The term may also be used more broadly to refer to the duty to supervise subordinates, and liability for the failure to do so, both in government, military law and with regard to corporations and trusts. The doctrine of “command responsibility” was established by the Hague Conventions (IV) and (X) of 1907 and was applied for the first time by the German Supreme Court at the Leipzig War Crimes Trials after World War I, in the 1921 trial of Emil Müller.