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



Now I ask the Court to take the map N" 6 of the Counter Case which 

 is the corresponding- map of 1892 which my learned friend the Attorney 

 General referred to yesterday. 



That is important, because a good deal more information is given in 

 connexion with the year 1802 than is given in connexion with 1891, 

 which information I desire to put before the Court in a compendious 

 shape. In 1891, no doubt, not seeing the importance of the matter so 

 much, they either did not keep the logs or tliey have not given us the 

 logs. I merely mean that we have not the same amount of information 

 for 1891 that we have for 1892. In 1892 they have given us the logs, I 

 think, of all the six or seven cruisers that were engaged. 



Now the state of things is this, and it bears, I shall respectfully sub- 

 mit, upon the very important corroboration, of the British Commis- 

 sioners' view. Six cruisers were engaged for 148 days; that is to say 

 combined, the total days occupied in examination was 148, ranging 

 between the 20th July and the 31st August, some more and some less, 

 amounting altogether to an average of something like 35 or 36 days 

 observations each. All the logs are given, and one, the "Corwin" 

 gives the number of seals they observed in all cases. The "Corwin" in 

 one or two instances — a few outside and a greater number inside the 20 

 mile radius, says that in certain instances the seals were too numerous 

 to be counted. 



It is not quite possible to give an exhaustive statement with regard 

 to this, but this is what the map shows and what the logs show. In the 

 first place, will the Tribunal kindh'^ observe again the 20 mile radius or 

 zone, which is a little more accurately drawn upon this map than upon 

 the other but sufiBciently for our purpose corresponding with that of 

 1891 and the words are written '' Seals within this area very numerous ". 

 Then occur,' Mr. President, the pictorial representations of the other 

 observations extending, as you will notice over a considerable area of 

 sea, and I i^erhaps cannot point my observation more than by telling 

 you that the map has been correctly made from the logs. 



On the 20th July, almost due south-east of the Pribilof Islands, you 

 will find 102 seals in a large cluster, and there are 102 in that bunch 

 when it is counted it is correctly put down, and they cover an area, as 

 nearly as possible, as well as you can clieck it of 400 square miles. If 

 it is a picture of what was seen the 102 seals would, in fact, cover a 

 space which would be perhaps three or four acres at the very outside 

 they would not cover it, but be in it. The map shows as though they 

 covered a large area. That is perfectly fair, but I want to remove any 

 false impression. This map and the log show this, that daring all this 

 time with a number of cruisers in and out, as was shown yesterday — 

 and I need not bring it to your attention again — the total observa- 

 tions outside the 20 mile radius were 1062 seals; the total observations 

 counted inside and outside were 1859, and then within the 20 mile 

 radius there is "thickly populated, very numerous ". Thej^ very nat- 

 urally and very properly not only did not attempt to count, but could 

 not because they were so very numerous. The area is nearly as large 

 as the map of 1891 covers, and even of the observed and counted seals 

 40 per cent are found within the 20 mile radius; but when you remem- 

 ber this area is spreading out and by geometrical i)rogression getting 

 larger and larger. 



The President. — The seals within the 20 miles radius are not taken 

 from the map, but from observation. 



Sir Richard Weester, — The dilference between 1062 and 1859 or 

 about 600 seals is taken from the logs, that is to say, in addition to the 



