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PROCEEDINGS

OF THE

TRIBUNAL OF ARBITRATION,

CONVENED AT PARIS

UNDER THE

TREATY BETWEEN THE UNITED STATES OF AMERICA AND GREAT

BRITAIN CONCLUDED AT WASHINGTON FEBRUARY 29, 1892,

FOR THE

DETERMINATION OF QUESTIONS BETWEEN THE TWO GOV.
ERNMENTS CONCERNING THE JURISDICTIONAL

RIGHTS OF THE UNITED STATES

IN THE

WATERS OF BERING SEA

VOLUME IV.

WASHINGTON:

GOVERNMENT PRINTING OFFICE.

ON THE PART OF THE

GOVERNMENT OF HER BRITANIMOOT COURT.

AJESTY
TRIBUNAL OF ARBITRATI

TO THE

CONSTITUTED

UNDER ARTICLE I OF THE TREATY CONCLUDED AT WASHINGTON

ON THE 29TH FEBRUARY, 1892,

BETWEEN

HER BRITANNIC MAJESTY AND THE UNITED STATES OF AMERICA.

WASHINGTON:

GOVERNMENT PRINTING OFFICE.

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GENERAL CONTENTS.

The case now submitted to the Arbitrators on the part of the Gov.
ernment of Her Britannic Majesty contains a statement of the facts
which that Government considers to be material to enable the Arbi.
trators to arrive at a just conclusion upon the points submitted to them
by the Treaty of Arbitration.

It contains also some general propositions which that Government
believes to be in accordance with the established principles of Inter-
pational Law, and upon which it intends to rely.
The case is arranged as follows:

Pages.

Introductory Statement and Outline of Argument..

1-9

Arrangement of Case and Heads of Argument..

9-12

Chapter 1, Head A: The User, up to the year 1821, of the Waters of Behr-

ing Sea and other Waters of the North Pacific..

13-36

Chapter II, Head B: The Ukase of 1821, and the circumstances connected

therewith leading np to the Treaties of 1824 and 1825..

37-58

Chapter III, Head C: The question whether the body of Water now known

as Behring Sea is included in the phrase “Pacific Ocean," as used in, the

Treaty of 1825 between Great Britain and Russia..

59–76

Chapter IV, Head D: The User of the Waters in question from 1821 to 1867. 77-90

Chapter V, Head E: What rights passed to the United States under the

Treaty of 30th March, 1867.

91-102

Chapter VI, Head F: The action of the United States and Russia from 1867

to 1886

103-120

Chapter VII, Head G: Various contentions of the United States since the

121-134

Chapter VIII. Has the United States any right, and, if so, what right, of

protection or property in the fur seals frequenting the Islands of the
United States in Behring Sea when such seals are found outside the ordi-

nary 3-mile limit?

135-140

Chapter IX. General Conclusions upon the whole Case

141-157

Chapter X. Recapitulation of Argument

158-160

Conclusion

161

Schedule of Claims: Statement of claims for compensation from the United

States' Government on account of the seizures of British Canadian Sealers
in the Behring Sea during the years 1886, 1887, 1889, and 1890.

The appendix to the case consists of four volumes, the contents of

which are as follows:

Vol. I. Miscellaneous documents quoted in the case.

Vol. II, Part 1. Selections from correspondence between Great Britain and Russia,

1821-1825.

Part 2. Selections from correspondence between the United States and Rus-

sia, 1822-1887.
Part 3. Treaties : Russia and United States, 1824; Great Britain and Russia,

1825; Russia and United States, 1867.
Vol. III. Correspondence respecting the Behring Sea seal fisheries. Papers presented

to the British Parliament. Treaty and convention between Great Britain

and the United States of February 29 and April 18, 1892.
Vol. IV, Part 1. Map of the northwest coasts of America and the Aleutian and Kurile

islands, published in the quartermaster-general's department, St. Peters-

burg, 1872.
Part 2. Map of the northern portion of the North Pacific Ocean.

year 1886

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