ORAL ARGUMENT OF SIR CHARLES RUSSELL, Q. C. M. P. 13 



Senator Mo'rgan. — That appears to be the question of indiscrimi- 

 nate killing", whether on land or sea. 



Sir Charles Russell. — In another connection as I have shown, 

 and I shall have again to show, that although the United States claim 

 was for discrimiuately to kill upon land, that is not a well-founded 

 claim. 



Senator Morgan. — I am not speaking of the claim of the United 

 States; I am speaking of the fact that it results in the destruction of 

 the seal species; and the point is indiscriminate slaughter. 



Sir Charles Russell. — 1 do not care, Sir, whether it is indiscrimi- 

 nate or discriminate, — one need not dwell upon that. They are slaugh- 

 tered. AVhether you can call killing on the Islands discriminate or not, 

 it has led to the depletion. 



Senator Morgan. — I am speaking of the killing of seals in the South- 

 ern Hemisi)here as well as in the Northern. Has not the destruction 

 of the seal species in the Southern Hemisphere resulted from indis- 

 criminate slaughter? 



Sir Charles Russell. — On land, it has. 



Senator Morgan. — Or on the sea either. 



Sir Charles Russell. — No, on the contrary. 



Senator Morgan. — No matter where. 



Sir Charles Russell. — No. On the contrary there has been no 

 instance whatever of any killing which it is even alleged had affected 

 seal life in any of the southern portions of the globe or anywhere else, 

 so far as I know attributed to pelagic sealing. No, Sir. 



Senator Morgan. — That may be the better method ; but the ques- 

 tion still recurs whether the loss of seal life in the Southern Hemi- 

 sphere and in the north is not due to indiscriminate killing, whether on 

 land or at sea. 



Sir Charles Russell. — At present I am dealing with pelagic seal- 

 ing. I am endeavouring to see what are the crimes properly to be 

 attributed to pelagic sealing; and in this connection dealing with this 

 concrete case, what i)art pelagic sealing has played in the depletion of 

 the heard of the seals frequenting or habitually resorting to the Beh- 

 ring Sea. 



Now my learned friend Mr. Carter in dealing with this matter put 

 forward this argument. It is to be found at page 81 of the United 

 States argument in print I think, and also I think in my learned 

 friend's argument — I have not the page at this moment — orally deliv- 

 ered. It was to this effect: a great part, said my learned friend — and 

 said truly — of the seals killed by pelagic sealers, are females and there- 

 upon he went on to say that being females that necessarily caused a 

 diminution of the stock and a lowering of the birth-rate of the stock 

 below the normal point which it would otherwise naturally reach. I 

 want to point out, with great respect to my learned friend, that that 

 is not correct; because it would assume that the female killed had pro- 

 duced no young at all, and would produce young if it had not been 

 killed. Let me remind the Tribunal and remind him that according 

 to the evidence it is stated that each female produces in the course of 

 its normal life, assuming that it escapes the great dangers to which 

 it is exposed from natural causes, from 11 to 14 pups. It is put as 

 high as 14. 



Senator Morgan. — 12 is an average? 



Sir Charles Russell. — Assume 12 to be an average by all means. 

 My learned friend will see at once that if the particular female that has 

 been killed is one that has produced even two pups, the killing of that 



