gas chambers: “I believe this is only a detail in the history of World War
II.” He added, “There are historians who debate these questions,” a re-
mark which offered a legitimate opening for the negationists’ claims by
allowing them to again become part of the public discourse of the Front
National.
• In January, 1990, the Notin affair erupted. It was named for an in-
structor at the University of Lyon III who had published a racist and
negationist article in an internationally recognized economics review,
Économie et Sociétés. The affair took on considerable proportions be-
cause it demonstrated that the French university milieu was infiltrated
by militant negationists and that their ideas could be voiced in presti-
gious academic publications. The Notin affair took place at the time of
the desecration of Jewish graves at the Carpentras cemetery on May 10,
1990, one of the most serious anti-Semitic acts committed in France
since 1945. The desecration produced outrage and protests on a national
scale. It also resulted in the modification of the famous law of 1881 on
the freedom of the press, in declaring that denying crimes against hu-
manity committed by the Third Reich constitutes a misdemeanor. This
new law, known as the “Gayssot Law,” was named for the Communist
deputy who wrote it. The Notin affair attracted a lasting interest in the
University of Lyon III, which has since been accused of being a “bas-
tion” of the extreme right and of negationism. After a prolonged period,
Bernard Notin was finally sanctioned by the University.
• In December, 1995, the former Marxist theorist and specialist in
Third World affairs who converted to Islam, Roger Garaudy, published
Les Mythes fondateurs de la politique israélienne, which became a best-
seller in the Arab-Islamic world.23 Garaudy’s book takes its place in the
long line of writings which consider the Holocaust to be an “instru-
ment” of Israeli politics. In France, Garaudy received the support of
Abbé Pierre (who later recanted), one of the most popular men in France
because of his work with the homeless. Roger Garaudy was condemned
in l998 for denying crimes against humanity. On 24 June 2003, the Court
of Europe upheld Garaudy’s conviction. It stipulated that article 10 of
the European Convention on Human Rights, which protects freedom of
speech, could not be applied to case involving “revising or denying
clearly established historical facts – as in the case of the Holocaust.”
78 SOUTH CENTRAL REVIEW

• 1 April 1999 saw the beginning of a new controversy involving


negationism, this time implicating a former student at Lyon III and Lyon
II, Jean Plantin, who was accused by the court of operating a negationist
bookstore in Lyon. It was also discovered that Plantin had received de-
grees which were based on term papers containing negationist theses.
This new scandal involving the Lyon universities exposed not only the
negationist networks within these universities but more importantly the
inadequacies of monitoring and evaluation procedures in the French
university system.
• On 4 October 2000, Serge Thion, a historian specializing in con-
temporary Asia, a militant of the “ultra left,” and for twenty years one
of the principal supporters of Robert Faurisson, was dismissed from the
Centre National de la recherche scientifique (CNRS) for “questioning
the existence of crimes against humanity.” This is one of the most seri-
ous sanctions ever brought against the negationists, thirty years after
the inception of negationism within the confines of French universities.

THE POLITICAL REASONS FOR NEGATIONISM

If each of these affairs occurs in a specific context, the phenomenon


as a whole has deeper roots which are related to the political and cul-
tural context of contemporary France and Europe. In order to under-
stand these roots one must first consider the history of the extreme right
in France. Following the failure of Vichy in 1944, the extreme right
suffered another serious reversal with the end of the Algerian war in
1962 and the abandonment of French sovereignty over the former colony.
The battle for “French Algeria” had, for a time, provoked a feeling that
a rebirth of radical nationalism, even of neo-fascism, was possible in
France. In the decade which followed, however, with the repression of
the members of the Organisation armée secrete (OAS), the extreme
right again lost any political standing in the face of a Gaullism trium-
phant in political, institutional, and economic fields. Not until the be-
ginning of the 1970s, after the death of General DeGaulle, and with the
birth of right-wing fears of a united left (including socialist, radical, and
communist parties) taking power for the first time under the Fifth Re-
public did the extreme right regain a certain influence. As a result, the
Front National, which included several smaller groups of the extreme
right, was created in 1972 by Jean-Marie Le Pen. Several years later,
one of the founders and theorists of the movement, François Duprat,
decided to secretly introduce into France several Anglo-Saxon negationist
texts. These were Richard Harwood’s Did Six Million Really Die? and
NEGATIONISM IN FRANCE / ROUSSO 79

Arthur Butz’s The Hoax of the Twentieth Century, published respec-


tively in 1975 and 1978 in the United Kingdom. In these texts, we find
the same postwar reasoning mentioned earlier: the denial of the Holo-
caust does not spring solely from an ideological creed; it constitutes
instead a political necessity aimed at destroying one of the major ob-
stacles to the rebirth of the extreme right as a credible political alternative.
An identical reasoning explains the links between negationism and
the “New Right,” a current of thought which emerged in the years 1970–
1980 in university and cultural circles, but whose social origins and
strategic aims differ from those of the Front National.24 As a rallying
point for a number of intellectuals on the extreme right, the New Right
brought together men of diverse ideologies, heirs of Action Française
(Pierre Gaxotte, Thierry Maulnier), “liberals” (Louis Rougier), follow-
ers of “socio-biology,” as well as those nostalgic for French fascism of
the past, exemplified in the figures of writers like Lucien Rebatet and
Pierre Drieu la Rochelle.25 Turning its back on radical activism in the
1960s, the New Right tried to impose itself on the cultural field through
a “metapolitical strategy” inspired explicitly by Antonio Gramsci. It’s
aim was to counter the hegemony of Marxism in the intellectual groups
of the period. The objective was to rehabilitate an anti-democratic ide-
ology: it included the denunciation of the “Judeo-Christian” heritage
which is accused of having encouraged the emergence of human rights.
It also denounced the universalist principle of equality, adhering in-
stead to theories of biological racism from the last third of the 19th cen-
tury, and the glorification of a so-called indo-European civilization.
Henceforth, the legacy and the memory of the 1930s and 1940s fascism
was at stake either because its opponents within the New Right sought
to discredit it in assimilating it with a resurgence of fascism or Nazism,
or because other New Right proponents continued to claim roots in these
ideologies. This led, obviously, to tensions and internal divisions.
Here again, as in the postwar period and for the Front National ten
years earlier, we find a connection with negationism especially visible
inside the University of Lyon III where GRECE, the intellectual organi-
zation of the New Right, was able to install itself, thanks to the political
tenor of the university itself. Centered in a small “Institute for Indo-
European Studies,” created in 1961, a small group of linguists and his-
torians (Jean Haudry, Jean-Paul Allard, Pierre Vial...), all members of
GRECE, were able to both direct scholarly works on Indo-European
languages and spread the movement’s ideology within the university.
This small nucleus was directly involved in two of the affairs linked to
the university: the Nantes dissertation defense, whose committee chair,
80 SOUTH CENTRAL REVIEW

Jean-Paul Allard, was never officially sanctioned for his role in the de-
fense; and the Notin affair, since Bernard Notin had been a member of
the GRECE cell of the University of Lyon III. As for Jean Plantin, he
was without question influenced as a student by the special climate of
this university, at least in certain disciplines.

HISTORICAL REVISION AS A CULTURAL PHENOMENON

A second series of causes also help explain the considerable pres-


ence of the negationist phenomenon in the years 1970 to 1980. It was at
this time that the debate over the Vichy and French responsibility in the
deportations of Jews erupted. This issue soon took on a broadly Euro-
pean dimension. Because of this, negationism became not only a neces-
sary condition for the rebirth of the extreme right, but an even more
urgent necessity because historical research on the Holocaust was ac-
celerating, producing more and more witnesses and scholarly publica-
tions which completely discredited the earlier assertions of Rassinier,
intended solely to denounce the testimonies of survivors in the immedi-
ate postwar years. There exists, therefore, a link of cause and effect
between the recent versions of negationism, the rise in power of a new
radical right, and the renewal of interest in the Vichy past.
However, if political factors can explain the rebirth of negationist
theories, when all is said and done they do not explain their spreading
beyond the limited circles of the extreme right. The most important new
development in the years following the war was the impact of these
ideas on public opinion. As an emotional subject combining curiosity,
incredulity, and no doubt a certain fascination, negationism attracted
the attention of the press beginning in the late 1970s, which gave it,
ipso facto, a certain importance. There were other countries which had
their own negationist movements, but France was undoubtedly the only
one in which the issue became a recurrent public problem debated at the
highest levels and provoking a national mobilization involving actual
“national policies” and judicial actions.
We must therefore look for explanations of the phenomenon that are
not simply political, but cultural as well. Negationism made itself known
in the pervasive climate of the years following May 1968, years in which
doubt was cast on all the great mythologies of the postwar period, in
particular the official statements concerning the attitudes of countries
occupied by Nazi Germany. This “revision” of history and the reread-
ing of the latter by later generations, which took place throughout West-
ern Europe in the 1970s and 1980s, resulted in a reevaluation of the
NEGATIONISM IN FRANCE / ROUSSO 81

weight of collaboration, of anti-Semitism and of the responsibilities of


a political regime such as Vichy in France.
It also brought about, in an apparently paradoxical manner, other “re-
visions” which produced a general attitude of suspicion toward other
established historical accounts as well. This is the reason negationism
has always found support not only on the extreme right, which was
searching for ways to exonerate the Nazis, but also on the fringes of the
extreme left among intellectuals like Pierre Guillaume and Serge Thion
who took part in the Vieille Taupe (“Old Mole”) movement and its re-
view. The attraction of the theories of Rassinier and later Faurisson for
groups such as the Vieille Taupe can be explained by a greater recep-
tiveness to theories of conspiracy, to “cryptohistory” and “hypercriti-
cism,” but also by their inability to admit that the extermination of the
Jews did not arise from a materialist logic. Their inability to admit this
carried them to the point of denying the existence of the Holocaust be-
cause it did not conform to the logic of class struggle. Their negationism,
like that of Rassinier, also derived from a rabid anti-Stalinism that led
them to minimize Nazi crimes.
The attention accorded negationism is also explained by the fact that
this attempt to eradicate the past was born at the very moment when a
small part of international opinion realized, little by little, not only the
enormity of crimes committed against the Jews but also the heavy con-
sequences for later generations. This recognition was developing at the
same moment that survivors began to willingly speak out and, as op-
posed to the postwar situation, found an audience. It also set in motion,
belatedly and unexpectedly, trials for legal, moral or financial repara-
tion on a very large scale, especially in France during the 1990s. In this
sense, and even though it seems paradoxical, negationism is an indirect
consequence of “the age of memory” which western societies have en-
tertained for almost twenty years. It benefited indirectly from the sensi-
tizing of issues having to do with the Shoah. The existence and devel-
opment of negationism even became one of the recurring justifications
for repeated injunctions to remember the past in order to fulfill a “duty
to memory.”
Finally, the strong presence of negationism is to be found as well in
the rebirth of a contemporary anti-Semitism on both the right and left. It
is an essential element of judeophobia after 1945.26 There is no current
ideology hostile to Judaism that doesn’t make a reference, in one way
or another, to the Shoah in order to destroy its significance, to minimize
it or, in extreme cases, purely and simply to deny it. This recent anti-
Semitism does, of course, reproduce the rhetoric of traditional anti-
82 SOUTH CENTRAL REVIEW

Semitism, in particular that which emerged in the 19th century. The rheto-
ric embraced and promulgated the theory of a worldwide Jewish con-
spiracy and manipulation of public opinion. The most famous product
of this mindset were the infamous—and fraudulent—Protocols of the
Elder of Zion. Another permanent feature of the rhetoric related to ac-
counts of mass murders of Jews, which are perverted through a
negationist denial and even the inversion of charges, according to which
the victims become the executioners and the executioners are presented
as victims. The same phenomenon can be observed in the cases of the
Armenian genocide and in other more recent massacres, notably in the
former Yugoslavia.
However, this contemporary anti-Semitism, soaked in negationism,
also feeds on new elements which belong to the post 1945 context, in
particular the creation of the State of Israel, which redirects and par-
tially modifies the structure of traditional judeophobia. Negationism has
been used to denounce the politics of the State of Israel, accused of
being based exclusively on the “exploitation” of an “imaginary crime.”
This exonerates anti-Semitic ideologies and also plays on a reversal of
the place of victim and executioner by voluntarily exploiting the confu-
sion between “Jews” and “Israelis,” “anti-Semites” and “anti-Zionists.”
For the last ten years, negationism has been developing in a spectacular
manner in the Arab-Islamic world, in a context very different from the
European or North American one, reaching large sectors of public opin-
ion and without the legal of political restraints which exist in countries
like France and Germany or within the context of the institutions of
Europe. This is an important point which underscores the considerable
gap between, on the one hand, the over exploitation by the media and
antifascist associations in France of local and limited negationist activi-
ties as in the Lyon case, and, on the other hand, the extent of negationist
activity on a global scale coming essentially out of Arab countries or
Islamic groups.
This gap can be explained as a result of both political reasons and
psychological obstacles. The struggle against negationism and against
the extreme right carried out by large sections of the youth, has, in the
last fifteen years, given a legitimacy to the extreme left. This new legiti-
macy of the extreme left has also made it possible to avoid a serious
evaluation of bolshevism and Communism, even after the fall of the
Berlin Wall. The result is that today this extreme left is again a legiti-
mate political force with which the democratic parties of the left have to
contend. Moreover, the denunciation of the antisemitism of the extreme
right was carried out, at least until recently, to the detriment of a similar
NEGATIONISM IN FRANCE / ROUSSO 83

denunciation of an antisemitism and a negationism emanating either


from the left, or from Islamist circles, or from the French muslim com-
munity. These realities, which today are difficult to deny, have consid-
erably bothered the French left, which has been tempted to play them
down. The signs of a new judeophobia emerging from populations which
are themselves considered as “victims” of colonization or immigration
or of economic and social exclusion are clear. And the fact that they are
legitimate victims does not justify their own racism. In other words,
negationism is not only a reality which is continuous and which as-
sumes different forms, but the struggle against it involves high stakes
and stirs political rivalries between movements which attempt to use
for their own purposes the emotion and outrage generated by denial of
the Holocaust in a large majority of public opinion.

WHY THE UNIVERSITY?

Independent of the reasons which explain the strong presence of


negationism between 1970 and 1980, the question arises as to why it
developed in a university environment, inside institutions dedicated to
the dissemination of knowledge. This was and is a specifically French
phenomenon. Universities in other countries experienced similar inci-
dents, whether they admitted them or not. But France27 no doubt headed
the list in terms of such allegations being directed at the university as
such. Of the eight cases discussed earlier and which are national and
even international in scope, five concerned the universities or their cen-
ters of research (four of which were at the Lyon universities). The cases
involved either the use of the university’s name in the dissemination of
negationist ideas, or the failure of administrative oversight in the award-
ing of degrees. If the total number of incidents in nearly thirty years
remains small – a fact which invites a strong degree of caution in offer-
ing interpretations – two explanations can nevertheless be offered. The
first results from the fact that most negationists who have been active
within the university began their activities when they were already in
place. They had been hired by the universities much earlier, and un-
doubtedly the issue never arose at the outset of their respective careers.
The university thus became, simply as a result of this state of affairs, a
place for propagating negationist ideas. This was notably the case with
Robert Faurisson, whose impact on the history of negationism in France
is important, as we have seen. When he began to commit himself pub-
licly to the denial of the Holocaust, he already enjoyed a certain aca-
84 SOUTH CENTRAL REVIEW

demic and public reputation. Unlike his “teacher,” Paul Rassinier, who
claimed legitimacy only as a “critical witness” and a deportee, Faurisson
possessed an intellectual and academic legitimacy. He worked in a uni-
versity context, which allowed him to claim, or to try to claim, that his
views were part of a legitimate academic debate because they were sanc-
tioned, through his professional credentials and titles, by the university
itself. This validation by the university is what all these negationists
seek.
A further point needs to be stressed here: the fact that the majority of
negationists are rarely “professional historians” is often invoked to mini-
mize the impact of their writings, for example, those of Faurisson,
Roques, Butz, and Harwood. There are a few notable exceptions, in-
cluding Serge Thion and David Irving. The latter was recognized as a
specialist on Nazism before he began writing negationist texts. Under
any circumstances, negationist activities manifested themselves within
all the disciplines associated with Holocaust studies (literature, linguis-
tics, history) an area of research whose legitimacy no one questioned.
So, in fact, all of the human and social sciences have had to confront the
challenge of negationism because the harm done by a Faurisson, a Notin,
an Allard, a Thion, comes less from their writings than from their posi-
tion, and the respect their positions inspire.
The second danger comes from the fact that the extreme right in France
has shown itself visibly open to the ideas put forward by Robert
Faurisson. The reason for this is not that his works are basically new or
original; since 1945 the arguments have hardly varied, and most ex-
treme right militants are familiar with them because they are widely
disseminated in their political milieu. On the other hand, the interest of
the Faurisson pieces, like those of Anglo-Saxon negationists translated
in the 1970s, lies in the fact that they develop a pseudo-scientific jargon
different from the texts of Maurice Bardèche or of Paul Rassinier. This
offers them the possibility of removing their ideas from the clandestine
where they were developed and voicing them on a larger, more public
stage. There they can be transformed from simple ideological topoi which
are hardly noticed into objects of scientific “debate” founded on “ob-
jective” facts and leading to “arguable” theories, a new wording which
could (and still can) have disturbing effects on public opinion. So, for
reasons relating to the very nature of Robert Faurisson’s discourse, that
is, the discourse of a highly educated and cultured university professor,
these ideas first seduced extreme right militants within the university, at
Lyon III, Paris, Nantes, and elsewhere. These academic extreme right
militants then promote the question of negationism and develop strate-
NEGATIONISM IN FRANCE / ROUSSO 85

gies which will allow the theses on negationism to be validated by di-


plomas or scholarly writings exploiting, in one way of another, the im-
primatur of the university. This is of course as much a strategic tactic as
it is the result of the professional standing of the militants themselves.
Rather than exhausting one’s energies refuting negationism, which is
nevertheless a praiseworthy endeavor but intellectually useless, it is
preferable to consider this movement as a social and cultural fact, even
more as the “symptom” of a malady which speaks to us from the edges
of our democratic societies. Actually, if we observe negationism’s his-
tory over the last thirty years, we realize that it has raised virtually no
important historiographical questions, except possibly encouraging his-
torians to pay more attention to the subject of negationism itself. This
was one of the consequences in France of the polemic over Faurisson,
which did contribute to an increased interest in the history of Nazism
and the Holocaust. Negationism has never substantially modified the
factual truths elaborated by professional historians. The result is that,
having failed in its pseudo-historical pretensions, negationist discourse
is once again taking up the odious language of traditional anti-Semitism;
a simple click on a negationist internet site is sufficient to observe this
charge.
On the other hand, this movement has raised more serious epistemo-
logical problems concerning the status of truth in history, of the ques-
tion of “versions” of the truth, of the possibility of multiple interpreta-
tions of the past, issues which were at that moment objects of fierce
controversy. Negationism raised questions about the best way to ana-
lyze structures of argumentation that sought to deny something as mas-
sive and undeniable as the Holocaust. This is a problem historians have
often neglected in favor of examining the material circumstances of
distorted facts, or the position or situation of the negationists themselves.
In fact, questions concerning the structure of argumentation are crucial
because the denial of the Holocaust belongs to a level of discourse more
and more widespread, based essentially on universal suspicion, which
renders useless factual arguments of any kind. It functions on a mini-
mum of conventions, of confidence, and thrives on shared implicit propo-
sitions, like the radical impossibility of “proving” anything in objec-
tive, factual terms. Finally, negationism has raised major ethical, juridical,
and political problems touching on the limits of freedom of expression,
on the difficult definition of the rights and duties of professional schol-
ars, and the difficulty of accepting that history can be written by laws
like the Gayssot Law, even with its virtuous intentions. The denial of
history offers us in fact the possibility of finally writing a true history.
86 SOUTH CENTRAL REVIEW

NOTES
1. Besides the president, the commission included Annette Becker, Professor of
Contemporary History at the University of Paris X–Nanterre; Philippe Burrin, Direc-
tor of the Geneva University Institute of Advanced International Studies; and Florent
Brayard, researcher at the Institute of Contemporary History (CNRS).
2. Cf. Henry Rousso, The Vichy Syndrome: History and Memory in France since
1944 (Cambridge: Harvard University Press, 1991), l5l. An important bibliography
exists on negationism. For France see the basic texts of Pierre Vidal-Naquet, Les As-
sassins de la memoire, “Un Eichmann de papier” et autre essais sur le revisionnisme
(Paris: La Découverte, l987), which includes his famous 1980 article which appeared
in the magazine Esprit, and Alain Finkielkraut, L’avenir d’une négation. Réflexion sur
la question du Génocide (Paris: Seuil, 1982). Also see Valérie Igounet, L’Histoire du
négationisme en France (Paris: Seuil, 2000).
3. The original report is available online: ftp//trf.education gouv,fr/pub/edutel/
rapport/rousso.pdf. It has also been published: Henry Rousso Le Dossier Lyon III, L
rapport sur le racisme et le négationnisme a l’université Jean-Moulin (Paris: Fayard,
2004). This article reviews and develops certain conclusions of this work for an Ameri-
can public. Since June, 1990, negationism is a crime under French penal law, as it is in
many other European countries.
4. Remarks reported by many press organizations, among them Reuters, on October
11, 2004: <htto//www.Ici for/news/france/2004/o..3179386-VUSWXOIEIDUy.00.
html>.
5. Remarks reported on the website of the daily Francais d’abord, an organ of
the Front National, October 13, 2004: <http//www.francais. dabord.info/
quotidian.detail.php?id=2976&art=5>. And also on October 11, during a segment on
the site of an important permanent information channel (LCI), Bruno Gollnish de-
clared, and this time in a decided way: “M. Rousso is an enemy of those who contest
the official truth on the subject of World War II. He was both judge and party. This is a
Jewish person. This is a fact which could lead us to fear that the report is not altogether
objective. His work is more nuanced, however, than I had thought.”
6. Numerous examples can be found in the report even though, before October
2004, Bruno Gollnisch was not the extreme right teacher the most criticized by anti-
fascist associations.
7. Cf. Le Monde, l9 October 2004.
8. On this question see Philippe Burrin, “Que savaient les collaborationistes?”
in Stéphane Courtois and Adam Rayski, eds., Qui savait quoi ? L’extermination des
Juifs 1941–1945 (Paris: La Découverte, 1987), 67–78.
9. Cf. Pierre-André Taguieff, ed., L’antisémitisme de plume 1940–1944, Études
et documents (Paris: Berg International Éditeurs, 1999).
10. Robert Brasillach, “Les sept internationales contre la patrie,” Je suis partout,
September 25, 1942. On this text see Alice Kaplan, The Collaborator (Chicago: The
University of Chicago Press, 2000), Chapter IV; and Henry Rousso, “Une justice im-
possible: l’épuration et la politique antijuive de Vichy,” Annales ESC no. 3, June l993,
reprinted in Henry Rousso, Vichy. L’evénement, la mémoire, l’histoire (Paris: Gallimard,
2001), 639–640.
11. Maurice Maurice Ivan Sicard, “Dernier avertissement,” in Je vous hais, a bro-
chure published by the Bureau Central de Presse et d’Information, April 15, l944. The
NEGATIONISM IN FRANCE / ROUSSO 87

underlined words are underlined in the original text. After the war, Sicard wrote under
the literary synonym of Saint-Paulien.
12. Maurice Bardèche, Nuremberg ou la Terre Promise (Paris: Les Sept couleurs,
1947), 19.
13. Underlined in the text.
14. Maurice Bardèche, Nuremberg ou la Terre Promise, 193–194.
15. Florent Brayard, Comment l’idée vint à M. Rassinier. Naissance du révisionisme,
preface by Pierre Vidal- Naquet (Paris: Fayard, l996); Nadine Fresco, Fabrication
d’une antisémite (Paris: Seuil, l999). Fresco published one of the first important ar-
ticles on negationism: “Les redresseurs de morts. Chambres à gaz: la bonne nouvelle.
Comment on révise l’histoire,” Les Temps modernes (June 1980): 2150–2211.
16. Paul Rassinier, Le Mensonge d’Ulysse, Paris, 1950 (at author’s expense). This
text, as well as Rassinier’s early writings, was reprinted in 1979 by the editor of Robert
Faurisson, La Vieille Taupe, eponym of an “ultra gauche” group which began distrib-
uting negationist ideas in 1978. The quotation is from page 113 of this new edition.
17. There is a great deal of literature about these questions. On the links between
Norton-Cru and Rassinier, cf. Christophe Prochasson, “Témoignages et experiences.
Des usages du “vrai” et du “faux” de Jean Norton-Cru à Paul Rassinier,” in Christophe
Prochasson and Anne Rasmussen, eds., Vrai et faux dans la Grande guerre (Paris: La
Découverte, 2004), 189–217.
18. Underlined in the text.
19. Foreword to the second edition of Mensonge d’Ulysse (1954), 241 in the 1979
edition.
20. Especially in Le véritable procés Eichmann ou les vainqueurs incorrigibles
(Paris: Les Sept Couleurs, 1962). This publishing house belongs to Maurice Bardèche.
21. Rousso, The Vichy Syndrome, 139–144.
22. Le matin de Paris, 16 November 1978. He repeats these affirmations in Le
Monde, 29 December, 1978.
23. Cf. Richard J. Golsan, Vichy’s Afterlife: History and Counterhistory in Post-
war France (Lincoln: University of Nebraska Press, 2000), 124–142.
24. See Anne-Marie Duranton-Crabol, Visages de la Nouvelle Droite. Le GRECE
et son histoire (Paris: Presses de la FNSP, 1988); and Pierre-Andre Taguieff, Sur la
Nouvelle Droite. Jalons d’une analyse critique (Paris: Descartes & Cie, 1994).
25. Cf. the articles in Elements, no. 16, June–August 1976, p. 7, on the occasion
of the reissue of Les Décombres, Jean-JacquesPauvert, 1986; “Rèhabilitation de Drieu”,
Elèments, no. 33, February–March 1980, 51.
26. See Pierre-André Taguieff, “La nouvelle judeophobie. Antisionisme, Anti-
racisme, et Anti-imperialisme.” Les Temps modernes 520 (November 1989): 1–80.
27. In May, 2000, the University of Canterbury, in New Zealand, appointed a com-
mission of inquiry in order to establish under what conditions one of its teachers, Joel
Hayward, a specialist in the history of Nazism and strategic questions, had obtained in
1993, a Master of Arts, with highest mention which was entitled The Fate of Jews in
German Hands: An Historical Enquiry into the Development and Significance of Ho-
locaust Revisionism, in which he had later been accused of having introduced negationist
theses. It all amounted to the author drawing up an “addendum” to his conclusions and
asking to be excused at the same time for denying having had a negationist perspective.
On the history of this affair, which resembles certain incidents at Lyon III, see the
anti-negationist site: WWW.nizkor.org/ftp.cqi/people/h/hayward.joel/ and the univer-
sity site “http://www.canterbury.ac.nz” www.canterbury.ac.nz. The commission of en-
88 SOUTH CENTRAL REVIEW

quiry mobilized the British historian of Nazi Germany, Richard Evans, who was also
an expert at the trial of April 2000, which involved the historian Deborah E. Lipstadt
and the negationist, David Irving who accused her of defamation, a trial which he lost.
Cf. Richard J. Evans, Telling Lies about Hitler: The Holocaust, History, and the David
Irving Trial (London: Verso, 2002); Deborah E. Lipstadt, History on Trial: My Day in
Court with David Irving (New York: Ecco, 2005).

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