ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 211 



It is worth while here to repeat the statement of the latter (hat formerly there 

 ■would be on an average 30 cows to 1 bull; now they would not average 15. 



Tills is considered so important, Mr. President, if I am not unduly 

 troubling you will you look at page 344, you will tind tliere they quote 

 Captain Webster and they quote Mr. Eeilpatb. Captain Webster is the 

 only one who is supposed to have said anything with reference to the 

 size of the harems. Mr. Kedpatb only speaks of the total number of 

 females, which has nothing of course to do with the point uj>on which I 

 am arguing, which is to contrast the condition of virile males, and the 

 condition of females per virile males. 



The President. — Where was this declaration made? 



Sir Richard Webster. — I should think on the island to the Com- 

 missioners in the year 1891, when they were there. 



The President. — By word of mouth? 



Sir Richard Webster. — Yes. A statement made to them on a 

 vital point by Mr. Webster. Mr. Webster makes subsequently his affi- 

 davit — the actual date is sometime in June 1892 — and that athdavit does 

 not refer to the size of the harems or in any way repeat the statement 

 that has been made. I do not want it to be thought that I am goingto 

 rely upon negative testimony in this respect, if you will i)ermit me to 

 say so. I am only calling attention to that to show the absence of 

 afihrmative testimony on the part of the United States in regard to the 

 matter. 



But there is one observation, before you adjourn. Sir, which I must 

 make. The Commissioners were there in 1891 themselves. If they 

 thought as they have said, that it was of vital imi^ortance to ascertain 

 this fact, whether harems had diminished in size per virile bull, they 

 would have examined it. Either they did or did not examine it, they 

 have not given us their results. If they did not examine it they have 

 failed, as I contend in my submission to this Tribunal, to consider that 

 question which they themselves by their report put down as being a 

 test question, and which, at any rate, I have shown my willingness to 

 meet upon the evidence. 



The Tribunal here adjourned for a short time. 



Sir Richard Webster. — I had pointed out to the Tribunal that if 

 the United States could have established a decrease in the number of 

 cows per virile male it was vital to their case to do so. Now, how does 

 the evidence stand? I will call the attention of the Tribunal first to 

 paragraphs 292 to 294 of the British Commissioners' Rei)ort. 



292. Though each full-grown male or " seacatch" holding his place on the rookery 

 ground endeavours to obtain and keep about him as many females as possible, there is 

 a limit to the number which may be advantageously held by a single male, and when 

 adult males are found in abundance, it is not easy to pass this normal limit; but, on 

 the other hand, when, in consequence of a paucity of adult males in proportion to 

 females, the harems become too large, the females are irregularly served, served too 

 late in the season, or, in some cases, may altogether obcipe efficient service, with 

 resulting irregularities in times of birth of young in the i.bxt year, or an addition to 

 the number of barren females. 



293. The proper portion of adult males to females cannot be ascertained by inspec- 

 tion of the Pribylof rookeries as they are at present, because of the obvious and gen- 

 erally acknowledged deficiency of virile males; but in the earlier years of the control 

 of these islands by the United States, Bryant estimated the existing proportion as 

 about one male to fifteen females, or, as indicated by other statements by the same 

 writer, as one to nine or twelve. Elliott, a few years later, and subsequent to the 

 date of certain changes in organization of the seals described by IJryant, writes: — " I 

 found it an exceedingly difficult matter to satisfy myself as to a fair general average 

 number of cows to each bull on the rookery; but, after protracted study, I think it 

 will be nearly correct when I assign to each male a general ratio of fiom fifteen to 

 twcut}' females at the stations nearest the water, and from there back in order from 



