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



Mr. GkAjVI. — In my country we liave the experience that cod come 

 every year to tlie .same places for breeding. 



Sir Richard Webster. — Yes. I believe the experience upon both 

 coasts of America, where the cod fishing is very great; I bdieve the 

 experience on the east coast of England and on the coast of Europe, is 

 that codfish do come back to the same place year after year; but for 

 my point, Mr. President, it is not very important, because there is abun- 

 dant evidence that the cod are found, practically speaking, in all parts 

 of Bell ring Sea. 



The President. — And during the season when the seal is on the 

 islands? 



Sir EiCHARD Webster. — During the season when the seal is on the 

 islands. I would call attention, Mr. President, as you have been good 

 enough to put that question to me, to Captain Coulson's report, at page 

 235 of the Counter Case: 



At every station where the vessel was stopped, codfish were taken. In some locali- 

 ties they were abundant; at others only a few were caught. 



I merely mention that for the purpose of showing that it is not, as 

 far as we can gather from the evidence, a case of there being quantities 

 of codfish distances away from the island, but as far as I can judge 

 from the evidence and the evidence only, these cod appear in very 

 considerable numbers, practically speaking, all around the islands. 



But it may be said, "That is perfectly true; but you cannot deny 

 that female seals, which we call nursing females, are found and killed 

 at great distances from the island." Mr. President, it is no part of my 

 case to deny it, and I never have, in any observation that I have made, 

 intentionally denied that at times, at distances from the islands greater 

 than the distance I have mentioned of twenty or thirty miles, seals with 

 milk in their breasts have been killed. But I ask the Tribunal in con- 

 sidering this matter to be good enough to look at the whole question 

 and not to look at the question from the narrow point of view, closing 

 their eyes to all we know about natural history, which is the attitude 

 that has been assumed by my friends upon the other side. I do not in 

 any way want to exaggerate or put their case unfairly against them. 

 But I must remind you that Mr. Coudert actually argued in this court, 

 solemnly, before you, that inasmuch as the pups were found with milk 

 in them in the month of November, that therefore it must be assumed 

 that the pups were dependent upon their mother right up to the month 

 of November. Well, of course it is an absurdity Mr. President. 



That pups may occasionally suck as late as this, is extremely proba- 

 ble; but we have got to consider Avhat is going to happen. These 

 animals are going in the next day or so right across the sea, hundreds 

 and thousands of miles, to find their own living; and nobody suggests 

 that they go on sucking, the mother then. It would be contrary to 

 all the experience of every other animal known, to imagine that it is 

 dependent upon its mother up to within four or five days of the month 

 of November and then suddenly becomes independent. What is the 

 ordinary rule you expect to apply? Be it long or be it short, weaning 

 takes place gradually, either at a longer or a shorter period; and wean- 

 ing takes place, at times, by the pup poddiug and wandering away from 

 the rookery, being able to support itself, not being dependent upon the 

 mother, so that the mother does not have to find it out and feed it. But 

 there is another most important incident in connection with this matter 

 which the United States advocates are obliged wholly to overlook. They 

 entirely forget that it is common knowledge now ever since we have 



