ORAL ARGUMENT OF SIR RICHARD WP:BSTER, Q. C. M. P. 259 



sea by pelagic sealiug taken on onr submission, to a large extent are a 

 class of seals not freciueiitiiig the islands at the time. 1 do not refer 

 to that, but the barren females who will be found away from the islands, 

 and a large number of otlicrs, have no motive or inducement to go — 

 take the male seals which are not forming part of the breeding or 

 producing stock upon the islands. 



The President. — We have had the number of seals killed at sea 

 last year and the year before, and the amount was 70,000. 



Sir EiCHARD Weester. — You are speaking, I think, of the amount 

 of seals killed in 1891. 



The President.— 1891 and 1892. 



Sir KiCHARD Webster. — To a large extent outside of Behring Sea. 



The President. — And Behring Sea is to be added. 



Sir EiciiARD Webster. — As a matter of fact there were killed 

 there, Sir, 500 only. 



The President. — It should be added if Behring Sea was left open. 



Sir EiCHARD Webster. — Of course, one must have it one way or 

 the other. It cannot be put against me both ways. All pelagic sealing 

 up to July 1st is stopped, and you have to contrast the new state of 

 things with the old; and my submission to this Tribunal is that after 

 the 1st July in every year sealing in Behring Sea would stand at 

 about a normal figure. It may be 30,000 or 25,000 or thereabouts, but 

 it would be directed to and attack a class of seals that to a large extent 

 would not be going to the Islands, and would never be got by the 

 people on the Islands at all. I have endeavored to make my point clear 

 on that, and I hope I have done so. 



The President. — You do not say outside Behring Sea there would 

 not be seals killed also. 



Sir EiOHARD Webster. — Outside Behring Sea; the position of Her 

 Majesty's Government is that upon reasonable arrangements made that 

 an undue quantity should not be killed on the islands they would be 

 willing to prohibit pelagic sealing until the 1st of May which would 

 cut off all the dangerous killiug, outside as well as inside. 



The President. — What do you consider not to be dangerous? 



Sir EiCHARD Webster. — The killiug of seals south of the Aleutian 

 Islands after the 1st May, and in Behring Sea after the 1st July, out- 

 side the 30 mile zone, dealing with the matter as a whole. If I have 

 not made the point clear. Sir, I would ask you to put the question 

 again. 



The President. — I think you have made it quite clear; but I also 

 think that the questions I have put have contributed to make it more 

 clear to me at any rate. 



Sir EiCHARD Webster. — I have not the smallest doubt as to that, 

 of course, Sir. 



The President. — And I would like to know the total average in the 

 killing of seals that is admissible both on sea and on land. 



Sir EiCHARD Webster. — The killing of seals, both male and female 

 altogether would amount to something like 90,000 or 100,000, but you 

 must not understand me as admitting the absurd contention that killing 

 a female necessarily reduces the number of a herd. I do not want to 

 go back on that: it is such an outrageous contention. 



The President. — That has been argued very fully. 



Sir EiCHARD Webster. — Because if what I say were so, the herd 

 would have disappeared years and years ago, because hundreds and 

 thousands are killed every year. If you put it to me what is meant by 

 the total killiug, I should say a total killing on land and sea of between 



