ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 185 



state this, as much as 1 can against myself, whether it is 30 or 35 or 25 

 per cent, onght not to make any difference in tlie inind of the Tribunal, 



I have recognized in ray argument that the theory of useful game- 

 laws is that such a wasteful method of killing would not be permitted, 

 and speaking to civilized men — men of the highest civilization and 

 cultivation of all nations, I shiink from ])utting any argument that 

 might not be thought to commend itself to their minds, and for the 

 purpose of my argument, though I think I could satisfy this Tribunal, 

 if it was at all important for me to follow it up, that in the evidence of 

 many of the witnesses who have spoken for the United States, there is 

 very great exaggeration, that the number of females gravid and supposed 

 to be gravid is a great deal exaggerated, yet I cannot shut my eyes to 

 the tact that taking the British evidence as it stands there is quite 

 sufticient proof of the killing of gravid females during those earlier 

 months to justify some regulation in that regard in order to prevent 

 even that percentage. 



Now what does that mean? It means this; that you ought to avoid 

 the pelagic sealer being tempted to attack the herd at a time when it 

 is composed principally, or largely, or to any great extent, of gravid 

 females. We are not without statistics, and not without data enabling 

 us, to a very considerable extent, to assist the Tribunal in coming to a 

 conclusion in that respect. In the first place, the date at which the 

 whole herd arrive at the Pribilof Islands is pretty nearly fixed. I have 

 stated it more than once myself in the course of my argument to-day. 

 It may be taken roughly to be about the 20th of June, it is stated by 

 Mr. Stanley Brown, quoting from memory, to be the beginning of July, 

 when the Kookeries are about all filled up. The United States Com- 

 missioners themselves say they arrive early in June up to the end of 

 the month, and the harems are complete early in July. That will be 

 found at pages 325 and 320. Of course, in a matter of this kind, there 

 would be a difference of opinion; but it is not an unfair representation 

 to take that. 



What do we know further? We know further that, during the latter 

 part of May and the beginning of June, the animals "bunch up", as it 

 is called, and travel rapidly from the Unimak Pass to the Pribilof 

 Islands; in other words, in the latter part of May, they are found in 

 Behriug Sea and not outside Behring Sea. 



Mr. Justice Harlan. — Including the females'? 



Sir EiCHAKD Webster. — Yes; I confine my attention to females. 

 It is not, for the purpose of this argument, necessary to consider the 

 killing of males; I consider the question of interfering with that kind 

 of killing which is said on all hands to be a kind of killing to be 

 restrained. 



Bearing that, then, in view, the first date is, within what time, or up 

 to w^hat time should ])e]agic sealing be prohibited altogether? I pass 

 from zone, Mr. President, and deal now entirely with the question of 

 close time. 



Now it was very properly if I may say so put by a member of the 

 Tribunal, whether or not, adliering to the date mentioned by the British 

 Commissioners, the 1st of July, coupled with the zone indicated by Sir 

 Charles liussell, we were not giving away a point which the pelagic 

 sealer or Great Britain on behalf of the pelagic sealer might fairly 

 make. My answer is it seems to me fairly not for this reason — that 

 you cannot always calculate on a particular day. We have the evidence 

 in the past, sometimes the seals are a few days later and sometimes a 

 few days earlier. Sometimes they have begun to arrive in the middle 



