322 ORAL ARGUMENT OF FREDERICK R. COUDERT, ESQ. 



thrown it into the water, and have seen it swim about like a yonucj dofj. I have 

 seen it keeji afloat for fifteen minutes, as loufj as the vessel was within sight. On 

 the islands the mother seal will take the young and force them into the water to 

 teach them to swim. They will never take the water freely themselves for from six 

 weeks to two mouths. 



It is only due to say that here is something that purports to be evi- 

 dence. Whether our friends will consider it evidence or not, I do not 

 know. They offer it to us as evidence, but I do not think they will 

 rely upon it. In case they omit it, I will read it, and your Honors will 

 determine whether this was meant seriously, or whether as a sample of 

 grim humor. I am reading from the Appendix to the Counter Case of 

 Her Majesty's Government, volume 2, page 87. 



Here is a gentleman who has been seal hunting for 6 years. He was 

 a resident of the city of Victoria, and he says : 



New born pnps swim if thrown into the water. I remember one that I took from 

 a cow and threw overboard that swam after our boat for over an hour. It, however, 

 made so much noise that I caught it again and killed it, as it interfered with our 

 hunting. 



I make no comment upon that; I simply read it. We also assert as 

 a fact that the pup during the first few months of its life, is dependent 

 on the milk of the female for its sustenance, and this will be directly 

 in the range of the enquiry put by the President of the learned Tribu- 

 nal as to the weaning of the pup. The United States Case, pp. 106 and 

 107 says: 



After learning to swim the pup spends its time on land and in the water, but the 

 greater portion is passed on land, nntil its iinal departure, which takes place, gen- 

 erally about the middle of November, but the time depends a great deal upon the 

 weather. 



In fact, I may say that seals have been known to remain in very mild 

 seasons all through the winter, as I think our testimony wall show. It 

 is evident that they are only driven away by the extreme cold and 

 the necessities of food, and their departure, like the departure of more 

 intelligent beings, depends on the i)eculiar conditions of each year. 

 When the season is very severe, they leave early; when the season is 

 favorable and mild, they leave late. 



During the entire time the pups remain upon the islands they are dependent solely 

 upon their mothers for sustenance. 



The importance of this consideration I need not press, in view of 

 what has already appeared in the Case as to the slaughtering of the 

 mother. 



Professor Dall says that the pups require the nourishment of their mothers for at 

 least three to four months after birth, and would perish if dejjrived of the same. 

 Others fix the period of weaning at at least four mouths. Others say that the female 

 seal suckles her young as long as it remains on the islands. All agree that without 

 this nourishment the pup would starve to death, and Dr. Hereford gives an account 

 of endeavouring to raise a motherless pup by hand, which resulted in its death. 



So that even with the utmost tenderness and care, even with the 

 greatest eftbrt, which, of course, cannot be given to a mass of young 

 seals, the seal perishes if the mother is killed. 



The importance of this question will now justify my reading a few 

 extracts from the testimony, and I shall read from our volume. Part 

 2nd. It is a collated supplement to the Argument as raised by the 

 subjects. I have selected some of the testimony, and although the 

 whole of it is interesting and should be read, and although I shall take 

 the liberty of asking the Court to examine it, yet I do not think I am 

 justified in occupying valuable time in reading it all myself, and I shall 



