"ARTICLE VI.

"The printed Case of each of the two Parties, accompanied by the documents, the official correspondence, and other evidence on which each relies, shall 5 be delivered in duplicate to each of the Arbitrators and to the Agent of the other Party as soon as may be after the appointment of the members of the Tribunal, but within a period not exceeding eight months from the date of the exchange of the ratifications of this 10 Treaty.

"ARTICLE VII.

"Within four months after the delivery on both sides of the printed Case, either Party may in like manner deliver in duplicate to each of the said Arbitrators, and 15 to the Agent of the other Party, a Counter-Case, and additional documents, correspondence, and evidence, in reply to the Case, documents, correspondence, and evidence so presented by the other Party.

"If in the case submitted to the Arbitrators either 20 Party shall have specified or alluded to any report or

document in its own exclusive possession, without annexing a copy, such Party shall be bound, if the other Party thinks proper to apply for it, to furnish that Party with a copy thereof, and either Party may 25 call upon the other, through the Arbitrators, to produce the originals or certified copies of any papers adduced as evidence, giving in each instance notice thereof within thirty days after delivery of the case, and the original or copy so requested shall be delivered as soon 30 as may be, and within a period not exceeding forty days after receipt of notice.

"ARTICLE VIII.

"It shall be the duty of the Agent of each Party, within three months after the expiration of the time 35 limited for the delivery of the Counter-Case on both sides, to deliver in duplicate to each of the said Arbitrators, and to the Agent of the other Party, a printed argument showing the points, and referring to the evidence upon which his Government relies, and 40 either Party may also support the same before the Arbitrators by oral argument of counsel; and the Arbitrators may, if they desire further elucidation with regard to any point, require a written or printed statement or argument, or oral argument by counsel 45 upon it; but in such case the other Party shall be entitled to reply either orally or in writing, as the case may be.

"ARTICLE IX.

"The Arbitrators may, for any cause deemed by 50 them sufficient, enlarge either of the periods fixed by Articles VI, VII, and VIII by the allowance of thirty days additional.

CHAPTER I.

INTRODUCTORY STATEMENT.

(a.)-Geographical.

GUIANA, as understood by historians and geo5 graphers, comprises the territory bounded by the Orinoco, the Cassiquiare, the Rio Negro, the Amazon, and the Atlantic Ocean, whence it was often spoken of as the Island of Guiana. The greater part of the territory of the United States 10 of Venezuela lies to the north of the Orinoco, and is consequently not in Guiana.

The controversy is as to the dividing-line between the Colony of British Guiana and that part of the United States of Venezuela which lies 15 to the south of the Orinoco.

The British contention is that British Guiana is bounded by a line commencing at the mouth of the Amakuru River, following the course of that river to the Imataka moun20 tains, and thence following the watershed between the tributaries of the Orinoco and those of the Cuyuni and Massaruni to Mount Roraima, on the frontier of Brazil.

Recognizing, however, the the fact of the 25 establishment of Spanish Missions during the eighteenth century on territory south of the Orinoco, in the neighbourhood of the River Yuruari, which Missions continued to exist up to the year 1817, the Government of Great Britain 30 has never actively sought to press its claim to that portion of the district north-west of the Cuyuni, in which missions were actually situated.

The Venezuelan contention is that the boundary of British Guiana must be drawn along 35 the west bank of the estuary of the Essequibo

from the sea to the junction of the Cuyuni with the Essequibo, thence along the east bank of the Essequibo to a point in the neighbourhood of its confluence with the Rupununi, thence following 40 the watershed, between the Essequibo and the Berbice and Corentin, till it meets the frontier of Brazil.

The Government of Venezuela has, however, on occasion, modified its pretensions as regards

Guiana.

British Contention.

Venezuelan Contention.

Rivers and Settlements.

the district immediately to the west of the estuary
of the Essequibo, and claimed only that the
boundary should run from the neighbourhood of
the mouth of the Moruka southwards to the
Cuyuni, near its junction with the Massaruni, 5
and then as stated above.

As regards the western boundary of British Guiana from Mount Roraima southward, as shown upon the Map in the Atlas accompanying this Atlas, p. 4. Case, there are questions still outstanding between 10 Great Britain and Brazil, as well as between Great Britain and Venezuela.

Upon the coast of Guiana from the Amazon to the Orinoco are found the mouths of numerous rivers, which, owing to the denseness of the 15 forests, and the marshy nature of the coast, afforded the only means of entering and traversing the country. Every settlement made upon that coast was placed upon one of these rivers, and was, with its district, named after that 20 river, as, for instance, Surinam, now Dutch Guiana, and Berbice, Demerara, and Essequibo, the districts which now together form British Guiana.

Similarly, the different districts within the settlements were often described by the names 25 of rivers or creeks which traversed them. Thus the word Cuyuni is constantly used of the district watered by that river and its tributaries: and the word Barima does not necessarily indicate either Point Barima or the river of 30 that name, but usually means the district on either bank of the river stretching to the Amakuru on the one side and to the Waini on the other.

The Colonies of Essequibo and Demerara were 35 in Dutch times distinct from Berbice: that of Essequibo was for a long period the chief settlement, and besides besides the district of the Essequibo and its tributaries included the rivers and districts of Pomeroon, Waini, and 40 Barima on the west. Subsequently Demerara became the leading settlement and the seat of the Colonial Government has been at Georgetown in Demerara, Essequibo becoming the name of a county which included all the territory 45 to the west of the Boerasirie Creek.

The territory more immediately under discussion which lies between the Orinoco and the Essequibo is traversed by numerous rivers, of which the principal are, in the interior, the

Rupununi, Massaruni, and Cuyuni, tributaries of the Essequibo, and, on the coast, proceeding from east to west, the Pomeroon, the Moruka, the Waini, the Barima, and the Amakuru, which 5 flow direct to the Atlantic.

The delta of the Orinoco lies between the River Vagre on the west and the main stream of the Orinoco on the east. The low land on the coast to the east of the Orinoco has no connec10 tion with the Orinoco delta, having been formed by the detritus brought down by the rivers to the eastward of the Orinoco, and carried westward under the influence of the westerly current and the prevailing wind on that coast.

15

The Cuyuni, which is one of the principal tributaries of the Essequibo, receives in its upper reaches on its left bank two important tribu. taries, the Curumo and the Uruan; the latter is joined not far above its confluence with the 20 Cuyuni by another stream of almost equal magnitude, the Yuruari.

In the territory of Venezuela to the westward of the territory now in dispute there are several rivers which flow to the Orinoco, the most 25 important of which is the Caroni; and there are other smaller tributaries between the Caroni and the mouth of the Orinoco, the chief of which are the Imataka and the Aguirre.

The basin of the Essequibo* and its tributaries 30 is divided from that of the Caroni and Orinoco by a range of hills which runs past Upata and joins the Imataka range.

The interior of the country westward of the Essequibo is covered with thick forests stretch35 ing almost without a break from the sea to the Imataka mountains, and filling the whole valley of the Cuyuni. But if the course of the Curumo and Yuruari be followed upwards from the Cuyuni, it is found that as the ground rises towards the 40 water-shed the forest is replaced at some distance from the Cuyuni by open plateaus called savannahs, which were formerly known under the collective name of the Pariacot Savannah.

The natural, and until recent years the only, 45 route of communication through the belt of forest between the Pariacot Savannah and the River Cuyuni was by the Rivers Uruan and Yuruari or by the Curumo, which were impassable for

Throughout this Case the expression "basin of the Essequibo" is used to include the basins of the Essequibo, Massaruni, and Cuyuni, as well as the other tributaries of the Essequibo.

Forests and Savannahs.