ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 249 



And wlien I remind yon — taking it not from any Table that i.s disputed, 

 but from the total pelagic catch — the north-west catch, in and out side 

 Behring Sea— the numbers in 1879 are 11,090; in 1880, 15,227; and in 

 1881, 11,655 — if you apply even the tests of the United States Com- 

 missioners to that, the reduction in the year 1881 in two and three- 

 year-olds, could not amount to more than between 4,000 and 5,000 seals 

 if every one of the females produced a pup. 



Mr. Carter. — How many do you say"? 



Sir EiCHARD Webster. — I give the figures they are in the Talde 

 page 257 of volume II, of the Ai)pendix to the Counter Case of the total 

 Pelagic Catch. In 1879 it is 11,090; in 1880 15,227; in 1881, 11,655. 



Mr. Carter. — I mean your statement of what it would amount to? 



Sir EiCHARD Webster. — I say, if you assume all to be females, and 

 merely apply the death-rate from the United States table, the utmost 

 deficiency there could be of two and three-year-old's in the year 1884 

 would be between 5,000 and 6,000 seals. 



But now, Mr. President, will you let me remind you what the condi- 

 tion of things is with regard to pelagic sealing. It is very well put, 

 Sir, at page 211 of the British Counter Case and the references are 

 given to the detail information about it in the Commissioners Eeport. 



In the Case of the United States, it is olaiuied that this took phice coucurrently 

 with increased sealing in Behi'iug Sea and iu consequence of the death of suckling 

 female seals. But in 1884 only one Canadian sealiug-schooner is known to have 

 entered Behring Sea. 



The first ship to enter was in 1883, the "San Diego", an American 

 shij). 



But in 1884 only one Canadian sealing-schoouer is known to have entered Behring 

 Sea, and in 1885 but two schooners, and it was not till 1886 that as many as sixteen 

 vessels entered the sea. 



ISTow the case made with regard to the killing and deterioration of 

 the holluschickie or the males is due to the fact it is said of the nurs- 

 ing mothers being killed iu Behring Sea. Now I need not do more than 

 put my point before the Tribunal to show the impossibility of sealing 

 to that extent inside Behring Sea, up to the year 1886, having had any 

 sensible effect on the rookeries at all the answer is whatever may have 

 been the diminution of general seal life unquestionably pelagic sealing 

 played its part, and I have not for one moment suggested the contrary 

 but you must look to some other cause to find the very large decrease 

 and, looking for some other cause, you find it in the evidence to which 

 I have called your attention. 



Now with reference to the fact that in the years 1891 and 1892 that 

 there is no dimunition of the number of seals found at sea, you will 

 find at page 29 of the Second volume of the Appendix to the British 

 Counter Case, the Summary of the evidence of 132 witnesses as to the 

 seals being as numerous at sea iu the years 1891 and 1892, that so fiir 

 as you can gather from that testimony there has been no corresponding 

 decrease in the seals at sea, confirming another matter upon which the 

 Commissioners and others have expressed an opinion that the effect 

 of this treatment upon the islands may be to drive a considerable 

 number of the seals to the sea. I was asked by Senator Morgan whether 

 there was any evidence at all of these animals suffering from disease? 

 I expressed an opinion or rather 1 remarked that any race of animals 

 would indeed be extraordinary which was entirely free from disease to 

 which, as far as we know certainly all animals that have ever come 

 under our notice are subjected. 



