16 ORAL ARGUMENT OF SIR CHARLES RUSSELL, Q. 0. M. P. 



We liave a means of assisting the Tribunal to what is the true meas- 

 ure of the injury done by pelagic sealing; and in order to explain it, I 

 will take the liberty of presenting, or asking the Tribunal to take, one 

 of these tables which has been prepared for the purpose of presenting 

 this. I would remind the Tribunal of this; there are certain tables 

 found in the United States volume, A, B, and 0, I think they are. 

 These three maps will be found at page 352 of the United States Case. 

 I am not going to trouble you, Sir, with a detailed examination of this; 

 but it is absolutely necessary that I should explain what it means. If 

 you will take " male Seals, diagram", facing page 352, you will see, Sir, 

 that that purports to set out what would be the natural condition and 

 distribution of a collection — I will use the word " herd" for brevity — 

 of male seals numbering 40,025; and you will observe that there are 

 different colors there to indicate the different divisions of these animals. 



The first column, which is colored green, and which is framed upon 

 the basis of an annual number of ten thousand male pups being born. 

 You will see the figure "I" at the bottom of that column. There 

 is a series of figures, 1, 2, 3, 4, 5, 6, 7, 8. You see the numbers, Mr. 

 President? 



The President. — Yes. 



Sir Charles Russell. — Those figures at the bottom indicate the 

 ages which the seals have attained; and you will see, therefore, that 

 upon the assumption of 10,000 male pups born in one year, that of 

 those 10,000. 



The President. — Pups, not male pups. 



Sir Charles Russell. — This is entirely conversant with males, Sir. 

 There is another dealing with females. That of 10,000 male pui)S born 

 in the year, ouly 5,000 survive to the next year; because you get the 

 number which survive to the next year by following the column at the 

 base of which is the figure I until you find it crosses the line. You 

 will see, therefore, it goes up to the point of 5,000. If you have 

 appreciated what I have been endeavoring to describe, I will pass on. 



What that shows, therefore, is this: assuming that their calculation 

 is correct — probably approximately it is correct — that from natural 

 causes one half of the pups born disappear, prey to accident, prey to 

 the killer whale, prey to epidemic, prey to any cause you like; but to 

 natural causes is to be attributed the fact that 60 per cent of the pups 

 born in any one year disappear during that year, and only 50 per cent 

 survive to be yearlings. That is the ouly fact I wish, in this connec- 

 tion, for the moment to beg you to carry in your mind. 



That being so, we have prepared a table in which we have taken the 

 total number of seals pelagically killed from 1871 to 1878, and then 

 going on to 1879, 1880, 1881, 1882, 1883, 1884, 1885, and we have pro- 

 ceeded upon the principle which I am now about to explain to you. 

 We have assumed that every seal pelagically killed was a female 

 seal, was not a barren female seal, but was in fact a pregnant female 

 seal. Now, let us see how the figures work out, even on that violent 

 hypothesis; because it is admitted by my learned friends that a cer- 

 tain percentage of the pelagic catch are old seals, females that are 

 barren, females that are past bearing, and male seals whose skins are 

 of comparatively little value for market purposes if killed upon the 

 islands. 



From 1871 to 1878 — although 1 do not seek to dwell upon that, 

 because it is going too far back — the number periodically killed was 

 2,000. The figures upon which I base these observations are to be 

 found set out in the report of the British Commissioners, figures 



