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



!N"ow, I will, in the first place, as fairly as I can, and as clironologically 

 as I can, tell you what tlie evidence shows. First, let me refer to the 

 tignres of the Kussiaii killing. Dnring- the Russian time, which will be 

 found at pages 132 and 133 of the British Commissioners' Keport, sec- 

 tion 771, — you will remember that General Foster interposed the other 

 day to say that they disputed all these figures or some of them, — I 

 really do not thiidc, after the fullest examination that I can make out 

 what on earth is meant by that, because the source of every one of these 

 figures is given, it is taken in the most important iieriod namely from 

 lb38 to 1800, that is to say, a peiiod of 22 jears, from the corres])ond- 

 ence printed at Washington in the year 1890. And all 1 say is this, 

 that no other figures have been suggested. The Tribumil are not to 

 act on surmise or on the observations of an Agent, however distin- 

 guished. The authority for these ligures is given in paragraphs 772 to 

 781. They were referred to by Lord Hannen, 1 think, Avhen the obser- 

 vation was ujade the other day; and I merely mention that, as far as 1 

 know, no other alternative figures have ever been suggested for the 

 Eussian period; and it is the fact that they show, as was mentioned 

 by the Attorney-( General, an average of less than 40,000. I may men- 

 tion that in the documents annexed to the President's JMessage, I read 

 from Executive Document 450 of the 51st Congress, and page 31 will 

 be found, quoting from Mr. Mclntyre the special Agent of the Treasury 

 Department, again giving the reference to another Executive Docu- 

 ment, these figures set out, without any suggestion that they are inac- 

 curate or not trustworthy. Criticise the figures by all means; let any 

 deducti<m be drawn from them that can fairly be drawn, and then say 

 if this is fair or not. 



Lord llANNEN. — Do I understand you to say that that is this very 

 Table? 



Sir Richard Webster. — Yes, my Lord. My learned friend, Mr. 

 Phelps, has it now before him. I do not know how manj^ years it com- 

 prises. Perhaps iny learned friend, Mr. Phelps, will be good enough 

 to give it! 



Mr. Phelps.— The earliest year is 1817, and the latest 18G0. 



Sir Richard Webster. — Yes. I merely mention it from the point 

 of view of authentic documents. It is possible on some such idea as 

 this, that this was not accurate that some of the suggestions have been 

 made about the British Commissioners. The authority is given in 

 every single case. 



Now, what happened afterwards? I wish to treat it chronologically; 

 though perhaps 1 could make my argument a little more gra])hic by not 

 doing so, but I prefer to treat it chronologically; and I ask the Tri- 

 bunal to turn to paragrai)h 809 of the British Commissioners' Report. 

 From paragraph 809 to paragraph 833 are set out extracts from the 

 United States documents, almost without exception ; or, if not without 

 exception, the authority is given. I have, either myself or by those who 

 have assisted me, verified the whole of these documents; and I can say 

 (though it must not be taken from my personal knowledge; therefore, 

 I can only say as far as I know and as far as my information has led 

 me) that these extracts are perfectly accurate. 



Let me take them chronoh)gically, and see if it is true that upon the 

 information before the United States up to 1884 the first time that 

 there was any doubt as to whether the sufficiency of the number of 

 seals or seal herd was being kept up was subsequent to that date. 

 The other extracts are important; and I will ask the Tribunal at some 



