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equire the presence of military forces in every populated area, although the occupying forcemust, inter alia, control the most important places. 57The type of forces used to maintain the authority of the Occupying Power is not material.For example, the occupation might be maintained by permanently based units or mobile forces,either of which would be able to send detachments of forces to enforce the authority of theOccupying Power within the occupied district. 58 However, air superiority alone would notconstitute an effective occupation.Similarly, as long as the occupation is effective, there is no precise number of forces thatare considered necessary to constitute an effective occupation. The number of forces necessaryto maintain effective occupation will depend on various considerations, such as the disposition ofthe inhabitants, the number and density of the population, the nature of the terrain, and similarfactors. 59 An occupation may be effective despite the existence of areas in the enemy State that aretemporarily controlled by enemy forces or pockets of resistance. For example, the fact that adefended location (such as a city or town) still controlled by enemy forces exists within an areadeclared occupied by the Occupying Power does not render the occupation of the remainder ofthe area invalid, provided that continued resistance in such place or defended zone does notrender the occupier unable to exercise control over the remainder of the occupied territory. 60Similarly, an occupation may continue to be effective despite intermittent insurgent attacks ortemporary seizures of territory by resistance forces. 6157 Keely v. Sanders, 99 U.S. 441, 447 (1878) (“No conquering army occupies the entire territory conquered. Itsauthority is established when it occupies and holds securely the most important places, and when there is noopposing governmental authority within the territory. The inability of any other power to establish and maintaingovernmental authority therein is the test.”).58 1956 FM 27-10 (Change No. 1 1976) 356 (“It is sufficient that the occupying force can, within a reasonable time,send detachments of troops to make its authority felt within the occupied district. It is immaterial whether theauthority of the occupant is maintained by fixed garrisons or flying columns, whether by small or large forces, solong as the occupation is effective.”).59 1956 FM 27-10 (Change No. 1 1976) 356 (“The number of troops necessary to maintain effective occupationwill depend on various considerations such as the disposition of the inhabitants, the number and density of thepopulation, the nature of the terrain, and similar factors. The mere existence of a fort or defended area within theoccupied district, provided the fort or defended area is under attack, does not render the occupation of the remainderof the district ineffective. Similarly, the mere existence of local resistance groups does not render the occupationineffective.”).60 1958 UK MANUAL 502 (“The fact that there is a defended place or zone still in possession of the national forceswithin an occupied district does not make the occupation of the remainder invalid, provided that such place ordefended zone is surrounded and effectively cut off from the rest of the occupied district.”).61 United States v. List, et al. (The Hostage Case), XI TRIALS OF WAR CRIMINALS BEFORE THE NMT 1243 (“It isclear that the German armed forces were able to maintain control of Greece and Yugoslavia until they evacuatedthem in the fall of 1944. While it is true that the partisans were able to control sections of these countries at varioustimes, it is established that the Germans could at any time they desired assume physical control of any part of thecountry. The control of the resistance forces was temporary only and not such as would deprive the German armedforces of its status of an occupant.”).746