The trial of Japanese General Tomoyuki Yamashita was one of the first major war crimes trials following World War II and is a landmark case in international law. Yamashita, who had been the commander of Japanese forces in the Philippines, was tried by a U.S. military commission in Manila in late 1945. The core of the charge against him was not that he personally ordered atrocities, but that he failed to "control the operations of the members of his command," thereby permitting widespread and bru