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



are bred in sueb inimbers tbat tbey are iiiexbaustible, because the 

 experience all the world over is that fisheries have become repeatedly 

 depleted; and that further, if identification aud habits of returning to 

 the same locality, is to be a sufiicieut test, and if the i)ower of destroy- 

 ing" the whole, or abstaining from destruction is a sufficient claim, this 

 claim must be recognized in respect of various migratory birds and 

 various other animals which are of great use to mankind, probably of 

 much greater use than the seals, the bodies of which are wasted, the 

 oil of which is never reclaimed, and the skin only is used for the orna- 

 mentation of the dresses of certain persons who can afford to pay large 

 sums for their apparel. 



Mr. President, I have said all that at the present stage T feel it 

 necessary that I should say to this Tribunal. I have endeavoured only 

 to supplement the much wider, abler, and more exhaustive argument 

 of my learned friend, the Attorney General, and it is no part of my 

 duty, Sir, to attempt to apply the arts of oratory or the influence of 

 eloquence to the consideration of the questions submitted to this Tri- 

 bunal. I have had two objects in view, and two only, that, so far as 

 facts are involved, the true facts, all the facts, and the facts only shall 

 be laid before this Tribunal, that so far as enunciated principles of law 

 are involved those principles of law should be drawn from the best 

 sources that are at our command, and without any attempt either to 

 strain those principles in favour of, or to minimise their effect against, 

 the contentions we are supi^orting. I am perhaps, more conscious 

 than any one present of the deficiencies in my own argument, but I 

 trust, with its defects, it may still have been of some service to this 

 Tribunal; but, Mr. President, what will remain forever in my mind is 

 the recollection of the unvarying courtesy and patience with which my 

 observations have been received by every member of this Court. 



The President. — Sir Eichard, we thank you for the very substan- 

 tial and useful observations with which you have supplemented the 

 argument of Sir Charles Russell. We knew how much we were 

 indebted to you already for the elaborate study you have made of this 

 case on behalf of Great Britain, and I for one have very much admired 

 the unrestricted and friendly co operation of yesterday's Attorney 

 General with to-day's Attorney General. The country is indeed to be 

 envied where party spirit admits of such brotherly association when 

 the national interest is at stake. 



