108 BULLETIN OF THE BUREAU OF FISHERIES. 
instead of a marine league from the shore following its sinuosities. The present 
tendency is to consider all bays less than ro miles in width at the mouth as 
within the jurisdiction of the riparian state. 
In the convention of 1839 between France and Great Britain, applicable to 
the seas lying between the coasts of the two countries, it was agreed that “‘the 
limits within which the general right of fishery is exclusively reserved to the sub- 
jects of the two kingdoms respectively are fixed (with the exception of those in 
Granville Bay) at three miles distance from low-water mark. With respect to 
bays the mouths of which do not exceed 10 miles in width, the 3-mile dis- 
tance is measured from a straight line drawn from headland to headland.” By 
a municipal law of June 7, 1832, Belgium had already adopted this rule. 
The convention of 1882 signed by Belgium, Denmark, France, Germany, 
Great Britain, and the Netherlands, respecting the fisheries of the North Sea, 
recognized territorial waters as those ‘‘within the distance of 3 miles (geo- 
graphical) from low-water mark along the whole extent of the coasts of their 
respective countries, as well as of the dependent islands and banks. As regards 
bays, the distance of 3 miles shall be measured from a straight line drawn 
across the bay, in the part nearest the entrance, at the first point where the width 
does not exceed 10 miles.”” And precisely the same language was used in the 
Anglo-Denmark convention of 1901 for regulating the fisheries in nonterritorial 
waters surrounding Iceland and the Faroe Islands. 
The unratified Anglo-American fishery treaty of 1888 provided that the 
territorial jurisdiction of 3 marine miles “shall be measured seaward from low- 
water mark;” and after designating certain bays which should be considered 
as territorial waters, it set forth: ‘‘But at every bay, creek, or harbour not 
otherwise provided for in this treaty, such marine miles shall be measured sea- 
ward from a straight line drawn across the bay, creek, or harbour in the part 
nearest the entrance at the first point where the width does not exceed 10 
marine miles.” 
While the tendency of international law is to restrict jurisdiction over large 
coastal indentations, there is no absolute rule in this respect. Chesapeake Bay 
and likewise Delaware Bay are recognized as parts of the territory of the United 
States.? Great Britain claims territorial jurisdiction over Conception Bay in 
Newfoundland,’ which is of an average width of 15 miles; also over Bristol 
Channel,° an arm of the sea about 80 miles long and from 5 to 45 miles wide.¢ 
France claims the Bay of Cancale, which is 17 miles wide, and also a large portion 
of Granville Bay. Other territorial bays in Europe are: White Sea in Russia, 
Zuider Zee in Holland, and the Frisches Haff, the Kurisches Haff, Bay of Stettin, 
a Wharton, Digest of International Law, 2d ed., sec. 27 and 28. 
b Direct United States Cable Company v. Anglo-American Telegraph Company (1877), L. R. 1 
App. Cases, 394. 
¢ Queen v. Cunningham (1859), Bell’s Crown Cases, 86. 
4 See also page 136, with reference to her claim of jurisdiction over Moray Firth, which is about 85 
miles across at the mouth. 
