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It is alleged that Szmielew proved that Pasch's axiom is a consequence of the circle axiom. The source is said to be

The Pasch axiom as a consequence of the circle axiom, Bull.Acad.Polon.Sci.Sér.Sci.Math.Astronom.Phys.18 (1970), 751-758

But I don't have a copy of this yet.

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No luck here with the source (online issues start at 1973), but I did find the abstract:

The Pasch axiom is known to be independent of the remaining axioms of the plane Euclidean geometry $E$. By replacing, in the axiom system of $E$, the continuity axiom ($C_0$) by the circle axiom ($C$) one gets an axion system for the so called geometry of elementary constructions. In this axiom system the Pasch axiom occurs to be dependent, thus superfluous. At the first glance the situation seems to be paradoxical, since it is common to say that $C$ is a particular consequence of $C_0$. Actually in the proof of $C$ besides $C_0$ also some other axioms of $E$ are involved, and, as we see now, the Pasch axiom must be one of them.

Moreover, Victor Pambuccian haș written an article "in memoriam to Wanda Szmielew", where he describes the axiom system she used in her 1970 paper.

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