ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 119 



Lord Hannen. — The difficulty I feel about this is that there is a 

 great drain on the males; that nature has siii)plied means of providing 

 for that drain : there is a great drain on the females during the time of 

 nursing, but there is no evidence that nature has supplied them with 

 any additional reserve of fat. 



Sir Richard Webster. — I do not think it is quite "no evidence'' 

 my Lord. 1 am not sure whether there is any evidence of the emacia- 

 tion of the females after the period of nursing. I am very much 

 obliged to the Court for indicating any point upon which they think my 

 statement requires further support. I call attention to the fact — it 

 must be only a question of degree — that there must be that drain, ex 

 concessis for a considerable time — I say from 14 to 17 days or three 

 weeks. The whole significance of this, my Lord, is, during what period 

 the pup is dependent on the mother. It is not a question of whether 

 or not the female feeds — the question is, whether a female that is killed 

 is one ui)on whom the life of a pup depends; because there is nothing 

 morally wrong from the point of view. 



Lord Hannen. — We are merely on the natural history point. 



Sir EiCHARD Webster. — Quite so, there is nothing wrong from the 

 point of view of the killing of a female. All I meant is, the LTnited 

 States argument proceeds on three assumptions, everyone of which I 

 shall submit later on, are unjustifiable. First: that every female seal 

 killed at sea has got a pup on the ritokery ; secondly : that every female 

 seal killed at sea has already been impregnated so that she is going to 

 produce another seal; and next they boldly state that the pelagic sealer 

 who kills a female seal kills three seals at the same time. I will not of 

 course refer to the passages in Mr. Coudert's speech on that. They 

 appeared to me at the time as being extremely exaggerated. My sole 

 object in examining this is not for the purpose of saying that female 

 seals never feed for any given time, which 1 can fix, after the birth of 

 the pup, but I submit to the Court that upon the evidence they are not 

 shewn to go out to feed until a time when there is reasonable ground 

 for supposing that the pup is to a great extent independent of the abso- 

 lute necessity of the sui)x>ly from its own particular mother or from any 

 mother at all. 



Mr. President, it is no part of my case — not the least necessary to 

 my case — to suggest that these fenmles must fast for two months, or 

 anything of the kind. I have understated the period with regard to 

 the males, for it appears to be nearer three months; but however, it is 

 no part of my case to suggest that these females are to be subjected 

 and must be subjected to that draft u])on their strength. My w^hole 

 jioint is to endeavour that the court may have fairly before them the con- 

 siderations which bear upon what I may call the necessity for regula- 

 tions in connection with the preservation of seal life; and I submit that 

 so far as the evidence, apart from mere surmise and apart from mere 

 assumption, is before the Tribunal, it would seem that the period when 

 the pup is absolutely dependent upon the mother is, roughly speaking, 

 from three to four weeks at the outside, and that after that time, 

 whether the mother goes to sea to feed or not is, comparatively speak- 

 ing, immaterial. 



My Lord, with regard to the spreading of the seals out upon the 

 shores upon the islands, I desire to call attention to an extract from 

 Mr. Elliott's Eeport for 1881.- Now, Mr. President, having read this 

 extract, I propose temporarily to make a digression, once and for all, 

 with reference to the way in which I am going to use Mr. Elliott's 

 Eeports and the evidence that I think ought to be before you in con- 



