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



had everytbiug to the west of it — there was absoUitely no contention 

 between Great Britain and Russia as to the i)oint on the coast to which 

 the Russian possessions went. 



The Prksident. — If you say that the contention merely bore on those 

 parts of territory and seaboard, how can you iin])ly that Behring Sea 

 was contained and comprised in those definitions? 



Sir Richard Webster. — I am afraid I liave not made my meaning 

 clear. I say the contention bore from whatever point in the South you 

 liked to fix right to the extreme North. 



The President. — There was nothing in question as to Behring Sea 

 coast? 



Sir Richard Webster. — Nothing, except the right of navigation and 

 fishing. I must have expressed myself very badly if I had not conveyed 

 that. 



The President. — As regards the coast, there was no contention 

 except as to what? 



Sir Richard Webster. — As regards navigation and fishing, and the 

 right to visit uninhabited points in accordance with international law. 

 The whole area, up to the North, was in question. 



Mr. Justice Harlan. — There were no conflicting settlements? 



Sir Richard Webster. — There were no conflicting settlements on 

 the coast between Great Britain and Russia. There was no question 

 of a claim to territory by Gieat Britain on the coast of Behring Sea. 



If you would look at page 38 of the British Case, you will find Russia's 

 description of the North- West Coast at the time of the Ukase, the 

 attempt to exclude other nations from exercising then right: 



Section 1. The pursuits of commerce, whaling, and fishery, and of all other industry, 

 on all islands, ports, and gulfs, including the whole of the Northwest coast of America, 

 beginning from Behring Straits to the 5l8t of Northern latitude. 



Therefore, I do not start with that, because it does not happen to be 

 quite the earliest document; but there is a document, which I am going 

 to make allusion to where our construction of " North- West Coast" is 

 put by Russia, and there is not a single document in which a trace can 

 be found of a different definition of "North- West Coast", not a single 

 document; yet my learned friend, Mr. Carter, says that "North- West 

 Coast" is to be regarded as beginning at 60°, if I may use the expres- 

 sion, and coming downwards, after the Treaty he says, ending at 54° 

 40'. My whole point is, there was no discussion as to the point on which 

 Russian possessions ended on the coast itself away to the North. 



The Tribunal then adjourned for a short time. 



Sir Richard Webster. — Mr. President, I find that by inadvertence 

 I made a mistake in regard to that map. I had originally put the red 

 marks on the "number one" map in the United States Case. When I 

 directed a copy to be made for Mr. Phelps and the court there were no 

 coi)ies of "number one" to be had, and therefore those red marks had 

 to be put upon a map of ours. Mine is on the original; but there is no 

 difference. There is nothing upon the map except agreed matter. I 

 only desire to correct a mistake I made by inadvertence, not remember- 

 ing that they had not been plotted on the same map as the one of the 

 United States. 



The President. — I believe it is on your map which is in the 

 Appendix? 



Sir Richard Webster. — I am not sure if it is even that. Yes, you 

 are right, Mr. President. It is the one which is in the 4th volume of 

 the Appendix to the British Case. There are only two maps which 

 were exhibited. 



