THE date at which the Memorial of the United S Government in the Webster claim reached His Maj Government has rendered it necessary to prepare Answer without obtaining the observations of the Zealand Government.

The Memoranda by the Solicitor-General for Zealand were prepared in 1913 before the receipt o Memorial.

His Majesty's Government may therefore fin necessary to file a supplementary Answer containing observations which the New Zealand Government con should be laid before the Tribunal.

WILLIAM WEBSTER.

States ajesty's re this he New

or New

of the

find it

ing any consider

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ANSWER OF HIS MAJESTY'S GOVERNI

THE claim submitted to the Tribunal by States Government on behalf of the repre William Webster is "for damages resulting fro "of title to and loss of possession of certain 1 "Zealand as the direct consequence of the "and unjustifiable acts of the British authori

annexation of the islands."* Claims for com made in respect of six such tracts of land, and different considerations apply to these six cla dealt with separately at a later stage of this general statement, however, dealing with the nature of the Webster claim is indispensable.

New Zealand was annexed by Great Brit it was not until more than forty years la Government of the United States approached E Government on the subject of any claims United States citizens in respect of lands clai in New Zealand. On the 19th March, 1887 then United States Chargé d'Affaires in Londe to Lord Salisbury a copy of a Resolution p Senate on the 28th February in that year. this Resolution will be found in Mr. Bayard's the President of the 4th January, 1888.† mention of Webster, but requests the Presi copies or full statements of all the proce "Government of New Zealand and of any la

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or board or other lawful authority that has decided 66 or that has pending before the same, any matter r "to the validity of the titles to any lands that are "been claimed by American citizens in the islands o "Zealand under grants or deeds made by the chiefs

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C

ruling powers in said islands prior to the date exercise of sovereignty over them by Great Britain It was only through the other papers contain Mr. White's note that Her Majesty's Government 1 that it was the claims of Webster which had led Resolution of the Senate on the 28th February, 1887 enclosure in Mr. White's note which gave this infor was a copy of the "Morgan Report" (the Senate I No. 1736, 49th Congress, second session), which is at p. 227 of the Memorial. The attention of the Tr will be called at a later stage of this Answer to the co of this Report and to the violence of its language and charges against Her Majesty's Government. If it anything approaching a true picture of Webster's ment, it is astonishing that the United States Gover should have allowed more than forty years to elapse making any representations to Her Majesty's Goveron the subject.

The claim as now submitted to the Tribunal considerably both as to the acreage of land of whic alleged Webster was despoiled, and as to the amo compensation claimed, from that which was brought notice of Her Majesty's Government on previous occa It is also put forward on different grounds.

Up till now the basis of the claim has usually bee the New Zealand authorities seized and sold the which Webster had purchased from the chiefs befo annexation.* In 1890 the State Department Memora formulates the claim somewhat differently:

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"In consequence of the annexation of by Great Britain and of the land ordinance enforced Mr. Webster was prohibited fr conveying or completing title to any of th he had purchased."*

His Majesty's Government do not feel that the United States Government do not maintain that the Government of New Zeala sold Webster's lands, for there is a paragrap the Memorial which says that the "Gover "United States contends that the seizure and by the British authorities in New Zeal acquired by Webster . . . . was an unj "wrongful act ", but as no specific all such sale is made in respect of any of the six cl ferred it is assumed that the claim is now bas the "denial of title and loss of possession the opening sentence of the Memorial.†

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