ORAL ARGUMENT OF SIR CHARLES RUSSELL, Q. C. M. P. 211 



figures given. It is not mucii more, if anything more, tliau a third of 

 each year. So far, therefore, there is very little difterence between us. 

 I am not concerned however to demonstrate that the seal is a sea ani- 

 mal. Probably the true explanation is that it is partly a land animal 

 and partly a sea animal, or in other words, what is commonly called 

 "amphibious''; but that does not seem to be very important. 



Is there any dispute about the other facts which are important on 

 the question of jn'opeity : that it gets no sustenance from land, there is 

 no dispute as to that: or upon the fact that the lessees of the United 

 States do nothing artificially to induce it to come to the islands, and 

 that if they did try to do anything artificially to induce it to come to 

 the islands, it would probably have a repellent effect. There does not 

 seem to be any dispute about that. 



Then what does it come to? It comes to this : that it is an animal 

 which breeds on the islands, and resorts to the islands mainly to breed. 

 That will be found to be, ultimately, the material fact in the controversy 

 upon the question of property. But how about the character of the 

 animal itself f Is it, or can it be called, a domestic animal? 



Now I would like to refer to one or two points in this connection which 

 I think are not unimi^ortant. We have one instance given in the United 

 States Case, where an attempt was made to tame a young seal, and I 

 would like to refer to it as it is the onlj^ one I think that is given. The 

 story is given on page 33 of the Second Volume of the Appendix to the 

 case of the United States. It is the case of a pup called "Jimmie". 

 He was very short-lived. How he got his name does not appear; but 

 the accident of his birth is mentioned at the beginning of the section: 



Little " Jimmie", as this particular pup was called, was the child of adverse cir- 

 cumstances, as his mother happeued accidentally to be caught in a large drive and 

 could not be separated from the herd until the killing ground was reached. 



Shortly alter being parted out and allowed to go free, on her way to the water, she 

 hurriedly gave birth to this ])up and continued on her journey. The pup was watched 

 carefully for a few days, and when it Avas thought to have been deserted a kind- 

 hearted employe of the Company, Mr. Allis, brought it into the village with a double 

 view of trying to save its life as well as to make a pet of it. 



For the first lew days, as nobody could nuinage to make him eat, and as he would 

 generally get the best of some friendly linger in these attempts at feeding he was let 

 severely alone. Then followed various contrivances, mechanical and otherwise, for 

 holding his head so as to feed him with a sjioonor a nursing bottle, but all to no pur- 

 pose, for he would get most of the milk everywhere but where it was euteuded to go. 

 This went on for all of two weeks or more. I then. equipped myself with a large 

 syringe and a flexible tub« and about a pint or so of warm fresh cow's milk. Little 

 ''Jimmie's" mouth was kept open, the tube was passed down his throat into his 

 stomach, the syringe filled with milk, in quantity as before stated, and which was 

 unanimously agreed was not too much for him at one feeding, was slowly injected 

 down the tube into his stomach. 



Alter the operation the tube was carefully withdrawn, and "Jimmie" was left to 

 his own devices. The pup, much to the gratification and amusement of all present, 

 immediately began to show in the most unmistakable manner the greatest of seal 

 973 delight, i. e. to lie down in the various positions of seal comfort, on his back 

 and side, and wave and fan himself with his flippers, scratch hiuiself, bleat, 

 etc. As these signs were unniistalcable to all present who were familiar with the 

 habits of seals, the operation was thought to be a success. Up to the last time the 

 pup was seen, late that night, he was doing flnely, but next morning he was found 

 dead, and I attribute his sudden taking off either to the small boy or an accident 

 during the night". 



I believe that is the best authenticated instance — the only one that 

 I am aware of — of an attemi)t to domesticate the seal: the seal which 

 we are told could be induced to follow you — which was semi human in 

 its intelligence — which kept ap])ealing to you for aid and protection. 



Now, Mr. President, in this connection, I want to read one or two 

 passages from the same volume. The first is at page G9, which expresses, 



