ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 215 



cows to each old bull (no young ones about), as the result of careful investigation: 

 and single harems in which I have counted over one hundred cows each in the 

 flimsy charge of an old and weary "sea-catch"; such harems were not uncommon: 

 this unnatural disproportion of the sexes on these breeding grounds to-day renders 

 the service there of reproduction quite lifeless — almost impotent, wholly so in a vast 

 aggregate of cases. 



I cannot too often repeat as I have shown you already and will 

 remind you later on there are no less than four Government Agents, 

 who knew of these facts, and who have made Eeports, showing that 

 they observed the same thing; and there is not a shadow of a state- 

 ment that this is untrue. The only grounds on which it can be said to 

 be untrue or exaggerated is because it is not the class of testimony 

 favourable to the IJnited States' contention that the harems had decreased 

 in number. Would you kindly turn to page 240? This is the extract 

 made at the time on Ketavie, one of the rookeries: 



As this is the time the cows begin to haul out in appreciable numbers, I took a 

 careful view at this Ketavie Rookery to day from that point of sight in the sketch 

 opposite. 



You know that there were some 30 or 40 in number, which were 

 photographed by the United States, and the photographs have been 

 deposited with the Eeport before this tribunal. 



I saw but three clusters of cows in all the sweep of this picture, and they in 

 the fore-ground right between the 1st and 2nd rollers as they come in; these pods 

 were bevies of from 30 to 50 cows each, all thickly clustered around a single bull 

 with all the other bulls stretched in somnolence around them, just as I recorded 

 the state of affairs on Tolstoi yesterday ; and as I go over the field on Lukauuon right 

 after this I lind it precisely that way there, too; this apathy of the bulls coupled 

 with the total absence of the " polseecatchie" (or "half-bulls") on these breeding 

 grounds at this hour is a striking contrast with that din and fury that was so marked 

 among the swarming bulls of 1872 on this and every other one of the breeding grounds 

 of the Pribilof Islands. 



Then 1 might read page 241, the day before on Tolstoi, which he 

 refers to — 



But the behavior of the old bulls is extraordinary this morning at this time of 

 the inflowing cows ; they are listless ; three-fourths of their scanty number, stretched 

 out sound asleep, while right alongside of these sleepers, a pod of 15 or 30 cows will 

 be closely clustered around a single alert bull, or one that at least is not inert and 

 stupid. There are three such pods as that right under my eyes as I make this note, 

 lying at the junction of the sand beach and rocks of Tolstoi rookery; no such scat- 

 tering of bulls and indifference was ever witnessed on any of these breeding-grounds 

 in 18'72-'74; then every bull was alert and iurious in his struggles to get possession 

 of at least one, if not all the females within reach; — now, look at them! Why, it 

 seems to me that these bulls are enfeebled and sick. At least it is a most remark- 

 able deviation from the method and order of first arriviil of the females in 1872; 

 such a picture of perfect listlessness and indift'erence as this is, from the beginning 

 to the end of the season, never met anybody's eye on these breeding-grounds then. 



Now, nobody can read this Report and know that it was a contempo- 

 raneous record of that which he and many other persons saw at the 

 same time, without coming to the conclusion at once, if it was possible 

 of contradiction in fact, it would have been contradicted. I will show 

 you it is without contradiction. 



I cannot help pressing upon you the fact of four respectable Govern- 

 ment Agents referring to this Keport, knowing it is made and describ- 

 ing to the same extent though not in such detail the same things, all of 

 whom must be supposed to be telling a falsehood if this is not a true 

 story of what is going on. You cannot wonder that the United States 

 people were not willing that such accurate information should be at 

 our disposal. 



Take page 245, on the 3rd of July. You will remember the principal 

 hauling out begins on the 20th of June, and there are constant tights 



