ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 207 



then a residence of seven successive seasons on tlie island, in cliarfije of these animals, 

 has furnished me -nith the desired opjiortnuity for determining this snrjdns product 

 by actual study of their habits and requirements, and the result is, the killuif/ of lOOfiOO 

 j)er annum doeti not leave a sufficient number of males ti mature for tlie icanlsof the increase 

 in the nuniher of females. And as it is desirable to stare some of the niethods by 

 which these conclusions have been reached by mo, a brief statement of the habits 

 of these animals and the effect of the killing of 100,000 per year for the past five 

 years seems necessary. 



These, hanling-groinids are swept and driven two or three times a week during the 

 months of June and July, and the prime seals culled out for killing, and every seal 

 growing up has to run this gauntlet for his life his second, third, and fourth year 

 before he escapes to grow up as a breeding bull. Thus it will be seen the method of 

 killing does not admit of the setting apart of a special number and taking the 

 remainder for the quota for market, and the only possible way to preserve the requi- 

 site number for breeding purposes is to restrict the number to be killed so far within 

 the product as to ensure enough escaping for this object. 



I will sliow you, Mr. President, if I may make the observation here, 

 that after about the year 18S5 or 1888 the difficulty was so great in 

 getting- large skins — not small pups, but large skins, — that they killed 

 in the drives every seal that was big enough to kill. There was no let- 

 ting go of the five or six year olds in order that they might become 

 breeding bulls. They were all killed. 



When the lease was put in practical operation in 1871 there was a very large excess 

 of breeding males on hand ; since then the surplus has been diminished by the dying 

 out of the old seals faster than there has been younger seals allowed to escape and 

 grow up to till their places, until the present stock is insulJticieut to meet the neces- 

 sities of the increasing numlier of breeding females. 



Then occurs a passage on page 248, lower down, to which I direct the 

 attention of the court. I do not ])ause to read it, as it is under their 

 eye; but it supports the opinion Mr. Bryant then gave. 



In the year 1876 Mr. Bryant was examined by a Committee of Con- 

 gress, and his answer is given on page 248. 



Q. Your opinion then is that the number of 100,000 on the two islands authorized 

 hy law can be regularly taken without diminishing the crop or number of seals com- 

 ing to the islands? A. I do not feel quite sure of that, as will be seen in my detailed 

 report to the Secretary of the Treasury included in the evidence which has been 

 laid before the Committee. There were indications of diminution in the number of 

 male seals. 



-Then he refers to what happened in 1868. 



Mr. Foster. — That is the reason. 



Sir Etc HARD Webster.— Tlie United States say that we have not 

 referred to the whole of the evidence of Mr. Bryant. As a matter of 

 fact, there is nothing left out from Mr. Bryant's evidence before that 

 commission that tells in any way against us. On the contrary if the 

 report to the House of Representatives of the 44:th Cong., numbered 

 623, page 99, be referred to, it will be found that the further evidence 

 that he gives is in our favor, with regard to the matter that they had 

 been killing seals, that they were not allowing a sufficient number of 

 big seals to be left to become bulls. 



At page 249 of the Counter Case, Mr. Taylor, Assistant Treasury 

 Agent in 1881, is quoted. The reference is given, and my friends can 

 follow it. I need not give it. He says: 



I believe the capacity of the bull seal is limited the same as any other animal; and 

 I have very frequently counted from 80 to 35, and even at one time 42 cows to one 

 bull. I think if there were more bulls there would be less cows to one bull, and in 

 that way the increase would be greater than now. 



Then Mr. Mclntyre, in 1882: 



I was therefore always alert to see that the due proportion of breeding males of 

 serviceable age^was allowed to return to the rookeries. This was a comparatively 

 easy task prior' to 1882 but became from year to year more difficult as the seals 

 decreased; 



