Back in London, on July 31st, Jackson circulated a revised draft of the statute. He used Lauterpacht's idea of titles and included the new definition of the crimes. There, in black and white, for the first time, a reference to "Crimes Against Humanity." "We should insert words ti make clear the we are addressing persecution, etc. of Jews and others in Germany, as well as outside of it," Jackson explained to the Allies, "before as well as after commencement of the war." Continue reading
"Enemies, in other words, could no longer be identified by their openly professed views. A later NKVD boss Laverenty Beria would also frequently quote Stalin, noting that 'an enemy of the people is not only one who commits sabotage, but one who doubts the rightness of the Party line.' Ergo, an 'enemy' could mean anybody who opposed Stalin's rule, for any reason, even if he did not openly profess to do so."  
Applebaum, Anne. Gulag : A History. 1st ed. ed. New York: Doubleday, 2003. pg. 102