452 OKAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 



the continent, and the Islands of America to the north west), that 

 nobody who can take an impartial view of this matter can come to any 

 other conclusion than that the coast referred to in Article VII is the 

 whole coast; and Avhen we remember that in the United States the 

 expression lisiere does not occur at all, aud that Article III of the 

 United States treaty speaks of the north-west coast of America north 

 of 54° 40', and that I am justified in sajdng that Mr. George Canning 

 believed that he was getting the same for Great Britain as the United 

 States had got from Russia — there is not any answer, at any rate, 

 apparent (unless I have made some grave blunder) to the contention 

 that the right of Great Britain to visit, during ten years, inland creeks, 

 and harbours, and to visit for the purpose of navigation and fishing the 

 seas which washed the American coasts extended right away from 54^ 40' 

 up to the point to which I have called attention. 



Now it is not necessary for me, unless my friends tell me so, to refer 

 to the other Articles of the Treaty. They relate to the sale of spirits, 

 and to Sitka, and I^Tew Arclaangel, and to other matters, which are 

 specially referred to, but have no bearing on the discussion which is 

 now before you. 



There are two matters in this connection which have not received 

 notice, and to which I ought to direct the attention of the Tribunal, 

 not in any way as qualifying or even as strengthening v\"hat in my sub- 

 mission to this Court is so absolutely plain, but I refer to it in order 

 that it may not be thought that I have overlooked my friend, Mr. Car- 

 ter's, point. Mr. Carter said, for the purposes of this Treaty, they 

 were not concerned with what the previous correspondence had been. 

 They said "the Ocean commonly called the Pacific Ocean" — I think I 

 have quoted the language quite correctly — and accordingly they meant 

 by that "south of the Aleutian Islands". It would have been a little 

 satisfactory, at any rate to us who have to answer my friend, if he had 

 gone on and told us where he got the common reputation of Pacific 

 Ocean to be that south of the Aleutian Islands; but, at any rate, I will 

 put the material before the Court. I must not read it, because it would 

 be simply a waste of time, in one sense — not a waste of time as far as 

 the information is concerned, but it would be tresijassing on the 

 indulgence of the Court to read it. There are several collections of 

 what I may call information of considerable use, if this matter came to 

 be discussed. I call attention first to the 1st volume of the Appendix 

 to the Counter Case, because it happens to be most complete, and 

 will ask you to look at page 88. Now there you will find, Mr. President, 

 that which we believe to be the most complete record (and they have 

 been selected without any regard to taking anything that is for or 

 against us) of the maps and geographies which have ever been collected 

 in connexion with this matter. The list sent by Mr. Blaine to Lord 

 Salisbury was found, when it came to be examined very deficient indeed. 

 This is very much larger, and it includes a great many more; and Mr. 

 Blaine's list did not call attention to the way in which the names were 

 used. 



Would the Tribunal kindly look at page 88 of App. I to British 

 Counter Case. In the margin there you will find the date put of every 

 reference made. I will read down tlie dates first. 1795; 1802; 1803; 

 1804; 1808; 1815; 1819; 1822; 1823; 1820; showing that they are pretty 

 contemporaneous. Now, Mr. President, let me read you a specimen of 

 two or three of them : 



"Kamscbatka Sea is a largo hranch of the Oviental or North Pacific Ocean." 

 "Behrinu's Straits, which is the passage from the Nortli Pacitic Oceau to the 

 Anaic Sea." 



