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



Mr. Carter. — If you Avill read it, it Avill be a little more definite. 

 Sir EicHARD Webster. 



The nuniher of pups about the shore of St. Paul began to attract my attention 

 about the middle of July, last ye.ar. On August 2nd I stood on Zoltoi Beach. 



Zoltoi Beach is tlie place that I showed the court when I was calling 

 attention to tliis. — 



And counted dead pups within ten feet of me. and a line of them stretched along 

 the beat'h many of tlieu) starved to death on tlie rookeries, but by far the greater 

 number sunk in the deep water along the margin of the rookeries. 



Mr. Garter. — You did not begin quite high enough. 



Sir EiCHARD Webster. — I began at any point that refers to observ- 

 ing the seals. Where do you wish nie to begin, Mr, Carter? 



Mr. Carter. — If you want to get wluit he imputed as the cause of 

 it, you should begin a sentence or two higher. 



Sir EiCHARD Webster. — I beg my friend's pardon. I was not in 

 any way referring to that. 1 was calling attention to the fact that Mr. 

 Palmer, observing these matters does not suggest that either on Tolstoi 

 nor on the other rookery, Polavina, to which I have called attention, 

 there was any abnormal death, and I am calling attention to it for the 

 pui-pose of showing that every person who was there in the years 1890 

 and up to that time proved by their statements that that state of things 

 which the United States in their rei)ly suggest cannot possibly have 

 existed. 



Now I come, if you please, to the year 1892; and the Tribunal will 

 find that the condition of things rel'eired to in the year 1892, in the 

 first volume of the Api)endix to the British Counter Case. Before I 

 read this, Mr. President, may I remind you of certain admitted facts. 

 It is admitted that the total pelagic sealing in Behring Sea, the whole 

 of Behring Sea, in the year 1892, was under 500. I will first make 

 that good before I read from page 145 of the Counter Case. 



Mr. Carter. — You say it is admitted? 



Sir EiCHARD Webster. — I said admitted. 



Mr. Foster. — If you say the eastern part, we will accept it. 



Sir EiCHARD Webster. — I was not aware that from this point of 

 view it was important. Mr. Foster is perfectly accurate. It is so very 

 far away, Mr. President, that I may be pardoned for liaving spoken of 

 it as Behring Sea. Whnt Mr. Foster desiies me to point out as a limit 

 is a reference to the killing in what they call United States waters. 

 You know what I mean, Sir — to the east of the line of demarcation. 

 Perhaps somebody will show the line of demarcation on that map. 



Mr. Justice Harlan. — We can see that. 



(Mr. Tupper here indicated on the map the line of demarcation.) 



Sir EiCHARD Webster. — At page 93 of the United States Counter 

 Case, it is stated in this way: 



In consequence of the zealous and efficient efforts of the naval vessels charged 

 with the protection of the seal herd and the enforcement of the modus virendi, few 

 sealing vessels entered the eastern half of Behring Sea in 1892, and those waters 

 were practically free from open-sna hunters. If the cause of the mortality of 1891 

 among the pups was any of those advanced by the Report, it is a remarkable and, 

 for the opinion of the Commissioners, an unfortunate circumstance that with the 

 decrease of sealing in Behring Sea dead pup-seals have decreased likewise. 



You will not fail to note the fact that they argue that the alleged 

 decrease of dead pui)S in 1892 shows that the view taken on behalf of 

 Great Britain, that it could not have occurred from pelagic sealing, is 

 refuted. The actual certificate is given on page 156 of the first Volume 



