ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 121 



I tliiuk, Mr. President, it ^yould save you a little trouble if I asked 

 you to be kiud euougli to take the cliart of the rookeries. Would you 

 kindly take before you — I will have to refer to it a little later on — Chart 

 2 of the Pribilof Islands, in the United States Gavse. If you will turn 

 it with the north from you, the way the map is written, you will see 

 Keef Eookery, Lukaniion Kookery, Polaviua Rookery. 



Lord Hannen. — Which island f 



Sir Richard Webster. — 1 am on St. Paul's Island entirely, the 

 larger of the two. You will hud Zapadnie Rookery, Tolstoi Rookery, 

 Reef, Lukannon and Polaviua. I shall have to refer to that map 

 later on. 



They were of course in greatest nutabers in front of and near Lukannon, Ketavie and 

 Eeef iiookeries, but they extended in an unbroken line from Lukannon to the laud- 

 ing place at the village. — 



That, my Lord, is all the way around that point, Grarbatch Rookery, 

 right around to the village. The landing place of the village is where 

 Village Cove is written. The landing referred to by Mr. Macoun is at 

 Villase Cove — 



^w 



in places mixed with holischickie, but very frequently there were no older seals near 

 tliem. At Black Bluif and between Zoltol Saudsand the Village landing place, large 

 bands of pups swam about from place to place or hauled out on the rocks and sand. 

 It does not seem possible or probable that the mother seals should tind their own 

 young ones among so many and at such a distance from the breeding ground; and 

 during the whole time I was on the Pribilof Islands I never saw a female seal suckle 

 a young one except on a rookery. 



We have got this from the observation of Mr. Macoun, and we have 

 got it from the statement made by Mr. Elliott long before, that from 

 Northeast Point down to Zapadnie — You will see, Mr. President, that 

 Northeast Point is up at the extreme end of the island ; Zapadnie is the 

 westernmost of the rookeries, my Lord, a little to the left of the village; 

 and Mr. Elliott describes the pups that have just learned to swim as 

 having hauled out and swarmed along the whole length of St. Paul's 

 coast from Northeast Point down and around to Zapadnie. 



It seems to me — I must not put it higher than that — as not an unrea- 

 sonable suggestion to make, that the pups being born some where 

 between — speaking roughly — the 20th of June and the first week in 

 July. By the beginning of August they are found spread all the way 

 along the coasts of that island. It does not seem to me an unreasonable 

 inference to draw that after that time they are independent of their 

 mothers; and I ask the court to observe that when the evidence shows 

 us that no female seal has ever been seen, according to the evidence, 

 giving suck to a pup except upon a rookery, it is a very strong corrobo- 

 ration of the point which I am pressing ujion the Tribunal, that after 

 the pups scatter, are podded out and spread along the islands, they are 

 either wholly, or comparatively speaking independent of their mothers. 

 Would the President kindly follow on to page 141, the next passage: 



From the time the pups first go into the water, they are to be seen with pieces of 

 sea-weed in their mouths, and there is no reason for doubt that from this time until 

 they leave the island, at least a considerable ])ortion of their food is composed of sea- 

 weed picked up along the shore or in the waters adjacent to it. Mr. Elliott says 

 that he knows fur-seals feed to a limited extent upon crustaceans and squid, and also 

 eat tender algoid sprouts. Perhaps the seals live upon crustaceans and squid for the 

 first five or six mouths they are at sea. Squid, as has been shown in another part of 

 this Report, are plentiful near the seal islands. 



Now, Mr. President, the proposition which I am contending for is 

 this: that after the first four or five weeks, to put it most against 

 myself, the seals are in such a condition that they are practically inde 



