February 1990. The Constitutional Court of Lithuania decided the Constitution of 1938 had been suspended in 1940 and proceeded to reintroduce it. At the same time the Court recognised that it was impossible to reconstruct the system as it had existed in 1940. The new Constitution was adopted on 25 October 1992. Since then, Lithuania's arguments against the validity of the annexation have focused on Smetona's actions after the occupation. Smetona left the country on 14 June, soon after the troops arrived, and transferred his powers on an interim basis to Prime Minister Antanas Merkys, who stood first in the line of succession to the presidency. On 15 June, Merkys announced he had deposed Smetona and was now president in his own right. On 17 June, the Soviets forced Merkys to appoint the more pliant Justas Paleckis as prime minister. Merkys himself resigned under Soviet pressure later on 17 June, making Paleckis acting president. Lithuania now maintains that Smetona never resigned, rendering Merkys' takeover of the presidency illegal. Therefore, Lithuania claims that all actions leading to the Soviet annexation were ipso facto void. Baltic state continuity and international law The Montevideo Convention in 1933 was an attempt to list a legal concept of statehood. According to the definition the state has to have a territory, a permanent population, an effective government and the capacity to enter into international relations. However, already during the interwar period, the interpretation and application of the criteria were far from easy, such as the case of Åland. The concept of statehood in international law cannot be explained by mere reference to the Montevideo Convention. Decision on statehood are taken in given circumstances and at the moment in time. The Baltic states also base their claim to state continuity on two additional rules; the prohibition of the use of force in international relations and the right to self-determination, as expressed in free and fair elections. The former rule was the Baltic states' answer to Soviet claims that they had to follow the process of secession under the Soviet Constitution of 1977; the Baltic states argued that they only joined as the result of a forcible occupation. International reactions to the restoration of Baltic independence International organisations The European Communities welcomed the restoration of the sovereignty and independence on 27 August 1991. The Soviet Union recognised the Baltic independence on 6 September 1991. The Conference for Security