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



Commauder skins, and in tlie Copper and Commander consignments a 

 mixtnre of Alaskan skins, and in the Nortliwest catch a mixture of 

 both: and in all — which is to ine the most sinonlar fact — a large per- 

 centage of skins approximating to the character of Alaskan skins, or 

 approximating to the character of Coi)per and Commander skins: then 

 1 think it is imiwssible to resist the" conclusion that there is a much 

 wider intermingling, and not only intermingling but interbreeding, in 

 the seal family in this ])art of the North Pacific than is admitted by my 

 learned friends on the other side. 



Senator Morgan. — 1 believe there is no doubt that expert witnesses 

 can certainly trace the distinctions between these different skins of 

 different islands. You have no doubt on that point? 



Sir Charles Eussell. — You will see. Sir, what it leaves no 

 976 doubt upon when I call attention to the evidence, which I pro 

 pose to do in a moment or two. This fact, if it be the fact — 1 am 

 not treating it as an admitted fact at all; on the contrary it is denied — 

 but this fact, if it be a fact, of intermingling and interbreeding is only 

 what you would expect. It is a thing you would probably lt>ok for; 

 because here at least we are on common ground, namely that the seals 

 wherever they are found, whether in the I^orthwest Catch or the Rus- 

 sian Catch or the Alaskan Catch, or along the Southern shores, are all 

 of the same species. Therefore, there would be nothing unnatural, on 

 the contrary there would be everything natural, in the fact of their 

 interbreeding, if they intermingle. Then is there anything unnatural 

 or improbable in the fact of their intermingling? No. If the evidence 

 which I shall call attention to in a moment is well ibunded, it will be 

 seen that although there are two great divisions — one of which goes 

 south east in its migrations, and the other goes south west in the 

 autumn and winter — , yet that they are not two distinct armies, so to 

 speak, in regular Indian file, following one another, but that they are 

 scattered over the whole ocean in a greater or less degree: and that in 

 point of fact there is no part of the ocean in which they are not to be 

 found, and in considerable numbers, at any time during the period of 

 their annual migration. 



That again is what one would expect, for a very obvious reason. 

 These are amphibious animals, that live u])on fish, and upon fish only. 

 Tliey would, in the pursuit of their natural food, follow such variations 

 as might be suggested to them by the pursuit of their food, the schools 

 of fish being here at one time, and there at another time; and so thi^ 

 intermingling would be brought about. 



Lastly, and this is the only other point in this connection which I 

 wish to dwell upon, I think that it will be found to be an entire mistake 

 to suppose, as is suggested on the other side, that during the breeding 

 season the whole seal family make their way to the Pribilof Islands and 

 to the Commander and Copper Islands, and that the whole family or 

 whole families are there on or in the immediate neighbourhood of the 

 islands during that breeding season. That will be found not to be the 

 case. It will be found upon the evidence that even in the height of 

 the breeding season, in the month of July and in the month of August, 

 quantities of seals are to be found all over the seas — I mean at some 

 considerable distance from the coast — as to which the probability is 

 that a very large part of them are barren females, young bachelors, 

 and old seals, that do not go to the islands at all; and that as regards 

 the female seal, the evidence, even from the witnesses of the United 

 States, is to the effect that from the moment she leaves the island in 

 the autumn of the year in which she was pupx^ed, she does not return 



