ORAL ARGUMENT OF SIR RICHARD WEBSTER, Q. C. M. P. 525 



observation vS applicable, so to speak, to this particular tribe of animals, 

 the seals. I do not wish to add anything to the general description of 

 them given by my learned friend, the Attorney General. I confess I 

 was somewhat surprised in reading through the argument of Mr. Cou- 

 dert, and the passage I refer to will be found at page 594 of the revised 

 print before the Tribunal, when he stated that seals were only amphib- 

 ious as the result of education. It struck me as a somewhat strained 

 view. We know on the evidence that although young seals would be 

 drowned if they were allowed to remain in the water too long, that is 

 to say, that they cannot sustain themselves iu the water during the 

 first years of their birth any more than birds can fly when they are 

 first hatched 



Lord Hannen. — You used the word "years". I suppose you would 

 say "mouths". 



Sir EiCHARD Webster. — I ought to have said "days" of their birth 

 any more than birds can fly; but we know that the instinct is there, 

 for there is abundant evidence that pup seals have swum when in the 

 water. I mention this to show that the argument of the United States 

 has gone to very remarkable lengths when it leads my learned friend 

 to suggest that the amphibious nature of the seals is only the result of 

 education. 



I wish to say a word on that Avhich both my learned friends, Mr. 

 Carter and Mr. Coudert, regarded as of importance, — the question of 

 intermingling; and certainly, from a most careful view of this evidence, 

 I say he will be a very bold man who would suggest that these seals 

 did not inter uiiugle, whether you take the evidence of the United States 

 alone or whether you take the body of evidence on both sides. 



I will remind you in a few moments of one or two matters which bear 

 directly upon that. You will remember that my learned friend, the 

 Attorney General, read to the Tribunal extracts from the evidence of 

 the fur merchants, showing the existence in the Alaska catch of skins 

 which could not be distinguished from the Commander and Copper 

 Island skins, and iu the Commander and Copper Island catch of skins 

 which could not be distinguished from the Alaskan. He further read 

 to the Tribunal evidence to show that in the same catches there are 

 also skins in the Alaska and Copper Islands respectively which prac- 

 tically show interbreeding. I desire to supplement that evidence with 

 one or two observations, directing the attention of the Tribunal to two 

 or three matters in the same connection. First, I should like to tell 

 the Tribunal that there are no less than 32 Furriers of independent 

 position, many of them giving evidence for the United States, to many 

 of whom my learned friend, Mr. Coudert, appealed as being witnesses 

 of impartiality and integrity, — there are 32 witnesses, who will be 

 found on pages 238 to 251 of the 2nd volume of the British Counter Case, 

 who speak to the finding of these skins, as I have said, indistinguish- 

 able among the Alaskan catch from the Copper and Commander Island 

 catch. Mr. Coudert felt that that would be important evidence, for, 

 on page 618 of the Eevised Print, he said : 



But upon this you will observe that there is not one single witness who will tes- 

 tify that he ever found a skin which he would call a Copper skin, in a consignment 

 of Alaskan skins. 



I do not, of course, want to prove my learned friend to be in the 

 wrong, because it was a matter to which perhaps he had not had his 

 attention sufficiently directed to; but so far from there not being a single 



