20 ANDREJEVA v. LATVIA JUDGMENT B. As to the respondent State’s jurisdiction under Article 1 of the Convention 51. In their replies to the questions put by the Grand Chamber, the Government stated that, in so far as the application concerned Article 14 of the Convention taken in conjunction with Article 1 of Protocol No. 1, its subject matter fell outside Latvia’s “jurisdiction”; they therefore called on the Court to reject the application. They relied on Article 1 of the Convention, which provides: “The High Contracting Parties shall secure to everyone within their jurisdiction the rights and freedoms defined in Section I of [the] Convention.” 52. The Government submitted two arguments on this issue. Firstly, from a general standpoint, they argued that responsibility for the situation complained of lay not with one single State but with two different States, namely the Soviet Union and the Republic of Latvia. In the Government’s submission, the incorporation of the Baltic States into the USSR in 1940 had taken place in breach of international law, with the result that those States could on no account be deemed to have inherited the former Soviet Union’s rights and obligations. Accordingly, although the applicant might have had some hope of receiving the portion of her pension corresponding to the part of her career spent working in the territory of the former Soviet Union, that hope had been valid only in the context of a single State, the USSR, and could not exist, or have existed, in relation to Latvia. On the contrary, “existing praxis” showed that it was rather the Russian Federation that was the defunct State’s successor, both domestically and at international level. 53. Secondly, with regard to the applicant’s position, the Government pointed out that the recycling plant where she had been employed had had no distinct legal personality; that the local authorities of the Latvian SSR had had no means of exercising effective supervision of the activities of the enterprise in question, or the applicant’s professional relations; that such relations had been governed by the laws of other SSRs; that the applicant’s salary had been paid to her by giro transfers; and, lastly, that her employers had made no contributions on her behalf to the budget of the Latvian SSR or of the Republic of Latvia. On the contrary, the applicant’s employer was established under Soviet federal law and had paid social tax on her behalf to the USSR Federal Treasury through the centralised Soviet trade union for workers in the chemical industry. The Government thus inferred that, while the applicant had been working for enterprises based in Ukraine and in Russia, she had been outside Latvia’s jurisdiction and her work in Latvian territory was rather to be likened to a business trip. In short, Latvia was not required to assume a responsibility incumbent on another State and to pay pensions in respect of periods during which the beneficiaries had been employed in that State; if the applicant wished to claim her pension