958 NORTH ATLANTIC COAST FISHERIES ARBITRATION. 



that when they made that difference between Labrador and the other 

 parts, and used the word " coast " in both, that they intended clearly 

 to make the difference which appears on the face of the document 

 between Labrador and the other parts. And it would not be compe- 

 tent to go outside of the plain terms of the document itself, to give it 

 a different meaning from that which appears on the face of it. 



But, of course, Mr. President, the United States come before this 

 Tribunal for an interpretation of this treaty without being technically 

 or otherwise bound by the strict rules of procedure or the strict laws 

 of evidence of any particular country. And therefore both parties 

 have already in their Arguments and in their Cases gone outside of 

 the terms of the treaty itself, and looked at the surrounding facts and 

 circumstances existing at the time that were within the contempla- 

 tion or knowledge or cognizance of the negotiators of the treaty, in 

 order to make clear what was the real intention of the parties as 

 expressed in those words. 



THE PRESIDENT : Permit me, Sir James, to ask a question : Does it 

 not make, perhaps, a difference in the signification of the word 

 " coast," whether the word " coasts " is used in the plural, and is used 

 in contradistinction to " bays and harbors and creeks " which are fol- 

 lowing ; or whether the word " coast " is used in the singular, and the 

 expression is not only coasts, but " that part of the southern coast of 

 Newfoundland " which extends from a certain cape to another cape ? 



SIB JAMES WINTER: Yes. 



THE PRESIDENT : Is there not a difference in the signification of the 

 word "coasts" in the plural and this word "coast" in the singular 

 if it is only applied to certain geographically determined points, 

 within certain geographically determined limits? 



SIR JAMES WINTER: We say not; our contention is that there is 

 not ; that it makes no difference ; that it is immaterial ; that the word 



" coast " means the same thing in both places. 



574 THE PRESIDENT : Yes, but then would you have the kindness 

 to look at the next part of article 1 of the treaty of 1818. 

 There you find the words : "And also on the coasts, bays, harbours, 

 and creeks, from Mount Joli, on the southern coast of Labrador 

 . . . . " Here you have in the same phrase the word " coasts " in the 

 plural and in the singular. First it is said "on the coasts," and 

 these "coasts bays, harbours, and creeks," are here considered. It 

 seems you. could interpret that sentence in that sense, as if those 

 '" coasts, bays, harbours and creeks " would have been considered as 

 a part of the coast; and that would perhaps lead to a distinction, 

 coast in the singular embracing the whole, and "coasts," in the 

 plural in contradistinction to the bays and the creeks and the har- 

 bours. Would one not come then to a distinction between "coast" 

 in the singular, embracing the whole extention of the coast, and 



