198 ORAL ARGUMENT OF JAMES C. CARTER, ESQ. 



appreciable dimimition in its normal numbers. It is far less expensive than any 

 other mode of slaughter, and furnishes the skins to the markets of the world in the 

 best condition. 



That fact is of course incontestable. The expense of killing seals 

 upon land, where they may be put to death at the rate of 1,000 daily, 

 must be much less than where it is necessary to fit out vessels with 

 appliances and send them on distant voyages. And it furnishes the 

 seals to the markets in the best condition. The difference is indeed 

 very substantial, for the sealskins from the Pribilof Islands are held at 

 a much higher price. I ijroceed with the statement: 



The killing at these islands, since the occupation by the United States, has been 

 restricted in the manner above indicated. It has been the constant endeavor of the 

 United States to carefully cherish the seals and to make no draft except from the 

 normal and regular increase of the herd. If there has at any time been any failure 

 in carrying out such intention, it has been from some failure to carry out instruc- 

 tions, or want of knowledge respecting the condition of the herd. The United 

 States are under the unopposed influence of the strongest motive, that of self- 

 interest, to so deal with the herd as to maintain its numbers at the highest possible 

 point. The annual draft made at the islands since the occupation of the United 

 States has been until a recent period about 100,000. This draft would be in no way 

 excessive were it the only one made upon the herd by man. 



Now I have said that if the killing by the United States has not 

 been confined to this number, it is on account of some failure to carry 

 out instructions at the islaiuls, or from want of proper knowledge 

 respecting the actual condition of the herd. The United States lessees 

 carry on their enterprise under the influence of the strongest possible 

 motive, that of self-interest. It is to their interest to prevent any 

 diminution of the herd. Of course it is only the plainest of fools who 

 kills the goose that lays the golden eggs. Here is a property the 

 annual income of which is very large, and that annual income can be 

 made i^ermanent, but only on condition that the normal numbers of 

 the herd are maintained. It is therefore the interest of the United 

 States Government to prevent the taking of excessive drafts. It is a 

 question of self interest — of that interest which operates most strongly 

 upon the minds of men. What is the interest of the United States is 

 also the interest of the lessees themselves. The United States Gov- 

 ernment has adoi)ted the policy of leasing out these islands for a long 

 term — twenty years — and the lessees pay a considerable gross sum for 

 the privilege. It is therefore to their interest to keep the herd at its 

 highest remunerative strength. I proceed: 



Seventh, Pelagic sealing has three inseparable incidents: 



(1) The killing can not be contined to males; and such are the greater facilities 

 for taking females that they comprise three-fourths of the whole catch. 



(2) Many seals are killed, or fatally wounded, which are not recovered. At least 

 one-fourth as many as are recovered are thus lost. 



(3) A large proportion of the females killed are either heavy with young, or have 

 nursing pups on the shore. The evidence upon these point is fully discussed in the 

 Appendix. 



Eighth. Pelagic sealing is, therefore, by its nature, destructive of the stoclc. It 

 cannot be carried on at all without encroaching, ^ro tanto, upon the normal numbers 

 of the herd, and, if prosecuted to any considerable extent, will lead to such an 

 extermination as will render the seal no longer a source of utility to man. 



There can be no discrimination exercised in pelagic sealing. Every 

 seal that is found is killed, and no distinction of sex can be observed; 

 and, in point of fact, the amount of the catch is, as we maintain, three- 

 fourths females. Now the evidence upon that point will be more fully 

 discussed by my brother Coudert. I have time only to call the attention 

 of the Tribunal to some leading features. In the first place, to what 

 we should supi)ose to be true from the probabilities of the case. Here 

 is a herd of seals — animals which from their nature are highly polyg- 



