ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 117 



]Now I desire to call attention to a g'entleman who is eqnally entitled 

 to be treated in the same way, and will, I have no doubt, be treated by 

 my friend Mr. Phelps with the same fairness as 1 have treated Mr. 

 Stanley Brown — I mean Mr. Macoun, who also had tlie opportunity, for 

 a very'lengthened time, of observing this matter, and who was also on 

 these islands during the same two years that Mr. Stanley Brown him- 

 self was. But I must again be allowed to say that I do not put for- 

 ward Mr. Macoun as a witness whose opinions are to be taken as of 

 great value based upon previous experience, because he, in the year 

 1891, went I believe, for the first time, to the Pribilof Islands, and had 

 not been in the position of having previous experience. 



Now at page 142 of the 1st volume of the Appendix to the British 

 Counter Case, I call attention to a paragraph that has not yet been 

 read in Mr. Macoun's report. He says : 



Within a few hours after a pnp is born it receives its first notirishment from the 

 mother; and for some days, while the mother remains about the harem and the pup 

 is too young to wander far from it, there can be little or no doubt that each mother 

 seal suckles her own young one alone. 



It was not until the 1st of July that I first noted pups forming "pods" or small 

 separate herds. 



The time of arrival, if I remember rightly, of the mother-seals for 

 the x)urpose of giving birth to the young is about the 10th or 12th June, 

 so that this would make the pups somewhere about 19 to 21 days old. 



It was not until the 1st July that I first noted pups forming '^pods", or small 

 separate herds; every harem was still well defined, but the pups belonging to each 

 had begun to show greater activity, and the older ones had to some extent formed 

 little "pods" a few yards distant from the mother seals. By the 5th July it was 

 noticeable that the pups from adjoining harems had "podded" together l)etween 

 them, while the harems themselves wore still, with few exceptions, compact and 

 well defined. 



The cows had not yet begun to go to the water. The few wet ones seen upon the 

 rookeries were without exception females that were still carrying their young. The 

 seals on a great many small harems were counted, and it was always found at this 

 time that the pups and cows were in about equal numbers. Within the next week, 

 however, the cows began to go into the water, but not in great numbers. They 

 seemed content to swim about near the shore, and were often seen hauled-out on 

 some flat rock after they had been but a few minutes in the water, and, after scratch- 

 ing tliemselves for a little while, would plunge again into the sea, swim to shore, 

 and go back to the harem to which they Ijelouged. 



Now you will remember, Mr. President, that the observation of Mr. 

 Stanley Brown was that he saw, as he believed, the female seal to be 

 still travelling when he last saw her. Mr. Macoun, also observing for a 

 very considerable length of time, and having many days to devote to 

 this, describes that which is in accordance with the evidence of previ- 

 ous persons of experience in this matter who had written on the sub- 

 ject, and have called attention to the fact that the mother goes into the 

 water, remains in the proximity of the islands, plays about the islands, 

 and comes out again. Then follows a long passage read by Mr. Coudert 

 (I do not intend to read it again — I want to spare the Court as much 

 as I can), with reference to the question of whether a mother suckles 

 her own pup or not. Sir, I am not going to trouble the Tribunal with 

 a lengthened discussion on that point. From natural instinct it would 

 seem to me — I must not do more than submit it to the Tribunal — that 

 in all probability the mother does as a rule, suckle her own pup; but it 

 is by no means uncommon both in domestic, and in wild animals, to find 

 that mothers do allow other of their species to suck, and of course we 

 know it is a means in the case of sheep, and the case of other animals, 

 whereby the young are kept alive before they are able to feed. But in 

 my judgment the poiut becomes, comparatively speaking immaterial, for 

 this reason — that there is abundant evidence that after about three or 



