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



Sir Richard Webster. — If you, Mr. Foster, say they are errors in 

 copying that removes, of course my observation. 



Mr. Foster. — The date shows it. 



Sir Richard Webster. — It may not; but I have the information 

 somewhere. However, I will not rely any further upon the statement 

 after what you have stated. It is not a matter of any great importance. 



But now, Mr. President, I cometo theevidence of si>e(*ific experiments 

 or examinations made by the United States in order to support this 

 matter: and I want to call particular attention, and I ask for the atten- 

 tion of the Tribunal, to two affidavits, or two tables, one of Mr. Alex- 

 ander and the other of Capt. Hooper. Mr. Alexander's table will be 

 found at page 242 of the United States Counter Case. It is the United 

 States evidence in the year 1892. Now, let us just see, Mr. President, 

 whether or not this supports the theory that the seals go out for the pur- 

 poses of food. You will notice, sir, that there were killed between the 

 6th and 26th of August seven seals. I am very sorry, Mr. President; 

 I ought to have remembered what the actual distances from the islands 

 are. 



I will supply them to-morrow morning and have them written on the 

 table for you. I have got them somewhere upon my note, and I thought 

 I had them in my head, but unfortunately I have not remembered 

 them. Of course I could give the latitude and longitude, but I would 

 rather give the actual distance. One distance is stated as 110 miles, 

 but I will give you the others to-morrow morning. Of those seals six 

 were females and one was a male. What was the condition of their 

 stomachs'? "empty", "empty", "fishbones", "empty", "empty", 

 "fish-bones", "fish bones and a small cod". Now I ask whether that 

 is the slightest corroboration upon which any Tribunal would come to 

 the conclusion that these seals were to be regarded as going out for 

 food. It is extremely probable at those later dates, certainly on the 

 23rd of August, when " fish-bones and a small cod" were found in the 

 stomach of the female, at 110 miles that there was nothing to show or 

 even to suggest that they were in search of food. If you will kindly 

 look at the fourth column from the end, the only nursing females are 

 those of the 6th of August, the 21st of August and the 23rd of August. 

 Now what possible reason is there for connug to the conclusion that a 

 seal found with milk in its breast on the 23rd of August, 110 miles 

 from St. Paul's Island, has got a pup dependent upon her upon the 

 island and that therefore the killing of that seal is to be considered as 

 something which ought to be restrained by law. I ask the opinion of 

 every member of this Tribunal who has ever had to deal with this 

 question from a practical point of view. Of the two so called nursing 

 females on the 6th of August and on the 21st of August, their stom- 

 achs were empty. But of the three nursing females the position is 

 that two have nothing in them, the third has fish bones and a small 

 cod, on the 23rd of August, 110 miles away. And what is meant by 

 nursing females for this i^urpose? The only way they can judge is 

 that the milk is not dried up. There was no observation as to whether 

 that milk was in the course of drying up or was not. 



Now I call attention to Captain Hooper's table at page 217, and I 

 want first to call attention, with all respect, to the absurdity of the 

 argument that is based upon this table of Captain Hooper. I say 

 "absurdity" with all respect, because one is accustomed to taking out 

 averages and knows how averages should be taken. It is not a case 

 of a man sealing and killing as many as he could, but it is the case of 

 a man who killed a certain number of seals to get certain information. 



