ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P 115 



chickie", or bachelor seals, tboiigli out of the water from periods of from 

 4 to 6 weeks, or even longer, practically speaking do not feed at all. I 

 am prepared to establish both those propositions from the United States 

 evidence alone ; but I want to consider whether, on general considera- 

 tions, it is not highly probable that that which the evidence supports 

 will be the fact. ISTobody suggests the individual male seal knows that 

 it is going to be killed at a certain age, or it would try to enjoy life as 

 much as it could during the time that it was going to be allowed to live. 



I^obody suggests, for instance, that "holluschickie" at 3 years old 

 know they are going to be knocked on the head at 4 years old; or that 

 "holluschickie" at 4 years old know they are going to be knocked on 

 the head at 5. We know when they come into a proper condition to be 

 bulls 6, 7, or 8 years old, or possibly a little younger, they do fast for 

 these extraordinary periods of from 2 to 3 months. I should have 

 thought that if a seal is going in the year 1890 to fast for 2 months and 

 performing the functions you know of during that period, it is very 

 improbable that it will have eaten for every week of its life, or every day 

 of its life in the previous years of its existence. You would expect 

 from natural laws that if a seal has to go through that state of things 

 and that ordeal, the natural course of its training would be that in 

 these earlier years it will be in a condition to go without food, at any 

 rate after it has grown up, during that time until it is out upon the 

 Island, speaking of the substantial part of the time. 



Now, we come to the females; and we start, as I shall show you pres- 

 ently, with this statement (I am aware that I must not treat it as an 

 admission after what was stated), that for a considerable time, and I 

 think the lowest at which it can be fairly put upon the evidence is a 

 period of from 3 to 4 weeks, the female, after giving birth to the young, 

 does not go out to feed at all. Now, I i^ropose to pursue exactly the 

 same course, Mr. President, and to call your attention to such paragraphs 

 of the British Commissioners' Report upon this matter as have not 

 already yet been called to your attention. 



Now on page 54 at paragraphs 303 to 308, read by me yesterday when 

 the Attorney General was arguing on this matter, you will find the con- 

 clusion of the British Commissioners with regard to the feeding of the 

 female seal, which conclusion is, according to the judgment of the Brit- 

 ish Commissioners, that until the time when the pup-seals are beginning 

 to take care of themselves the female seal, though it goes into the water, 

 does not go out to feed. It is based upon facts — when I say " facts", 

 upon information, the value of which the Court was able to appreciate 

 when I read it yesterday, and I do not propose to read it again. Now 

 let us see what further evidence there is upon that particular matter. 

 Now I call attention, at once, to a statement made in an Affidavit of 

 Mr. Stanley-Brown, and as this is the first occasion upon which I have 

 had to refer to the evidence of Mr. Stanley -Brown, I wish to say a word 

 or two which will be taken to apply to all the observations on his evi- 

 dence and to him, which I make. It is no part of my duty, and much 

 less of my intention, to attack the evidence of Mr. Stanley-Brown (»n any 

 particular point in so far as it depends upon matters which he saw or 

 observed himself. I believe him to be a gentleman who certainly would 

 not intentionally make any statement he did not believe to be true; but 

 in critcising Mr. Stanley-Brown's opinion the Court must remember this 

 fact: That until the year 1891, when he went to the islands, he had 

 never studied seal life at all, and never had been any where near the 

 Pribilof Islands or taken any part in the investigation. I mention that 

 and I shall have to point my observation again when I come to remind 



