ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 235 



It will be seen also that by this tTriving process the 2- or o-year-olds, which are 

 tlu- only ones killed for their skins, are culled out almost ct)inpletely from the seals 

 ■which visit these islands, and therefore that very few male seals ever reach a greater 

 age; consequently, there are not enough yonng bulls growing up to supply even the 

 yearly loss on the rookeries, much less to provide fur any increase. 



I ask, if that is not true, why have not we the evidence of people who, 

 in 1801 and 1802, opened and examined these seals! There have been 

 openings and examinations of pups quite properly to make out their 

 death was due to the pelagic sealer. There was an examination in 1801 

 of pups to show that there was no trace of organic disease; and I want 

 to know if it be not true that this driving has this effect, — nobody 

 suggests that Mr. Palmer is not experienced, nobody suggests that he 

 is not honest; and he personally opened these seals himself and he 

 stated, speaking to a scientific society, the result of his own observa- 

 tions. But it does not rest only on Mr. Palmer though that would be 

 a very, very strong fact if it stood alone. I remind you again, and I 

 will not stop to read them because most of them have been read already, 

 on page 201 of the British Counter Case you will find a collection of 

 extracts of persons who have spokeu on this matter. 



Kow, I will ask you to be good enough to take volume I of the Appen- 

 dix to the Counter Case, and to look at what was observed in the years 

 1801 and 1802 by Mr. Macoun. 1 read from page 152 of the 1st volume 

 of the Appendix to the Counter Case. 



When on the Pribilof Islands I was present at four "food-killings", three on St. 

 Paul Island and one on St. George Island, and was tliui^ enabled to observe carefully 

 the methods employed by the agents of the North American Commercial Company, 

 and the natives working under them, in selecting from the thousands of seals driven 

 to the killing-grounds the few hundreds that were to be killed. I had expected that 

 the driving and killing of these seals would be under the direct supervision of an 

 officer of the Government, for while it was well understood that the skins of the 

 seals killed would be taken over by the Company, the object of the killing during 

 the modus rivendi was supposed to be not for the purpose of taking skins for the 

 Company, but to su^iply the natives with food. 1 did not myself accompany the 

 natives during the whole progress of a drive from the hauling-grounds to the killing- 

 grounds, but on three occasions on St. Paul Island I accompanied the drive for some 

 distance before the killing-grounds were reached. On none of these occasions did 

 an officer of the United States Government see anything of the seals until they were 

 all driven together near the killing-ground, and once the killing had to be delayed 

 for some time until the Treasury Agent reached the ground. Once only on either 

 island did an officer of the Government in my presence interfere in any way with 

 the natives or the agents of the Company iu their work of clubbing and skinning 

 the seals, or make to them any suggestion as to which seals ought to be killed and 

 which spared, and the number of seals killed on every occasion dejiended not upon 

 the wants of the natives, but entirely upon the number there were in the drive that 

 were thought by the agents of the Company to be of a size that would give to them 

 skins of the greatest value. The one instance referred to above was at the killing 

 on the 1st of July. A seal with apparently a broken shoulder was allowed by the 

 natives to escape though they noticed its condition. C«donel Murray, — 



he was one of the Government Agents, and I have read his Eeport 

 before, 



then ordered one of them to go after it, and it was killed. At this killing less than 

 300 skins were taken. A careful account was kept by me of the number of seals that 

 were driven up to the clubbers, and were allowed to esca]ie after having been hud- 

 dled together on the killing-ground, while those of a kilhiblesize were selected from, 

 the drive. 



But 14.1 per cent, of the whole number of seals driven at this time were killed, 

 while among those that escaped I counted seventeen that were badly enough bitten 

 or wounded to bleed considerably, and there were doubtless many more that I failed 

 to notice. Three of those injured were young seals that had evidently been struck 

 by the clubbers, as they were badly cut about the head. One seal, about 6 years old, 

 that had been wounded in the belly, was allowed to escape. I Avent to where it had 

 rested for a few minutes, and found as much clotted blood as would have filled a 

 breakfast cup. Another seal had a gash in its back about 5 inches long, and though 



