ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 167 



with the real cause of decrease of seal life in these islands, X slinll snji- 

 gest to you — I merely mention it now by way of anticipation — tliat it 

 is by no means impossible that the depreciation in the male life may 

 have had something to do with it; but I am not bound to take, nor do 

 I take, any burden of responsibility of afflrmative proof in regard to 

 this matter. It ought not to be put upon me. You will remember, 

 Sir, I read to you the paragraph of the United States Case, but a few 

 moments ago, in which they state that the depreciation of the death 

 of the pups in the year 1802 shows that the death of the pups in the 

 year 1891 was due to the pehigic sealing and they cite the fact of the 

 alleged less death in 1802 as showing that pelagic sealing was the cause 

 in 1891: 



If tbe cause of the mortality of 1891 among the pups was any of those advanced 

 by the report. 



That is by the C.ommisiouers' Eeport — 



It is a remarkable, and for the opinion of the Commissioners, an unfortunate cir- 

 cumstance, that with the decrease of sealing in Behring Sea, dead pups have 

 decreased likewise. 



I shall show you now presently, as soon as I come to it, from the 

 United States afftdavit, that even up to the beginning of August, the 

 date upon which Mr. Stanley Brown left, that even n\) to the beginning 

 of Auiiust he had noticed that there was an abnormal number of dead 

 pups there, more than there ought to be; and 1 shall show you that 

 Mr. Stanley Brown left and made his last examination at an earlier date 

 in August, whereas the examination with regard to the whole subject 

 had to be continued, and was continued by Mr. Macoun right through 

 up to the 11th of September, as I have shown j'Ou. I tliink it is 

 scarcely necessary to read it. I ought probably to have read to you Mr. 

 Maynard's affidavit, Mr. President, on page 150, to which Mr. Macoun 

 refers : 



1. That during the latter part of the month of July, and for nearly the whole of 

 the month of August, I was employed in taking photographs on the Pribilof Islands. 



2. That on the 23rd day of August, 1892, 1 visited Tolstoi rookery, on St. Paul Island, 

 in company with Lieutenant Ainsworth, AssistantTieasury Agent on St Paul Island, 

 Mr. Macoun, an Agent of the British Government, and An tone Melovedotf, chief boat- 

 man in the employ of the North American Commercial Company. 



3. We walked to the part of Tolstoi Rookery on which dead pups were lying in 

 great numbers, and while we were all standing within a few yards of the limit of 

 the ground on which these dead pups were, Mr. Macoun asked Antone Melovedoff 

 whether he thought there were as many of them as there were last year, to which 

 he replied, "More; more than 1 ever saw before. I was asked by Mr. Macoun to 

 particularly note what was said, and did so." 



I respectfully submit to this Tribunal that in the face of what I have 

 already read — I will show the corroboration when ihe court reassem- 

 bles — the argument put forward in the United States Case is turned 

 against themselves; because if the cause of the death in 1891 was as 

 they themselves say the pelagic sealing in the eastern side of Behring 

 Sea in that year, so, the cause stopping, the result should also cease, 

 I have shown you upon testimony which it cannot be suggested is tes- 

 timony otl.erwise than honest, of what was seen, that according to that 

 testimony, there was that same mortality in those particular places in 

 1S02. And again it passes the wit of man to suggest why it was more 

 abnormal because contined practically to Tolstoi and Zapadnie on St. 

 Panl and should not afl'ect the other rookeries. 



The President. — You think it strange that it did not affect both 

 islands'? 



