ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 453 



"Beering's Island. An island in the Pacific Ocean." 

 "KamscSatka. Bounded east and south by Paciho." 



That is a most imi)ortant matter : 



Bounded east and south by Pacific. 



Then it says : 



Kamschatka. Bounded on the North by the country of tho Koriacs, on the east 

 and south by the North Pacific Ocean and on the west by the Sea of Okotsk. 

 Behring's Island. In the North Pacific Ocean. 

 Behring's Island. An island in the North Pacific Ocean. 

 Kamschatka. River, which runs into the North Pacific Ocean. 



The Kamschatka River rans into Behring Sea JSTorth of the Com- 

 mander Islands. Then there is the date of 1819. I have not read the 

 dates against each. I might have done it perhaps in that way. Then 

 it goes on: 



"Pacific Ocean considered as the boundary of the Russian Empire, washes the 

 shores of the Government of Irkutsk, from Tschukotsky Noss, or Cook's Straits, to 

 the frontiers of China; or, in other words, from the mouth of the River Aimakan 

 that is, from 65° to 45° North latitude. It is divided into two great parts. That 

 lying eastwards from Kamschatka, between Siberia and America, is eminently 

 styled the Eastern, or Pacific Ocean; that on the west side, from Kamschatka, 

 between Siberia, the Chinese, Mongolia, and the Kurile Islands, is called the Sea of 

 Okhotsk. From the different places it touches it assumes different names, e. g., 

 from the place where the River Anadyr falls into it, it is called the Sea of Auadyr, 

 and above Kamschatka the Sea of Kamschatka; and the bay between the districts 

 of Okhotsk and Kamschatka, is called the Sea of Okhotsk, the upper part of which 

 is termed Penjinskoye More, that is, the Penjinskiau Sea, as it approaches the mouth 

 of the River Penjine." 



I might occupy a great deal more time than the importance of the 

 question merits, in going through these documents. If you will turn to 

 pages 92 to 105 you will find a consecutive record of maps, without 

 selection, from which it will apj^ear that though at times portions of the 

 North Pacific were called, and properly called, Beaver Sea, Behring Sea, 

 Sea of Kamchatka, and some other names, that in the vast majority of 

 cases the common appellation given to the whole district of the ocean 

 right up to the Behring Straits is Pacific Ocean. 



Mr. Justice Harlan. — Sir Eichard, do you regard the phrases 

 "North Pacific Ocean" and "Pacific Ocean", as identical all through 

 that volume ? 



Sir Richard Webster. — I think. Sir, that "Korth Pacific Ocean" is 

 for this purpose identical with "Pacific Ocean": "South Sea" was 

 another name for it for a particular reason. South Pacific Ocean would 

 really begin south of the equator. I have not studied the actual point 

 where South Pacific would end, but I understand that ^'orth Pacific 

 Ocean merely means the northern part of the Pacific Ocean. 



Mr. Justice Harlan. — I have seen a good many maps on which the 

 waters south of the Aleutian Islands are marked distinctly " North 

 Pacific Ocean", while the waters north of them were marked sometimes 

 Sea of Kanitchatka, and sometimes Behring Sea. It is quite true, as you 

 say, that there are maps both ways. 



Sir Richard Webster.— There is a large number of maps on which 

 Pacific Ocean appears as going over the whole, and Behring Sea appears, 

 above it, in small type as being the sea which was what I may call the 

 part of the Pacific Ocean that bad got that name. 



You will find a map of the North Pacific Ocean below the Aleutian 

 Islands hanging behind you, and Behring Sea put in its place. At any 

 rate, it should not be thought that we have created evidence for our- 

 selves. It is known all over the world that particular seas and parts of 



