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



stating — I think it is understating, as I shall show in another connec- 

 tion later on — the hypothesis of the United States Commissioners is 

 that there must be at least three million seals in a normal condition and 

 that of that three million seals the very smallest number of females 

 must be 1,500,00J. In fact upon their own figures the proper propor- 

 tion would be something like 000,000 males to about 2,400,000 females; 

 but I am not adopting, for the purpose of my illustration, views of the 

 proper condition of the seal herd, which on the evidence appear to be 

 not well founded. Therefore I am not straining my point by assuming 

 in my own favor what I may call the extravagant relations of male and 

 female, which the United States Commissioners have thought, and the 

 United States Case submits, to be sufficient and proper for this race. 

 I am taking a normal condition of things and assuming three million 

 of seals to be the total of the herd, an understatement as I should sug- 

 gest, by probably a million at least; but assuming three million it would 

 be 1,500,000 female seals beariug, that is to say having come to the 

 age of three and dying off at the age of 13 or 14 as the case may be. 

 They give for the extreme life something like from 10 to 14 years, and 

 it would be an average of somewhere about 12. That seems to me 

 to be somewhat of an overestimate. 



Lord Hannbn. — Twelve years is an average of what? Pup bearing? 



Sir Richard Webster. — For pup bearing; yes. If I take it to be 

 ten years — it really makes no difference, for the Tribunal can do the 

 figures themselves — I assume for the purpose of simplicity of calcula- 

 tion that 1,500,000 is the total number of female bearing seals neces- 

 sary for the herd which means that 150,000 seals pass into the barren 

 stage or die every single year. 



Mr. Carter. — You do not mean that is their assumption. You seem 

 to impute it as being such. 



Sir KiCHARD Webster. — It is really their assumption. 



Mr. Carter. — I think not. 



Sir Richard Webster. — I have not put it upon you. I will demon- 

 strate it to-morrow from the United States figures. I think the United 

 States Commissioners say in terms that the herd must be about three 

 millions, of which 1,500,000 would be bearing females. 



Mr. Carter. — Not bearing females. You are quite in the wrong 

 about that. 



Sir Richard Webster. — Indeed I am not; but I shall endeavor to 

 point it out to-morrow that I am correct. The assumption which it will 

 be found the United States Commissioners proceed upon is that the 

 total herd consists of bearing females about 1,500,000. I am much 

 obliged to you, Mr. Carter. I see now what you had in your mind. I 

 have not stated it quite correctly. I stated it from memory. I refer to 

 page 357, of the United States Case. I know now why I made the 

 mistake: 



In ordei" to represent more clearly the enormons herd of seals which it may be 

 supposed at one time frequented the Pribilof Islands, nmiistiirbed by man, these 

 numbers may be multiplied so as to give a total of 3,000,000 seals, 750,000 being born 

 every year and the same number dying from natural causes. Of the 1,500,000 

 females about 800,000 would be breeding, the remainder mostly too young to breed, 

 a very small number being barren. 



I am very much obliged to Mr. Carter for correcting me. I was quite 

 in error; but I had no intention of misrepresenting. The thing I had 

 in mind was the number it would be if that 3,000,000 was increased to 

 the proper amount; and I mistook the figures. I will take the figures as 

 stated: 800,000 lor breeding females, and the average life for breeding, 



