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



particular female does not reduce the stock at all, because she has more 

 than replaced herself by the production of her two pups; and if the 

 entire production in the course of her life is to be fixed, as you, Mr. 

 Senator Morgan, suggest, at an average of 12 pups, the probability is, 

 taking the same average, that when she meets her death at the hands 

 of the sealer she has produced six pups, and therefore much more than 

 replaces herself in the stock from which she is taken. 



And indeed my learned friend will see that his own argument leads 

 to this — 1 will say it, but say ic respectfully to him, because it is the 

 word that occurs to me — leads to this hopelessly absurd result. The 

 killer whales who are one of the great agencies of destruction of the 

 fur-seal have been going on, a natural enemy of the fur seal ever since 

 the fur-seals were, sparing neither age nor sex, not descriminating 

 between female and male, killing therefore a large number of female 

 seals. According to my learned friend's argument, if that argument 

 were well founded, the killer whales must have long since exterminated 

 the whole tribe of seals altogether. My learned friend's argument would 

 only be good if he could establish that the females that were so killed 

 were females that had not done something to replace themselves in the 

 stock, to fill their own places in the stock, because it is only in that case 

 in which they would have had any permanent effect upon the stock at 

 all. Besides my learned friend loses sight of this fact which I think it 

 is important to bear in mind, that the evidence now establishes — that 

 after the breeding seals have got to the Pribilof Islands and after the 

 time when according to my learned friend's views, the great family of 

 the seals frequenting Behring Sea had got into the neighborhood of 

 that Sea there are observed large masses of seals that never ap])arently 

 go regularly to those islands if they go at all at long distances from the 

 islands, at distances west and north of the islands and at distances 

 south of the Aleutian chain and away from Behring Sea altogether, 

 that at the very time that, according to their theory, the great family of 

 seals were gathered around and upon the Pribilof Islands. What were 

 these composed of? Many of them, we do not doubt, were composed 

 of barren females who, not going to the islands, would go to waste — it 

 is no exaggeration to say — but for the pelagic sealer. That class 

 embraces others, for instance young males that are not led to go to the 

 islands by any sexual instincts such as attracts them at a later period; 

 females not attracted by any sexual instinct, which only affects them at 

 a later period; and old seals which are considered unworthy of notice 

 by those who kill the seals upon the islands because they have reached 

 a stage at which their skins are not the most marketable, the best for 

 the market being from three to foitr or five years of age. These are all 

 classes of seals which may be dealt with without interfering so as to 

 intiict any permanent injury upon the stock of the fur seal and which in 

 large part, at least, would probably go to waste and be of no use for any 

 human i)urpose whatever unless the pelagic sealer was allowed to deal 

 with them. 



Senator Morgan.— Sir Charles, in that connection— I hope you will 

 pardon me for calling your attention to it — the statements of a good 

 many witnesses in this case would seem to indicate that every seal, a 

 year old or any other age, is impelled by its natural necessities to resort 

 to the land at some period of the summer during which its coat is 

 changed; and that that necessity is just as imperious as any instinct of 

 the animal in reference to its propagation. So that it is open to argu- 

 ment, to say the least of it, whether or not every seal does not every 

 year resort, under the necessity of an instinct that it cannot avoid, to 

 the land for the purpose of shedding its coat. 



