ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 451 



Lord Hannen. — You might suggest yet another word — " margin ". 

 Sir Richard Webster. — I will read now Article VII, which corre- 

 sponds with the American Article IV. 



It is also understood that, for the space of ten years from the signature of the pres- 

 ent Convention, the vessels of the two Powers, or those belonging- to their respective 

 subjects, shall mutually be at liberty to frequent, without any hindrance whatever, 

 all the inland seas, the gulfs, havens, and creeks on the coast mentioned in Article 

 III, for the purposes of tishiug and of trading with the natives. 



Not the lisiere; and if you look at the French, which is perfectly 

 plain description, the words are: 



Les golfes, havres et criquea sur la c6te mentionn^e dans I'Article III 



Without any reference to "lisiere" at all. The only feeling I have 

 in dealing with this matter, is that it is a little cruel to my friends to be 

 exposing the impossibility of maintaining the argument by which Mr. 

 Carter has said, in his opinion, Mr. Blaine, to his entire satisfaction was 

 completely successful in showing that Behring Sea was excluded from 

 the Pacific Ocean, and that Northwest coast had this meaning by those 

 treaties. 



Mr. Justice Harlan. — Would you turn to Article III and tell me 

 what is the " coast " mentioned there. 



Sir EiCHARD Webster. — Yes. The coast mentioned in Article III, 

 is — 



The line of demarcation between the possessions of the High Contracting Parties 

 ujjou the coast of the continent and the islands of America to the north-west. 



That is from about 54° 40' right up to the point where 141° West 

 longitude strikes the Arctic Ocean, and I submit there is no question 

 about it. 



The line of demarcation runs behind the lisiere until it gets to Mount' 

 St. Elias, and then it goes straight up. 



Mr. Justice Harlan. — What do you say is the point of the shore 

 referred to as the "coast" in Article VII ? 



Sir Richard Webster. — The "coast" is the whole of the coast up 

 to Behring Straits. 



Mr. Justice Harlan.— Up to Behring Straits? 



Sir Richard Webster. — The line of demarcation is a complete line. 

 It divides the British possessions from the Russian possessions j it has 

 nothing to do with the lisiere. 



Now I will read the translation, and perhaps, Mr. President, you wDl 

 kindly follow it in French. I am reading from page 54 of the British 

 Case. It is not my translation but I believe it is correct. It is this: 



The line of demarcation between the possessions of the High Contracting Parties 

 upon the coast of the continent and the islands of America to the north-west, shall 

 be drawn in the manner following: 



Commencing from the southernmost part of the island called Prince of Wales' 

 Island, which point lies in the parallel of 54° 40' north latitude, and between the 

 131st and the 133rd degree of west longitude (meridian of Greenwich), the said line 

 shall ascend to the north along the channel called Portland Channel, as far as the 

 point of the continent where it strilces the 56tli degree of north latitude; from this 

 last-mentioned point, the line of demarcation shall follow the summit of the moun- 

 tains situated parallel to the coast, as far as the point of intersection of the 141st 

 degree of west longitude "of the same meridian"; and, finally, from the said point 

 of intersection, the said meridian-line of the 141sfc degree, in its prolongation as far 

 as the Frozen Ocean, shall form the limit between the Russian and British posses- 

 sions on the continent of America to the north-west. 



I submit (remembering that the line of demarcation was to be com- 

 plete with reference to the coast referred to as the north-west coast of 



