ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 213 



A good many cows, aud a great many pups were not counted, as they did not seem 

 to belong to any particular family. These cows liad been served, and were, conse- 

 qnently. allowed to wander from their lords. The pups apparently do not long 

 remain in families where they belong, but soon begin to wander about, and to collect, 

 for a part of the day at least, into large bunches or pods. 



Tbeiefore I point out that it is an estimate not taken in a way that 

 would create tlie largest maximum number I make no complaint about 

 it but it cannot be said he counted exceptionally large harems, because 

 he himself describes before his count he left out some of the cows and 

 pups that might apparently belong because he thought there were more 

 than did belong to the harems. But in the evidence as it stands you 

 have in the year 1891 and 1892 averages according to Mr. Stanley 

 Brown of 25, aud of Mr. Evermann an estimate given from these cal- 

 culations which would show even a larger quantity. 



Now there is very accurate testimony of this matter given by Mr. 

 Macoun in page 140 of the first volume of the Appendix to the Counter 

 Case, which I will ask you to be good enough to follow reminding you 

 once more, if I may respectfully do so, of the importance of this issue, 

 as pointed out by the United States Commissioners themselves: 



Whenever harems were well defined, and could be readily separated from adjoin- 

 ing ones, the number of female seals was counted. It was found that though there 

 were a few cases in which an old bull would have but two or three cows about him; 

 there were many other bulls which had filty or more one in particular shown me by 

 Mr. Brown, hadabout him more than eighty females. This was Mr. Brown's estimate. 



The average number of females in each harem, according to my count was about 

 thirty, my figures giving a little over that number. My attention was frequently 

 drawn by the United States Agents to what they called the great number of mature 

 bulls that were without harems. Comparing mentally the number of such bulls 

 with those seen on the rookeries of last year, I decided, while on the ground, that 

 there were not more than there were in 1891 though an additional number of mature 

 males must have come upon the breeding-grounds. A comparison of photographs 

 taken during the two seasons show no change in the number of bulls without 

 harems. During neither season were there old bulls to be seen in anything like the 

 numbers mentioned by Elliott and others. 



Thus, Mr. S. N. Buynitsky says : 



Thousands of old bulls, which have become useless for the purposes of propaga- 

 tion and are an incumbrance to the rookeries might be killed for their blubber. 



Captain Bryant writes: 



Diu'ing the latter portion of the landing time there is a large excess of old males 

 that cannot find room on the breeding places; these pass up with the younger seals 

 and congregate along the upper edge of the rookery, and watch for a chance to 

 charge down and fill any vacancies that may occur. 



And again: 



The number of full-grown males at this date (10th August) may be considered as 

 three times greater than the number required, or equal to one full-grown male to 

 every three or four females. 



PZlliott says, writing of the years 1872-74 : 



At the rear of all these rookeries there is invariably a large number of able-bodied 

 males which have come late, but which wait patiently, yet in vain for families. All 

 the surplus able-bodied males that have not been successful in effecting a landing 

 on the rookeries cannot at any time during the season be seen here on this rear line. 

 Only a portion of their number are in sight; the others are either loafing at sea 

 adjacent, or are hauled-out in morose squads between the rookeries on the beaches. 



And again: 



300 or 400 old bulls were killed to supply skins to furnish the natives with canoes. 



Not that number could have been secured in 1892 had the bulls without harems 

 been driven from every rookery on both islands. 



The greatest number of bulls in proportion to the cows on the rookeries were to 

 be found at North-east Point. I visited the rookeries there in company with Mr. 

 Brown on the 2nd July. He drew my attention to what he called the excessive 

 number of bulls without harems and tliere certainly appeared to be a great many 

 but knowing that their great size renders them couspicioiis, I carefully counted all 

 that were to be seen in the vicinity of the rookeries at this place. 



The bulls near each rookery were counted three times, and the totals of the three 

 counts were 94, 89, and 92 respectively. 



