198 ARGUMENT OF THE UNITED STATES. 



sarily true. The animal being polygamous, and each male sufficing 

 for from thirty to fifty or more females, we have only to apply common 

 barnyard knowledge in order to learn that under normal conditions 

 there must always be produced a large number of superfluous males, 

 which, if not taken away, would, of themselves, by their fierce and 

 destructive contests for the possession of the females, not only destroy 

 themselves in large numbers, but greatly interfere with and obstruct 

 the work of reproduction. This superfluity of males, therefore, may 

 be taken not only without injury, but with positive benefit to the herd. 

 It is obvious that it is only by diminishing the birthrate that the nor- 

 mal numbers of the herd can be injuriously affected. If the seals were 

 not interfered with by man the herd would increase in number, until 

 by the operation of natural conditions tending to restrict increase, and 

 which operate with accumulating force as the numbers become large, 

 such as deficiency of food, want of convenient room on the breeding 

 places, the occupation of the males in destructive warfare among them- 

 selves, which must greatly interfere with the work of reproduction, the 

 deaths become equal to the births. The numbers of the herd will, 

 other things being unchanged, then remain constant. This is so clearly 

 explained in the Report of the Commissioners of the United States that 

 it is unnecessary to further enlarge upon it here. 1 



Disregarding the causes, other than the interference of man, which 

 may operate to reduce the numbers of the herd, such as killer-whales 

 or other enemies, or insufficiency of food, or disease, matters concerning 

 which we have little or no knowledge, it is manifest that the killing of 

 a single breeding female must, pro tanto, operate to diminish the num- 

 ber of births and thus tend towards the destruction of the animal. We 

 need go no farther. The conclusion from this single fact is certain and 

 irresistible. Pelagic sealing means the killing, principally of females 

 and breeding females; and if practiced to such an extent as to sacrifice 

 such females in considerable numbers, must, in proportion to the num- 

 bers sacrificed, work a destruction of the herd ; and the question when 

 the destruction will be so complete as to amount to a sweeping away of 

 the seals as a subject of value in commerce is a question of time only. 



It is respectfully submitted to this Tribunal that right here is an end 

 of legitimate debate. Any further discussion must relate to a question 

 how far man can tarn 'per with the laws of nature without incurring an 

 injurious penalty. The answer of a tribunal bound to take notice of 



1 Case of the United States, pp. 34G-350. 



