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



Sir Richard Webster.— One tenth of 800,000. Mr. Carter did not 

 do me the kindness to follow me. I have pointed ont that on his own 

 calculation there are 800,000 breeding females. They are sn])i)osed to 

 continue from ten to fourteen years, bearing pups. Therefore from one- 

 tenth to one-fourteenth of that number must pass into the barren class 

 every year. If Mr. Carter will consider this in the silence of his own 

 chamber, he will find I have not made a mistake; and, if I liad, he 

 would be the first to point it ont when lie comes to consider tlie matter. 



Mr. Carter. — I would like to understand the matter, but I confess 

 I do not understand how they can go into tlie barren class by death. 



Lord Hannen. — They do not bear any longer. 



Sir Richard Webster. — They do not bear any longer. They cease 

 to breed because they no longer have the sexual instinct, and do not 

 happen to bring forth the pup and eventually they die. Those tliat 

 have passed breeding are what I call tbe barren females; but really, 

 while admitting that Mr. Carter is my master, and that he can criticise 

 the way in which I am putting my arguments. 



Mr. Carter.— Kot at all. 



Sir Richard Webster. — I trust he will try to follow the substance. 

 The substance is that of the 800,000 breeding females every year, from 

 one-tenth to one-twelfth cease to be breeding females; and 1 do not 

 repeat myself, because the proposition seems to me, so stated, for the 

 reasons I have given, one which does deserve to be considered. 



But now, Mr. President, I want to say one word with regard to a part 

 of the case which in my mind, in one aspect, presents, or would pre- 

 sent, more difficulties in the way of the Government of Great Britain, 

 and which I frankly admit at once that if the Tribunal are in a posi- 

 tion to deal with the whole question of injury to the seal race ought 

 to be dealt with. I mean the question of the killing of gravid females 

 as apart from the killing of nursing mothers. Here I come to the part 

 of the case which takes me outside Behring Sea and I endorse tlie argu- 

 ments presented by my learned leader which I was touching upon on 

 Monday afternoon when the Tribunal indicated that I was only going 

 to a certain extent over ground with which they were familiar. 



I must say what I am about to say under reserve because I distinctly 

 contend that the area of Regulations is the same as the area of the 

 right but apart from that nobody who has looked into this case fairly 

 and desires to consider Regulations as apart from prohibition can have 

 any doubt I think what ought to be done. When attack has been so 

 unfairly made upon the British Commissioners let me remind the Tri- 

 bunal of this one incident in connection with their Report, that they 

 point out themselves the deletericms nature and harmful character of 

 pelagic sealing during the spring months when the gravid females are 

 passing up the coast, and be it right or be it wrong, be it sufficient or 

 be it insuificient they themselves acting with perfect impartiality sug- 

 gest a remedy which they submit to the judgment of those who have 

 to decide on this question whether to this Tribunal or any other 

 Tribunal. 



The evidence shows, and I am not going in any way to minimize it 

 or cut it down, in so far as it may tell against me, unquestionably that 

 a considerable number of gravid females are killed during the coast- 

 catch taking it from our own point of view, I do not think it could be 

 jmt lower than 30 to 40 per cent, and I think my learned friends might 

 fairly say as a criticism that if in the coast-catch there were as many 

 females as males, and that most of those females other than the virgin 

 females that might be passing up would be in the gravid condition. I 



