Notes. 
foot the wide expanse of level sauds, which at low water makes it 
possible to pass almost dry-shod from Skerries beach to the tidal island, 
known as vShennick's Island. Far out near the water's edge a straggling 
troop of Herring Gulls on the wing flapped to and fro a few yards above 
the sands, on the look-out for toothsome jetsam. As we drew near one 
of the birds was seen to swoop down, lift something, apparently a large 
shell, from near the tide margin, and mounting rapidly almost straight 
upwards for about 50 feet, let the object fall to the ground. The action 
struck us all as peculiar, and we approached to have a clearer view. As 
we did so the bird swooped down rapidly, seized the shell again ; we 
were near enough now to see that it was a large univalve shell, apparently 
a great whelk {Biucintun nndatuni), and mounting rapidly a second time into 
the air to an obviously greater height than on the first occasion, 
suddenly let his burden fall to the ground a second time. When we saw 
the bird thus repeat his peculiar action we felt strongly tempted to set it 
down as intentional, as designed, in fact, to dislodge the body of the 
whelk either by fracturing the shell or loosening the animal's hold. 
We approached more rapidly the scene of operations, and as we did so 
the gull swooped down again, lifted the shell (we were now sure 
of its being a whelk) for the third time, mounted straight up with it, 
and, as it seemed to us, to a still greater elevation than before, and for 
the third time released the shell. 
There was hardly any doubt in my mind now as to the nature of the 
gull's action. Nevertheless I hastened towards the water's edge, thinking 
to capture the shell, and make sure that it contained the animal. But I was 
too late. The gull swooped down a fourth time, snatched up the shell once 
more, and swept off with it in an almost horizontal path to the distant 
rocks of Shennick's Island. Though I failed to capture the shell it may 
be fairly assumed that it did contain the animal. A full grown Herring 
Gull is not likely to play with an empty shell as an imaginative young 
terrier sports with a make-believe rat in the shape of a rag or a rope's- 
end. 
There are three theories admissible as to the nature of the bird's 
action on this occasion: (i) The release of the whelk in mid-air was 
involuntary or accidental, (2) it was instinctive, or, to avoid the use of 
that ambiguous word, was part of the traditional wisdom of the species 
Za;7/i commonly called Herring Gull, and (3) it was reasonable, 
i.e., founded on this particular gull's deduction from his own personal 
experience in dealing with refractory whelks. 
To a sceptic in the matter of animal sagacity the first theory 
would seem the most acceptable. The whelk, he would say, was too 
heavy for the bird or too awkward in shape to be firmly grasped by its 
bill, or the bird was frightened b}' the advent of that hostile species^ 
Homo sapiens, or was attacked or threatened by its comrades, so that for 
one or other of these reasons the release of the vsliell Avas in- 
voluntary. And, he would add, the increasing height of each successive 
upward flight was probably imaginary, or if real was undesigned on the 
