ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 135 



known anything about the fur seal that a very considerable — when I 

 say considerable I mean a large number — of these pups are actually 

 killed by killer wliales in the months of August and September on the 

 very shores, when they begin to swim, and that a certain other number 

 of these pups are killed by ordinary accidents of life, due to the stam- 

 pedes upon the rookeries, the conduct of the bulls themselves, and other 

 natural causes. We also have a substantial body of evidence of ])ups 

 not infrequently dying from sun -stroke and from other causes of this 

 kind; and that therefore there must every year be present in the waters 

 of Behring Sea a large number of seals which have got milk in their 

 breasts, milk which is drying off, showing seals that have given up 

 suckling, seals whose pups are weaned or have died, this is certain, 

 without any argument; and I challenge contradiction upon it. 



What does it mean? We have at present no direct evidence of the 

 time it takes for the milk to disappear entirely from the glands. We 

 know they are very large glands.' We know that a very large portion 

 of the body of the seal is covered by the milk producing glands. You 

 will remember, Sir, there is a phofcograijh in one of the books of a seal 

 that was cut open by the United States for the purpose of examination, 

 and we further know that there are four of the mammae or teats, to 

 each of which the milk goes. Some of us have some experience from 

 other animals; but I admit that kind of experience is of no real value 

 for the purpose of what I may call a quatititive estimate. But I do say 

 this: it would be no exaggeration to suggest that milk would be pres- 

 ent, must be secreted, got rid of and ultimately dried up for a period 

 of two or three weeks in the bodies of these animals; and therefore my 

 learned friends are obliged to assume this position, in order partly to 

 introduce what I cannot help thinking is to a certain extent prejudice, 

 and in order to indicate that injury is done to the seals upon the islands 

 that the evidence does not warrant. Every seal that is taken, every 

 female seal that is killed, is a crime. Every female seal that is killed, 

 either she herself and the unborn pup in her — 1 am dealing now with 

 seals that have delivered their young on the Pribilof Islands — is to be 

 regarded as being lost, and therefore that two seals are lost, and if 

 there is a pup upon the island, three. 



Does the evidence warrant it"? With very great deference, Mr. Presi- 

 dent, and only inviting the candid and severe criticism of this Tribunal 

 upon my arguments, I submit the evidence does not warrant it at all; 

 and I submit that when the evidence is examined there is nothing to 

 show that any substantial number of females would be killed in Beh- 

 ring Sea by vessels that are j)elagically sealing at distances outside 

 thirty miles from the islands. Of course, Mr. President, it must not 

 be put upon me that I am advocating pelagic sealing within ten or fif- 

 teen miles of the shore. I have said distinctly tliat I do not advocate 

 it. It must not be put upon me that I am justifying pelagic sealing in 

 Behring Sea during the months of May and June, when the females are 

 gravid. That is another matter which I have disclaimed, and which I 

 am going, of course, to come to later on when I deal with the supposed 

 injury to gravid females. I am dealing now entirely with the injury to 

 nursing females. 



As I have said before, to make, my note complete, I will merely men- 

 tion in connection with this subject to form a starting point, sections 

 303 to 308 of the British Commissioners' Eeport. 1 do not wish to read 

 them now, because I read them yesterday; but I want my argument to 

 be self-contained, and therefore I call attention to them, that the Tri- 

 bunal may have in one passage, so to sj)eak, of my argument, all the 

 references that bear upon this. 



