ORAL ARGUMENT OF SIR CHARLES RUSSELL, Q. C. M. P. 63 



but accurate observation, numerically taken, of the actual number of 

 seals that they saw and were able to count, and the result of that is 

 shown in the rmniber of little red ticks that are to be found in Chart 6. 

 I may say it has been very carefully and correctly done, as far as we 

 can judge, considering the difficulty of doing- it, but looking- to the size 

 of tiiat map, one of those little ticks which represents a seal covers a 

 space of something' like a mile, still it is done as well as it could be 

 done; and in some instances the number recorded in the logbook of the 

 particular ship has been checked with the number of ticks to be found 

 on this maj), and they have been found to coincide, I believe, accurately 

 in the number that have been checked. 



There is one other of the 29th July, 1892, where there is quite a 

 cluster just north of the Akutan Pass. 



Now I wish to call attention to what these voyages were. They were 

 voyages during the months of July and of August, and you will observe 

 that within the St. Paul and St. George circle zones what is printed 

 across that area is this: "Seals within this area very numerous". The 

 circles are quite properly described there looking at the character and 

 shai)e of the islands; the outer line of the circle will be in some places 

 more than 20 miles from the nearest land, but the circle is at the least 

 20 miles in each case from the nearest land. Now we have taken the 

 trouble of checking their log books, and by absolutely computing the 

 seals that are here found in these numerous voyages extending over 

 the months of July and August, to see what they total up to. The 

 total shown on the map itself is 1,008 seals altogether, outside the 20 

 mile zone, and computing the entire number in the log, 1,800 seals. 

 That is the result of the observations although they say in their logs 

 that they did not begin to count until 5 or 8 miles from land. 



I need not say that when you bear in mind that the notation of one 

 of these seals upon this map occui)ies the space of nearly a mile or 

 about a mile, that does not show a very large accunuilation of seals out- 

 side the 20 mile zone, and when you have that in connexion with the 

 statement that within the 20 mile zone the seals were very numerous, it 

 does go some way to establish the i)roposition that during that which 

 is the important time to consider, the great bulk of the seals are to be 

 found within that very limited area. Of course, you will bear in mind 

 what I have said on another branch of the case that our case is that 

 there is a considerable number of seals that do not go to the Islands each 

 year and some that do not go for years. I referred to the evidence of 

 the United States Government Agent, Captain Bryant among others, 

 who expresses the opinion that in one class particularly the female seal 

 does not go from the time it leaves as a i)up till it comes back to deliver 

 its young; that would, be in the third year, and Bishop Veniaminoff 

 puts the same date. The same argument may be based upon mai) 4 to 

 which 1 have already referred. It refers to a corresponding period in 

 1891. This map refers to 1892. 



Now there is another very important matter and that is this question 

 of whether, and if so, to what extent the seals that come to sojourn on 

 the Pribilof Islands go, and if so to long distances to feed during their 

 sojourn on the Islands. I referred to this matter on Friday as showing 

 the incompleteness of information that we have on this very important 

 point. But there are certain facts in regard to the question which are 

 not in dispute, and I beg that these undisjmted facts be first noted. 

 First it is an undisputed fact that the breeding- males which come to 

 take up their place on the rookery and await the arrival of the cows do 

 not during the whole of the time that they are on the Islands and when 



