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However, it did happen...
In fact, the first ship that was sunk by a submarine during WW II was a passenger ship.
It was the "Athenia", just off the British coast. September 3, 1939.
An incident that became known as the "Athenia Incident".
The commander of U30, Fritz-Julius Lemp, stated on his return to Wilhemshaven that the darkened ship was on a strong zigzag course and he had difficulty in clearly identifying the ship. Without getting any certainty, he thought he could classify the ship as a troop transport, Q-ship or an armed auxiliary cruiser.
The sinking of the unarmed passenger steamer not only violated international law, but also an order issued by the commander of the Uboats, Admiral Dönitz, on the same day - namely that attacks on passenger liners were expressly forbidden.
The command of the Kriegsmarine decided not to bring Lemp to court martial, since Lemp could plausibly claim that he had confused the ship with an auxiliary cruiser or troop transport.
The political regime in Berlin decided the incident should be kept secret, denied the torpedoing and propaganda claimed that Churchill himself had ordered the sinking in order to turn the neutral states against Germany.
The truth only came to light at the 1946 Nuremberg Trials.
As a result of this incident, submarines were forbidden to attack passenger ships, whether they were darkened, zigzagging, or even guarded by escorts in a military convoy.
Sad enough:
This had less humanistic reasons, but was rather due to an incident from World War I when the "Lusitania" was sunk by a German submarine in the spring of 1915. An incident in which American citizens were killed and which naturally led to protests from the USA.
Germany feared a repetition of the events that could eventually lead to the USA entering the war.
So your instinctive concerns are quite correct.
Passenger ships should - if you want to stick to historical events - not be sunk.
At least not during the first two years of the war.
Btw:
Fritz-Julius Lemp (the commander who sunk the Athenia) later took command of U110, which was captured by the British. During this incident, the Enigma encryption machine and all important documents fell into the hands of the British.
As a result, the British secret service could in fact read the radio communications from the German submarines while they were being broadcast.
One of the main reasons the Uboat-War war was unsuccessful.
Karma, one could say.
The only way Lemp was acting against international conventions was that he sunk the ship without providing a safe escape for the crew and passengers (taking them on board or life rafts and sending ou a radio message on public channels). But that is not possible with a submarine, so it was out of the question anyway.
Also might be worth noting the story of U-156 (the Laconia incident), who sunk an allied troop transport. Radio'ed for allied ships to come pick up the survivors and waited near the wreckage only to be attacked and forced to dive (and leave the survivors) by a B-24 bomber. Donitz mentions this story in his book and was not to happy about it, ordering all submarines from 1942 onwards to not attempt to rescue survivors.
You have to take a neutral position in order to be able to classify both incidents somewhat correctly from a historical point of view.
To make the differences between the incidents clear and why they cannot be compared, a quick summary of the "Laconia-Incident":
Unlike Lemp (U30), Commander Hartenstein of U 156, was certain that he was attacking a troopship/auxiliary cruiser because the ship was visibly armed and in the service of the Royal Navy.
The fact that the "Laconia" had prisoners of war (Italians) and civilians (women and children) on board was unquestionably a tragedy in itself, made even greater by subsequent events - the attack on the rescue operation by an US air force plane. A second attack took place the next day.
Three German and one Italian uboat were involved in the rescue operation.
The senior officer on duty that day claimed that he did not know that this was a Red Cross German rescue operation and that's why he ordered the B-24 to attack the uboats.
The officer stated he feared that the German submarine would attack two Allied freighters which where diverted by the British to the site of the Laconia sinking.
In addition he assumed that the German submarine was rescuing only the Italian prisoners of war.
He also assumed that the uboat might discover and shell the secret Ascension airfield and fuel tanks. Ascension is an island from where the attacking B-24 started.
Neither the commanding officer nor the crews of the aircrafts were further questioned about the incident, nor punished. Nor was the incident made public.
Presumably for similar reasons as the Germans concealed the sinking of the Athenia.
For the action unquestionably did not cast a positive light on those responsible either.
Today the Naval War College of the United States Navy considers the attack of the aircrafts as "prima facie" (in the first sight) war crime.
Under naval warfare conventions, ships, including submarines, conducting rescue operations are considered immune from attack.
But to return to the sinking of the Athenia in violation of international law:
Lemp's guilt in sinking the "Athenia" is clearly the fact that he carried out an attack under unclear circumstances - and without warning.
And according to the law of naval warfare, if the situation is unclear, it is not allowed to attack.
The Athenia was btw. not a neutral ship. It sailed under the British flag.
But even so: the fact that the ship zigzagged and was darkened is of secondary importance.
Especially because Lemp ignored the BdU order not to attack passenger liners - and he ignored the German Prize Rules (Prisenordnung).
One can credit him with inexperience. But the attack was wrong under international law.
The fact that Lemp was not court-martialed was more for political reasons.
As Athenia was an unarmed passenger ship, Lemp's attack violated the Hague conventions and the London Naval Treaty of 1930. Under the terms of the treaty, warships were allowed to to stop and search merchant vessels, but forbade capture as prize or sinking unless the ship was carrying contraband or engaged in military activity.
If this was the case, and if it was decided to sink the ship, it was required that passengers and crew must be transferred to a "place of safety" as a priority.
Germany had not signed the 1930 treaty - but had it's own "German Prize Rules" from 1936 (Prisenordnung), which included most of the London Naval Treaty restrictions. Including the parts mentioned in the previous paragraph..
Lemp did not follow any of these guidelines, but had chosen to sink the ship without warning.
The fact that a uboat is not able to pick up shipwrecked persons or provide them with liferafts did not exempt it from compliance with the mentioned German Prize Rules (Prisenordnung) at this stage of the war.
Which basically makes the sinking of the Athenia a war crime.
Admittedly, I do not know whether it is known why the captain of the "Athenia" ordered the ship to be darkened and stear a zigzag course. At best, I can consider that WW I had only just ended 21 years ago and the unrestricted uboat war at that time certainly had an impact on this decision. He was probably just worried that the incidents might happen again. Unfortunately, he was right.
There is factual evidence that the lusitania had in it's cargo hold over 150 tone's of strategically important cargo for the entente's war effort,
And that german agent's had witnessed the loading of that cargo and reported it back to germany moveing the lusitania from a british civilian vessel to a unarmed enemy vessel,
As for the athenia and it's very suspiciou's behavior look up the kormoran's very suspiciou's behavior that attracted the attention of hmas sydney,
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And for the laconia see below,
And in the early part's of both war's it was the entente or western allie's that escalated the war by dismissing out of hand international recognized law's and international recognized convention's,
With the use of q ship's and smuggling strategically important war cargo on civilian and neutral vessel's,
As well as deliberately ignoring openly declared intention's as cruiser rule's-prize rule's and humanitarian aid from the other side among other thing's,
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And if you strip away all the ( history is written by the victor's ) and ( propaganda ) as well as ( good vs evil or black and white ),
Your see that germany was in both war's reacting to entente and western allie's escalation's.
In the end, it's a game.
In real life, submarine commanders were forbidden to attack passenger ships after the Athenia incident. No matter if they were darkened, zigzagging, or sailing in a convoy guarded by escorts.
Germany feared a U.S. entry into the war.
The order was in effect until 1942.
--America