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



What I was jjoiiig to sliow is this: I will take the year 1882, where 

 the figure given by the British Commissioners is 12,000; and I stop at 

 1882 for this reason: the pup born in 1882 would be a yearling in 1883, 

 would be a two-year-old in 1881 and would be a three-year-old in 1885. 

 Therefore, indeed, I ought properly to stop in 1881. That is to say, no 

 eflect of the killing of females in 1885 could be felt upon the number 

 of killable seals until the year 1884. That is to say, a pup in 1881 is a 

 yearling in 1882, a two year old in 1883, a three year-old in 1884, and is 

 kil]al)le, in his prime, from 3 to 5 years of age. Therefore the effect of 

 the killing of female seals could not tell uj^on the number of killable 

 males, or either sex, for that matter, until 1884, or the third year 

 afterwards. 



I have assumed for this purpose the figure given in the case by the 

 British Commissioners. They put the figure in 1881 at 0,000. The 

 American Commissioners put it at double that. Therefore you may 

 take it either one way or the other. It will not, I think, materially aU'ect 

 the matter. If it is 0,000, there are 0,000 pups born, which is a very 

 violent assumption — 0,000 gravid females, which, if not killed, would 

 have born 0,000 pups, of which 3,000 alone, because tlie sexes are equal, 

 would have been males, and tberefore would, in the year 1884, if the 

 mother had not been killed, have come into the (tlass of killable males 

 in 1884, and would have been in the class of killable males from 1884, 

 when it was 3 years of age, up until it was 5, or later. 



Now, of those 3,000 inale i)ups sup})osed to have been lost because 

 their mothers were killed in 1881, how nniny survived to reach two years 

 of age? According to the figures given by the United States in the 

 diagram to which I have referred, 900 only. How many would reach 

 three years of age? 720 only. Double, treble, quadruple the amount 

 of pelagic killing; and you get to a figure comparatively insigniticant 

 and wholly inadequate to account for or even go any substantial way 

 to account for the decrease which it is said was so noticeable in the year 

 1884, according to Mr. Coudert's argument, and following the printed 

 argument put forward on the part of the United States. 



Therefore I say, take any set of figures you please, starting from 1881, 

 and taking their contention to be that the decrease was markedly 

 noticeable in 1884, that could not have been noticeable until the ])U])s 

 had got to the age when if they had been interfered with they would 

 have been in the killable class, beginning with 3, and rising up to 5, 6 

 and 7 years of age. 



We have other ways also of testing this matter. One specific accu- 

 sation made against pelagic sealing is this; and they say that having 

 found this specific accusation to be capable of su])port, in one particu- 

 lar set of years, that it may be equally true, and a cause of the death 

 of the pups in previous years. That is to say, that in the year 1891 

 there was found to be upon the islands a large number of dead pups, 

 dead, as they say, from examination after death, because they were 

 starved, the starvation, as they allege, being attributable to the fact 

 that their mothers were killed in Behring Sea and so they were deprived 

 of their natural nutriment, causing the wholesale death of these pups, 

 which was manifest upon the island. 



The first observation one has to make in relation to that is this: that 

 it will be found that the whole of those deaths of pups in any noticeable 

 degree in 1891, were found on St. Paul's Island alone, not on St. George. 

 I need not ])oint out that if the death of those pups was attributable to 

 the killing of their mothers by pelagic sealing, that you must have found 

 corresponding indications of death of pups equal or proportionately 

 upon both islands. I think that will not be disputed. 



