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After the Soviet Union had annexed Estonia in the summer of 1940, President Konstantin Päts was arrested by the new authorities. He eventually died as a prisoner in USSR in 1956 . After Päts was arrested, Prime Minister Jüri Uluots became the Prime Minister in the duties of the President. According to Section 46 the then Estonian Constitution (''Riigi Teataja'' 03.09.1937 No. 71 Art 590), when the office of the President of the Republic of Estonia is vacant, or the President of the Republic can not perform his duties as in cases as specified by law, the duties of the President were to be performed by the Prime Minister. According to Section 52, in case both the Prime Minister and his Deputy were incapable of performing the duties of the Prime Minister, they were to be fulfilled by the eldest member of the Government. After the arrest of Konstantin Päts the Government of Jüri Uluots went underground and continued to work as constitutional authority without effective power in 1940-1944. After Soviets had arrested most of cabinet members before German occupation, the rest of them, including Uluots, fled to Sweden in the end of the Nazi Occupation Of Estonia in 1944, where they became representatives of Estonian interests as government in exile. In 1945, after the death of Jüri Uluots, the eldest member of the Government appointed by Jüri Uluots (with Otto Tief as the Deputy Prime Minister) was August Rei , the Minister of Foreign Affairs, who assumed his position after the death of Jüri Uluots. The Prime Minister in the duties of the President assumed office in the same way until 1992. Under the Stimson Doctrine , USA , and under similar Doctrine s, many other countries did not recognise the legitimacy of Soviet Occupation Of Baltic States , and consequently continued recognition of the exiled government, as the legitimate government of the Republic of Estonia until the reinstatement of the Republic of Estonia in 1991 . Accordingly, the government maintained recognised diplomatic representation in a number of Western countries. Similar arrangements were in force for the exiled governments of Latvia and Lithuania . This policy of non-recognition was instrumental in the principles of Stimson Doctrine becoming established precedent of international law. The last Prime Minister in the duties of the President Heinrich Mark , ended the work of the exile cabinet, handed over his credentials to the incoming President Lennart Meri (served 1992 - 2001 ), and formally found new authorities to be rightful representatives of Republic of Estonia, and the reinstated Estonia a continuation of pre- World War II statehood. LIST OF PRIME MINISTERS IN DUTIES OF THE PRESIDENT IN EXILE
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