ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 1 07 



the congested lierd of female seals, or tlie congested body of femnle 

 seals, is passing through the Uniinak and other passes up to the Pribilof 

 Islands they should be, practically speaking, free from attack. 



Now, having reminded you, Mr. President, of what the view of the 

 Commissioners was, put down impartially and fairly, not as an admis- 

 sion forced from unwilling witnesses, let me in a very few sentences 

 remind you of how the United States evidence stands. I must go over 

 somewhat the same ground as was referred to yesterday in order to 

 supplement it a little. Will you take map 4 of the United States Case. 

 That is the sealing chart of the year 1891. How do the United States 

 advisers describe tlie condition of sealing area in the year 1801? You 

 will find that they have drawn again two imaginary circles round the 

 Pribilof Islands at a distance of 20 miles from the nearest land. The 

 Attorney General was not quite accurate in saying it wouUl be more 

 than 20 miles in some places. That is not the condition. It would be 

 always 20 miles from the nearest land, and therefore more from other 

 pieces of land.. It is a zone enclosing the distance between St. George 

 and St. Paul, you will see, because, being 36 miles apart, those two 

 circles would overlap. How do they describe that? "Seals within 

 this area very numerous ". That is the statement made in the United 

 State's Case for the purpose of showing what was the condition of 

 things in 1891. 



Now I will tell the Tribunal what this map shows. It has been used 

 in the United States Argument and in the evidence of the United 

 States witnesses as though outside that 20 miles it showed the sea very 

 thick with seals. On the contrary, it shows the reverse. 



The total observations of six cruisers from the 15th July till the 15th 

 September (that is to say, at various times between that), put down 

 the total number, I have no doubt quite fairly, giving the dates and 

 numbers, is 615 seals. 



The total area over which those seals are spread is 100,000 square 

 miles. Now do not let me be misunderstood. It is quite possible that 

 on other days, or on 'tfie same day in other parts of these 100,000 square 

 miles there would be seals, comparatively speaking, sparse or frequent, 

 as you choose to call it, to the same extent. But it points to this, that 

 the observation, assuming it, as I do, to have been fairly taken, shows 

 that outside the radius of 20 miles from these Islands the seals are, 

 comimratively speaking, sparse, and further than that, that they 

 are existing in the condition, so far as thickness is concerned, where 

 you would expect to find them, if they were, as the evidence leads you 

 to believe, not in the course of actually migrating or going to or coming 

 from the Islands themselves. In other words, as it is described by 

 those who have made these affidavits, and compiled the evidence and 

 described them as being seen in one direction sometimes and sometimes 

 in another, and sometimes sleeping and sometimes not, and evidence in 

 the condition in which seals would be, treating this part of the sea as 

 that part of the universe they were inhabiting, if that is a proper 

 expression to use with regartl to seals in such a condition. I only 

 pause, before I leave this map again to remind you of how misleading 

 the api)earance to the eye would be when you remember the extraordi- 

 nary small scale on which this map is. I do not make the slightest 

 complaint, and I shall not be mistaken, but it is a fact that each one of 

 these seals covers from a mile and a half to two miles space on the 

 water and therefore does not represent what would be the physical 

 appearance of the seals in the sea itself. 



