574 ORAL ARGUMENT OF CHRISTOPHER ROBINSON, Q. C. 



Avero clainiinoby the TJka.se? What did the United States and Kn.iiland 

 iindeiistand them to chiiiu? Against wluit portion of that claim — if not 

 against all — did they protest; and how was their protest treated by 

 Kussia? Did she withdraw the claim, or oidy a part? 



Now we hnd that the Ukase, to nse the words of section I, which I 

 read from the Case of Great Britain, j). 38, says that: 



The pursuits of commerce, whaling and fishery, aud of all other industry on all 

 islands, ports, aud gulfs including the whole of the north west coast of America, 

 beginning from Behring's Straits to the 51° degree of northern latitude, al.so from 

 the Aleutian Islands to the eastern coast of Siberia, as well as along the Kurile 

 Islands from Behring's Straits to the South Cape of the Island of Uriip, viz, to the 

 45"^ 50° northern latitude, is exclusively granted to Russian subjects. 



ISTo one wonhl question what is the meaning of "north-west coast" 

 in those words : 



The whole of the north-west coast of America, beginning from Behring's Straits, 



Going southward, 

 to the 51" of northern latitude. 



There can be no question about that. Therefore the Ukase, at the 

 beginning, puts a perfectly plain and unmistakable meaning on the 

 words, " north-west coast." 



Then that was transmitted to Mr. Adams on the 11th of February 

 1822, and his reception of it is to be found in his letter of the 25th of 

 February 1822, in which he says : British Case p. 17. 



I am directed by the President of the United States to inform you that he has seen 

 with surprise, in this Edict, the assertion of a territorial claim on the part of Rus- 

 sia, extending to the 51st degree of north latitude on this continent. 



I take that to mean extending southward to the 51st degree of north 

 latitude on this continent. He then continues : 



And a Regulation interdicting to all commercial vessels other than Russian, upon 

 the penalty of seizure and coutiscatioii, the approach upon the high seas within 100 

 Italian miles of the shores to which that claim is made to apply. 



There, again, it would seem to me, we have Mr. Adams' very clear 

 apprehension that it was a territorial claim of the coast down to the 

 51st degree of northern latitude, and an interdict of approaching, on 

 the high-seas, within 100 miles of that coast. 



Now M. de Poletica answers that in Avords which have always 

 appeared to me, and I venture to say nuist appear to anyone, unmis- 

 takable and clear. These objections on the part of the United States to 

 the claim of Russia having been called, as I understand, to their atten- 

 tion, M. de Poletica answers in these terms: British Case p. 48. 



I ought, in the last place, to request you to consider. Sir, that the Russian posses- 

 sions in the Pacitic Ocean extend, on the north-west coast of America, from Behring 

 Straits to the 51st degree of north latitude. 



Now is there any i)0ssibility of doubt as to what that means? They 

 speak of "Pacific Ocean," and they speak of "the north-west coast." 

 Can anybody contend for a moment tliat "Pacific Ocean" there did 

 not include Behring Sea, or that the "north-west coast" did not include 

 the coast up to Behring Straits? 



It would be impossible to express that meaning in words more plain, 

 more conclusive, or more clear — I do not know how it could be done. 

 The Russian possessions — he asserts — "in the Pacific Ocean extend, 

 on the north-west coast of America" . . . "from liehring Straits 

 to the 51st degree of north latitude". The letter then goes on: 



