Overview of the 27th Amendment

Review of the 27th Amendment Taking about 203 years and the endeavors of an undergrad to at long last win sanction, the 27th Amendment has probably the most abnormal history of any correction at any point made to the U.S. Constitution. The 27th Amendment necessitates that any increments or diminishes in the base compensation paid to individuals from Congress may not produce results until the following term of office for the U.S. delegates starts. This implies another congressional general political decision more likely than not been held before the salary increase or cut can produce results. The purpose of the Amendment is to keep Congress from allowing itself quick increases in salary. The total content of the 27th Amendment states: â€Å"No law, differing the pay for the administrations of the Senators and Representatives, will produce results, until an appointment of delegates will have intervened.† Note that individuals from Congress are likewise legitimately qualified to get a similar yearly average cost for basic items change (COLA) raise given to other government representatives. The 27th Amendment doesn't make a difference to these alterations. The COLA raises produce results consequently on January 1 of every year except if Congress, through the entry of a joint goals, votes to decrease them - as it has done since 2009. While the 27th Amendment is the Constitution’s most as of late embraced alteration, it is additionally one of the initial ones proposed. History of the 27th Amendment As it is today, congressional compensation was a fervently discussed point in 1787 during the Constitutional Convention in Philadelphia. Benjamin Franklin restricted paying congress individuals any pay whatsoever. Doing as such, Franklin contended, would bring about agents looking for office just to promote their â€Å"selfish pursuits.† However, a greater part of representatives dissented; calling attention to that Franklin’s payless arrangement would bring about a Congress made up just of well off individuals who could manage the cost of holding government workplaces. All things considered, Franklin’s remarks moved the agents to search for an approach to ensure individuals didn't look for open office basically as an approach to stuff their wallets.â The agents reviewed their contempt for an element of the English government called â€Å"placemen.† Placemen were situated individuals from Parliament who were selected by the King to all the while serve in generously compensated managerial workplaces like presidential bureau secretaries essentially to purchase their good votes in Parliament. To forestall placemen in America, the Framers incorporated the Incompatibility Clause of Article I, Section 6 of the Constitution. Called the â€Å"Cornerstone of the Constitution† by the Framers, the Incompatibility Clause expresses that â€Å"no Person holding any Office under the United States, will be a Member of either House during his Continuance in Office.† Fine, yet to the subject of how much individuals from Congress would be paid, the Constitution states just that their compensations ought to be as â€Å"ascertained by Law† - which means Congress would set its own compensation. To a large portion of the American individuals and particularly to James Madison, that seemed like an impractical notion. Enter the Bill of Rights In 1789, Madison, to a great extent to address the worries of the Anti-Federalists, proposed the 12 - instead of 10 - corrections that would turn into the Bill of Rights when endorsed in 1791. One of the two corrections not effectively approved at the time would in the end become the 27th Amendment. While Madison didn't need Congress to have the ability to give itself raises, he additionally felt that giving the president a one-sided capacity to set congressional pay rates would give the official branch a lot of authority over the administrative branch to be in the soul of the arrangement of â€Å"separation of powers† epitomized all through the Constitution.â Rather, Madison recommended that the proposed revision necessitate that a congressional political decision needed to happen before any boost in salary could produce results. That way, he contended, if the individuals felt the raise was excessively enormous, they could cast a ballot â€Å"the rascals† out of office when they ran for re-appointment. The Epic Ratification of the 27th Amendment On September 25, 1789, what might a lot later become the 27th Amendment was recorded as the second of 12 revisions sent to the states for confirmation. After fifteen months, when 10 of the 12 alterations had been confirmed to turn into the Bill of Rights, the future 27th Amendment was not among them. When the Bill of Rights was endorsed in 1791, just six states had confirmed the congressional compensation revision. Be that as it may, when the First Congress passed the Amendment in 1789, officials had not determined a period limit inside which the Amendment must be sanctioned by the states. By 1979 - after 188 years - just 10 of the 38 states required had sanctioned the 27th Amendment. Understudy to the Rescue Similarly as the 27th Amendment seemed bound to turn out to be minimal in excess of a commentary in history books, along came Gregory Watson, a sophomore understudy at the University of Texas in Austin. In 1982, Watson was allocated to compose a paper on government forms. Looking into established changes that had not been confirmed; he composed his exposition on the congressional compensation correction. Watson contended that since Congress had not set a period limit in 1789, it not exclusively could however ought to be endorsed now. Sadly for Watson, yet luckily for the 27th Amendment, he was given a C on his paper. After his interests to get the evaluation raised were dismissed, Watson chose to take his intrigue to the American individuals in a major manner. Met by NPR in 2017 Watson expressed, â€Å"I thought at that moment, ‘I’m going to get that thing ratified.’† Watson began by sending letters to state and government administrators, a large portion of who just documented. The one special case was U.S. Congressperson William Cohen who persuaded his home territory of Maine to endorse the change in 1983. Driven to a great extent by the public’s disappointment with the exhibition of Congress contrasted with its quickly rising pay rates and advantages during the 1980s, the 27th Amendment confirmation development developed from a stream to a flood. During 1985 alone, five additional states confirmed it, and when Michigan endorsed it on May 7, 1992, the necessary 38 states had gone with the same pattern. The 27th Amendment was formally affirmed as an article of the U.S. Constitution on May 20, 1992 - a stunning 202 years, 7 months, and 10 days after the First Congress had proposed it. Impacts and Legacy of the 27th Amendment The long-overdue approval of an alteration keeping Congress from casting a ballot itself a prompt increase in salary stunned individuals from Congress and bewildered lawful researchers who addressed whether a proposition composed by James Madison could in any case become some portion of the Constitution almost 203 years after the fact. Throughout the years since its last sanction, the down to earth impact of the 27th Amendment has been insignificant. Congress has casted a ballot to dismiss its yearly programmed typical cost for basic items raise since 2009 and individuals realize that proposing a general salary increase would be politically damaging.â In that sense alone, the 27th Amendment speaks to a significant measure of the people’s report card on Congress as the centuries progressed. What's more, what of our saint, undergrad Gregory Watson? In 2017, the University of Texas perceived his place in history by finally raising the evaluation on his 35-year-old exposition from a C to an A.

What is The German Question? Essay -- Germany German Essays

What is â€Å"The German Question†? What is â€Å"The German Question†? This is an inquiry that has been presented by numerous investigators throughout the years, each having their own perspectives on what satisfies this inquiry. In any case, each concurs that it is an issue of high multifaceted nature. As indicated by Constantin Frantz, â€Å"The German Question is the most dark, generally included and most extensive issue in the entire of current history†. What makes Germanys’ question so hard to pinpoint is the way that for the entirety of its reality, until 1871 and again in 1990, it has attempted to bind together a country into a solitary state. As history appears, the German country has attempted to make its own country state. In contrast to France and Britain, Germany was a country before it was a state. That is, its kin had a solid feeling of patriotism and basic way of life as a social element yet they were deficient with regards to a solid state, or a type of political association that as serts the selective option to administer a particular bit of an area. As Dahrendorf states; â€Å"We need to discover what it is in German culture that may represent Germany’s steady inability to give a home to majority rule government in its liberal sense†. Yet, can we truly investigate the issue along these lines? It has not generally been the equivalent â€Å"persistent failure† thwarting Germany from giving a home for majority rule government, yet rather the issues looked by Germany since the beginning. To genuinely comprehend the German circumstance and its numerous battles for unification, it is imperative to know the historical backdrop of the current day Germany. This history is an extremely one of a kind one, one totally different from other European countries, for example, France and Britain. Along these lines one can draw sharp complexities between the procedure of national unification in Germany when contrasted with France or Britain. Be that as it may, when set up; â€Å"Compared with its chronicled forerunners in England and France, industrialization in Germany happened late, rapidly, and thoroughly†. Early German history can be followed back to the House of the Hohenzollern. A group of German rulers, beginning as a group of includes in Swabia in the eleventh or twelfth century. The Hohenzollerns managed Prussia and in the end joined together and governed Germany until the finish of World War I. Their solid, unbendingly taught armed forces gave Prussia a notoriety f or military greatness. During the sixteenth and seventeenth hundreds of years, regional rulers and city committees in Germany extended their ... ...have given some understanding on noting these two significant parts of â€Å"The German Question†. â€Å"When is Germany? Generally, over the most recent hundred years. Where is Germany? In all regions that had a place with Germany during this range of time.† I accept this is really the most significant part of the German Question given the countries’ steady battle for unification. Since Germany is at last rejoined it is on a straight track to the incredible nation it ought to be. Reference index Conradt, David P. The German Polity, Longman Publishing. New York, 2001. Dahrendorf, Ralf. Society and Democracy in Germany, Norton and Company. Lamborn and Lepgold, World Politics into the Twenty-First Century. Prentice Hall, Upper Saddle River. 2003 Microsoft Encarta Premium Online; Germany. Reference book Source. History of Germany. 2004. Niewyk, Donald. Talk Notes; Inside Nazi Germany. 2004 Rosinus, Franz. Meeting; Topics; German government, Helmut Kohl, ideological groups. 2004. Sax, Benjamin. Inside Hitler’s Germany. Heath and Company, Lexington Massachusetts. 1992. Walbruck, Harry A. Deutschland; Ein neuer Anfang. National Textbook Company, Lincolnwood, Illinois 1992.

Where Do You Start When Choosing the Best Argumentative Essay Topics?

Where Do You Start When Choosing the Best Argumentative Essay Topics?There are a lot of essay topics that you can choose from if you want to create some different and effective arguments to persuade your audience. But where do you start when it comes to essay topics?Before choosing an essay topic, you should have a good idea of what type of essay you would like to write. And you should know what you are trying to achieve with the essay topic. If you're aiming for a specific grade or goal, you will need to go with a topic that is appropriate.So how do you find good essay topics? The best thing you can do is ask for help from others who are already doing research on a particular topic. Sometimes, you may even be able to access their research material from their own websites. Or you can simply ask your fellow students or colleagues if they know of anyone that has written on the topic that interests you.As for academic essays, the only thing you need to make sure of is that you're well v ersed in the topic. Researching on the topic is one of the best ways to get an overview of the entire topic. And having a good overview of the topic is key when writing the essay.Once you know what you are writing about, then you will have a better idea of the details of the specific topic. Having a good outline of the topic is also key to get started. With the outline in hand, you will be able to focus on the things that you need to say in order to make the best argumentative essay.How do you go about choosing a good topic? For most people, the main thing they look for is something interesting. But the most important thing you have to do is to choose a topic that you will find interesting. Another thing you have to do is to narrow down the scope of the topic. Don't worry if the topic is a bit outside of your expertise, just focus on the most important issues that you want to include in your essay.You don't have to be a professional writer to get started when choosing a topic. There are many online resources available that will help you get started when it comes to essay topics.

The Issue Of Public Health - 1622 Words

Summary The term â€Å"Public Health† describes how a society strives to keep the conditions of the public to be healthy to all individuals. The healthcare industry continues to change for the good of society, although the pedagogy in the universities that teaches our future healthcare professionals are lagging in their changes to the curriculum. There is a need to change our public health major to a population health major. Population health is not just policies and programs to keep public society healthy, it is an approach that looks at all the factors that can influence healthy individuals over the course of their lives. There are many benefits to this change. Students of University of Arkansas will benefit because this change will give our undergraduates the advantage to compete for the best healthcare careers in the industry. The University benefits are the promise of attracting more healthcare degree sought students and the potential to work together with healthcare busines ses to shape the curriculum so that it is exactly what is needed. This change will cost the university professor’s time and research but the future outcome is notably leading the healthcare education in the right direction. Introduction The Public Health’s program of study should be expanded because the landscape of healthcare has changed. My proposal is to change the curriculum and title to Population Health to better equip students with the knowledge about current issues facing health within theShow MoreRelatedThe Issue of Public Health835 Words   |  3 Pages1) How is public health financed in your state, province, or country? How does the current budget crisis impact Public Health and Community services in your area? The issue of public health and its subsequent impact on society as a whole is becoming a very contentious issues for government. In the midst of an election year, public health issues such as Medicare, social security, and disease prevention are all becoming more prevalent. In the state of New Jersey, public health is no different inRead MoreThe Controversial Issue Of Public Health Issue725 Words   |  3 PagesProf: Dr. Praphul Joshi 10/23/2013 Controversial Public Health Issue There are several controversial issues confronting us today; from Universal Healthcare (Obama Care) to Stem Cell research, to vaccinations, to genetically engineered (GE)/genetically modified (GM) foods. However, I shall look at genetically modified foods as the controversial issue for this article. I shall look at an article from the mass media about this controversial public health issue and place emphasis on the message the documentRead MoreHealth Issues Of The Public Health Field857 Words   |  4 PagesIt is a matter of fact that women in the past and the recent present have had many public health issues that were hard on them, and they had to deal with these problems more than men did. However, they have overcome some of these issues, but there are still issues in the public health’s area women are still dealing with. Unfortunately, women’s issues were only mentioned if they had to do with maternity c are only, and rather than that they were ignored. Anything beyond maternity care was not on theRead MorePublic Health And Health Promotion Issues2662 Words   |  11 Pagesin the context of the nurse-patient relationship (Naidoo and Wills, 2000) Public health is a pro-active field of medicine that is concerned primarily with improving the health of populations rather than just the health of individuals. The challenge of maintaining the health of populations is the responsibility of health care professionals and the optimal use of available resources can assure overall improvement in health promotion within a population. This essay will explore and critically analyseRead MoreHealth Care Is A Public Health Issue1327 Words   |  6 PagesHealth care is a public health issue that continues to trouble different countries yearly. There is always a debate on whether health care is a human right issue or if it is just a luxury. 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Following a careful review of the literature surrounding this issue, the possible reasons for and implications of having a large percentage of the population who remains unvaccinated are discussed. Possible interventions and purposed interventions for resolution of this problem are discussed and conclusions are drawn based on what it learned from the literature. Keywords: controversy, vaccinationsRead MoreDepression As Public Health Issue2353 Words   |  10 PagesDepression as Public Health Issue Mental Health Statistics show that at some point in our lives, 1 in 4 people will experience some kind of mental health problem. With Anxiety and Depression being the most commonly diagnosed forms of mental illness, current thinking shows that tackling this problem head on, by addressing depression through treatment in clinical practice but also in the wider community as a major public health concern. (Mental Health Foundation , 2014) To combat this overwhelmingRead MorePublic Health Issue: Smoking2002 Words   |  9 PagesPublic Health Issue: Smoking This essay is aimed to explore, analyse and discuss smoking in adults. Smoking is a public health issue as such is one of the major contributors to high mortality and ill-health in the adults which is preventable (Health and Excellence Care (NICE) (2012). The United Kingdom (UK) is known to have the highest number of people with a history of smoking among people with low socio-economic status (Scriven and Garman, 2006; Goddard and Green, 2005). Smoking is considered

Criminal Activity and Charles Dickens - 1381 Words

Criminal Activity and Charles Dickens Great Expectations, like the majority of Charles Dickens fiction, contains several autobiographical connotations that demonstrate the authors keen observational talents. Pip, the novels protagonist, reflects Dickens painful childhood memories of poverty and an imprisoned father. According to Robert Coles, there was in this greatest of storytellers an unyielding attachment of sorts to his early social and moral experiences (566). Complementing Dickens childhood memories of crime and poverty was his legal training, reflected in the characterizations of lawyers and the abundance of criminal activity that hovers around the world of Great Expectations. Charles Dickens†¦show more content†¦Jaggers at it (195; ch. 24). Pip describes his guardian as a man who: . . . was striking (the witness), and the bench, and everybody present, with awe. If anybody, of whatsoever degree, said a word that he didnt approve of, he instantly required to have it taken down. If anybody wouldnt make an admission, he said. Ill have it out of you! and if anybody made an admission, he said, Now I have got you! The magistrates shivered under a single bite of his finger. Thieves and thief-takers hung in dread rapture on his words, and shrank when a hair of his eyebrows turned in their direction. . . . [H]e was making the legs of the old gentleman who presided, quite convulsive under the table, by his denunciations of his conduct as the representative of British law and justice in that chair that day. (195-96; ch. 24) Holdsworth mentions that passages such as these are a very valuable addition to our authorities, since they give us information we can get nowhere else and were painted by a man with extraordinary powers of observation, who had first hand knowledge (Collins 175). Taking his extraordinary powers of observation into consideration, it is no surprise that Dickens spent part of his early career as a journalist. 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The protagonist of this eventful and heart wrenching story, Oliver Twist, is a naive young man who endures intense abuse and starvation in Victorian England’s workhouses. He keeps his hopes high and has a turn-around from his past life of misery. During this morose experience, Oliver sees the realization of Victorian EnglandRead MoreChild Exploitation During The Victorian Era1583 Words   |  7 PagesEnglish novelist Charles Dickens was born into an underprivileged family during the Victorian Era. His father was jailed and Dickens was sent to work in a factory at the age of twelve (Dutta 1). It can be deduced because of Dickens’s formative years, one much like Oliver’s from Oliver Twist, Dickens felt the need to criticize the conditions of his time period (Diniejko). The novel is well known for being about an orphaned child who starts his life in an orphanage workhouse, gets invol ved in aRead MoreOliver Twist Characterization of the Criminal Mind In Charles Dickens novel, Oliver Twist,1600 Words   |  7 PagesOliver Twist Characterization of the Criminal Mind In Charles Dickens novel, Oliver Twist, Dickens portrays the hardships of people in poverty during the Victorian era through Oliver and various characters throughout the novel. Oliver is born into a workhouse with no name where he is starved, beaten, and treated like a prisoner during the first ten years of his life. Dickens makes all his characters in the novel â€Å"†¦either a jailor or a prisoner, like Dickens himself both, the author and his turnRead MoreOliver Twist: The Battle for Morality831 Words   |  3 PagesThe Battle for Morality in Oliver Twist In Oliver Twist, author Charles Dickens attacks the decomposing morals of Victorian society and law in the form of writing. He addresses major social conflicts and struggles between the rich, who hold positions of power, and the poor and working class who fight for economic justice. In addition, the book is representative of the need for moral values based on the author’s believe that people should not be oppressed, that every person deserves a chance. TheRead MoreGreat Expectations By Charles Dickens1347 Words   |  6 PagesExpectations, Charles Dickens voices the concerns of many that lived in Victorian England during the 19th century by promoting such a desire to live life in a more prosperous social class. One of the most fundamental and reoccurring themes in the novel is that of social class. Throughout the novel, the reader examines the protagonist, known as Pip, as he transforms from a poor working boy into a wealthy gentlemen. 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The same can beRead More Sympathy for Pip in Great Expectations by Charles Dickens Essay2049 Words   |  9 PagesSympathy for Pip in Great Expectations by Charles Dickens problems with format    Great Expectations is a novel in which each character is a subject of either sympathy or scorn.   Charles Dickens implies through his use of guilt and suffering that Pip is a subject of sympathy.   Frazier Russell wrote that in Great Expectations the protagonist (through his suffering and disappointment), learns to accept his station in life.(   Also through Pips suffering comes the sympathy the reader feelsRead More Laws, Crime and Punishment in Great Expectations by Charles Dickens3288 Words   |  14 PagesLaws, Crime and Punishment in Great Expectations by Charles Dickens Great Expectations criticises the Victorian judicial and penal system. Through the novel, Charles Dickens displays his point of view of criminality and punishment. This is shown in his portraits of all pieces of such system: the lawyer, the clerk, the judge, the prison authorities and the convicts. In treating the theme of the Victorian system of punishment, Dickens shows his position against prisons, transportation and deathRead MoreCrime And Criminality In Charles Dickenss Great Expectations1752 Words   |  8 Pagesare predominant in Charles Dickens bildungsroman novel ‘Great Expectations’ published in 1861, which depicts the growth of the protagonist Pip and his desires to establish himself as a gentleman. With reference to Great Expectations, Dickens denotes one of his felonious characters as a â€Å"creature of neglect† yet at another point in the novel he refers to criminals as â€Å"irreclaimable wretches†. Philip Collins details Dickens’ li beral position towards crime, observing that Dickens had â€Å"strong and conflicting

Case Analysis Obergefell V. Hodges - 1136 Words

In Obergefell v. Hodges, the United States Supreme Court held that same sex couples can now exercise the fundamental right of marriage nationwide. Justice Kennedy reached this result by redefining what marriage is. James Obergefell and John Arthur married in Maryland in 2013. They lived in Ohio, which did not recognize same sex marriage. When John Arthur was diagnosed with ALS, the couple sued to have Obergefell’s name placed on the death certificate as a surviving spouse. The U.S. District Court overturned Ohio’s law banning same-sex marriage. The respondents appealed to the United States Court of Appeals for the Sixth Circuit. On appeal, the decision was reversed; therefore, Arthur’s death certificate could not have Obergefall’s name on it. The case was brought to the Supreme Court and consolidated with three similar cases. The Supreme Court’s decision finalized the questions of whether states have the right to pass laws treating marriages differently based upon sex, and if states have to acknowledge the marriage of same-sex couples who were married in another state. On a 5-4 decision, the Court determined that the Fourteenth Amendment requires states to issue marriage licenses to same-sex couples because they cannot be treated differently than opposite sex couples. The court also determined that states have to recognize same-sex marriages the same way they do with opposite-sex. However, the Supreme Court did not create a law about same sex marriage, it just stated thatShow MoreRelatedThe Constitutional History II On The United States1544 Words   |  7 PagesClause of the Fourteenth Amendment. (Lempert, 2015) The case of Obergefell v. Hodges was a case that held that the Fourteenth Amendment requires all states to recognize and grant same sex marriage licenses to couples that have been granted that right in other jurisdictions. This case may be considered a significant decision of the United States Supreme Court when analyzing US Constitutional History, but the real question is whether or not this case was decided and analyzed using the framework of legalRead MoreLegalization Of Same Sex Marriage1256 Words   |  6 Pagesbecause of popular case which is called the Obergefell v. Hodges (2015). This very important case involved â€Å"14 same-sex couples and two men whose same-sex partners are deceased† in this case the couples argued that the â€Å"state officials violated [their] 14th amendment by denying them the right to marry or to have marriages lawfully performed in another state given full recognition and also violated their equal protection Clause.† The supreme court ruled in favor for this case because in the 14thRead MoreWhy Did The 14th Amendment Guarantees Equal Protection Under The Law?1092 Words   |  5 PagesStates. This all occurred becaus e of the Obergefell v. Hodges (2015) case. This very important case involved â€Å"14 same-sex couples and two men whose same-sex partners are deceased† and the couples argued that the â€Å"state officials violated [their] 14th amendment by denying them the right to marry or to have marriages lawfully performed in another state given full recognition and also violated their equal protection Clause. The supreme court ruled for this case because in the 14th Amendment it clearlyRead MoreThe Tension Between Liberty And Equality2115 Words   |  9 Pagesequality are â€Å"slowly disclosed† and only become apparent in the long-term analysis, whereas those of liberty can be seen immediately and are â€Å"apparent to all† (203)—combined with the initial point, it appears far more valuable to men in the short-term to place greater value on equality. These two points are also valuable justifications when considering Tocqueville’s secondary argument to be discussed later in this analysis. Following from Tocqueville’s observations of the tension between libertyRead MoreConvention Of The States Argument Essay1024 Words   |  5 Pagesthe 12th and still most recent state to come on board with the Convention of the States. Over the last 40 years, 27 states have supported the idea, but only twelve have passed an application affirming approval (Personal Address). As stated in Article V of the Constitution, a Convention of the States would require a 2/3 approval from state legislatures (Texas Gov.). Most recently, the Convention of the States Project took pride in hitting three-million supporters nationwide. Advocates including SenatorRead MoreAnalysis Of Paul Loeb s Soul Of A Citizen1687 Words   |  7 Pagesbut also of the entire world as well. A good citizen will stand up for what they consider important. As the quote by Giroux states, it is a responsibility to others as well, as the brave citizen is doing the entire community a favor as well. The analysis inclu ded in this paper will allow a reader to fathom what it means to bring change about, to get one’s voice heard, and to stand up for one’s beliefs, hopes and desires. This paper will be proceeded in a manner that not only summarizes the key ideasRead MoreThe Power Of A Society s Justice System1581 Words   |  7 Pagesaffecting the nation’s international standing. Society’s shared understanding of values and its behaviors influenced by the Supreme Court’s rulings, while simultaneously, influencing international interpretations of justice, are exposed through the analysis of ideological and behavioral codes. Key to the understanding of American values and the Supreme Court’s rulings is the political theory interwoven between the nation’s framework. Liberty, justice, and equality are at the heart of American democracyRead MoreSame Sex Marriage Should Be Legal Under International Law1219 Words   |  5 Pagesand I call on all members of our UN family to unite in rejecting homophobia as discrimination that can never be tolerated at our workplace†. Ban Ki-moon, the 8th Secretary General of the UN, commented on the United States Supreme Court case Obergefell v. Hodges by saying, â€Å"A great step forward. Denying couples legal recognition of their relationship opens the door to widespread discrimination.† This shows the growth and change of open mindedness all around the world over past centuries (PublicRead MoreI Chose The United States Of America As My Case Study,1355 Words   |  6 PagesI chose the United States of America as my case study, due to its re markable design that is still in effect today. Although it’s far from perfect it has been present since 1776 without signs of it diminishing anytime soon. Understanding the reasons why it was established in the first place is crucial to grasping an educated analysis. Analyzing the United States’ history, background, and governmental design in a hypothetical approach will entail a better understanding in how and why it developed itsRead MoreThe United States1445 Words   |  6 PagesThe history of the United States tends to be understood through analysis of periods of conflict. From the Revolutionary War, to the Civil War, both World Wars, the Cold War (and its affiliate proxy incidents), and finally modern day. What this skeletal description misses are the individual struggles of people who spent their lives marginalized due to societal stereotypes and discriminatory legislation. Groups have been affected due to identities that include but are not limited to: race, re ligion

Impact of relocating sendong survivor of barangay bayug iligan city after the typhoon sendong free essay sample

Iligan City was one of the places in the Philippines devastated by Typhoon Sendong(International name: Washi) last December 17, 2011out of the 44 Barangay that compose IliganCity, 22 Barangay were severally affected. Six thousand (6,000) families were displaced and have received different kinds of survival assistance and support worldwide. However, Bayug Island a part of Barangay Bayug has been declared as no Man’s LAND or Danger Zone (because its 6 -7 feet below sea level) for men resident are no longer allowed to reside in that place. More that five hundred household need to be relocated in different relocation areas designated by the local and national government to include local national and international (NGO’s). There is urgent call for all benefactors ( local, national and international) to find an appropriate area to become the permanent relocation site for the Typhoon Sendong family victims This research focuses on the relocation of the Sendong Victim towards to their new relocation and socialization of the victims in Barangay Bayug Island, however the researcher choose this topic in order to guide the respondents for their improvement in making harmonious relationship and psychological status Theoretical Framework This study used the following Socialization theories by (Freud) and Neurosis Theory by (Horney). We will write a custom essay sample on Impact of relocating sendong survivor of barangay bayug iligan city after the typhoon sendong or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Socialization is an integral part of the process every human being, regardless of gender, culture or geographical location, goes through from childhood through adulthood. It is a never-ending process. But it is especially important during the formative years of a person’s life. In brief, socialization can be described as the process by which an individual acquires his or her own personal identity. He or she learns the values, norms, social behavioral patterns and social skills needed to integrate in and become a functioning member of their particular society. Musgrave (1998) said that Socialization is education in the broadest sense: It is the process whereby one acquires a sense of personal identity and learns what people in the surrounding culture believe and how they expect one to behave† Socialization is broadly categorized into two: primary and secondary socialization. Primary socialization is phenomenal during infancy and early childhood while secondary socialization is most prevalent after early childhood and continues even in old age. In addition, secondary socialization incorporates a term resocialization. Resocialization refers to the process of discarding former behavior patterns and accepting new ones as part of transition in one’s life. It is most prevalent in reform schools, political indoctrination camps, prisons and therapy groups. Horneys theory is perhaps the best theory of neurosis we have. First, she offered a different way of viewing neurosis. She saw it as much more continuous with normal life as previous theorists. Specifically, she saw neurosis as an attempt to make life bearable, as a way of interpersonal control and coping. This is, of course, what we all strive to do on a day-to-day basis, only most of us seem to be doing alright, while the neurotic seems to be sinking fast. From her experiences as a psychiatrist, Horney named ten patterns of neurotic needs. [9] These ten needs are based upon things which she thought all humans require succeeding in life. Horney modified these needs somewhat to correspond with what she believed were individuals neuroses. A neurotic person could theoretically exhibit all of these needs, though in practice much fewer than the ten here need to be present for a person to be considered a neurotic. The ten needs, as set out by Horney, (classified according to her so-called coping strategies) are as follows: Moving Toward People 1. The need for affection and approval; pleasing others and being liked by them. 2. The need for a partner; one whom they can love and who will solve all problems. Moving Against People 3. The need for power; the ability to bend wills and achieve control over others—while most persons seek strength, the neurotic may be desperate for it. 4. The need to exploit others; to get the better of them. To become manipulative, fostering the belief that people are there simply to be used. 5. The need for social recognition; prestige and limelight. 6. The need for personal admiration; for both inner and outer qualities—to be valued. 7. The need for personal achievement; though virtually all persons wish to make achievements, as with No. 3, the neurotic may be desperate for achievement. Moving Away from People 8. The need for self sufficiency and independence; while most desire some autonomy, the neurotic may simply wish to discard other individuals entirely. 9. The need for perfection; while many are driven to perfect their lives in the form of well being, the neurotic may display a fear of being slightly flawed. 10. Lastly, the need to restrict life practices to within narrow borders; to live as inconspicuous a life as possible. Horney noticed that, in contrast to our stereotypes of children as weak and passive, their first reaction to parental indifference is anger, a response she calls basic hostility. To be frustrated first leads to an effort at protesting the injustice! Conceptual Framework In order to gain clearer understand on the schematic diagram of the study, this section presented to conceptual framework of the study which focuses on the relationship of the variables of Impact of Relocating Sendong Survivor as show in figure 1. Independent variable in this study focuses on the personal profile of the Sendong Victim and their socialization process. Figure 1. The schematic diagram showing the interplay of variables in the study. Statement of the Problem The main thrust of this research was to find out the Impact of Relocating the Sendong Victim toward to their new communities and common problems of socialization process Specifically, this research sought to answer the following question: 1. Socio – Demographic profile of the Respondent. 1. 1 Gender 1. 2 Age 1. 3 Civil Status; and 1. 4 Educational Background? 2. Coping Mechanism of the survivors after the typhoon sendong. 2. 1 Cognitive Mechanism 2. 2 Conversion Mechanism 2. 3 Adaptive Mechanism 2. 4 Avoidance Mechanism 3. Advantage and Disadvantage of Relocation. 4. Effect of relocation to the livelihood of Sendong Survivors. 5. Common problems in the relocation area and how did they address the problems. 6. What can the survivors say in Relocation then? Hypothesis Ho1 there is a great significant of the profile of sendong victim respondent and the impact of survey because profile can be use as bases for the solution of sending victim relocation problem. Significance The results of findings of this study provide more knowledge and information to the brangay / city official to the department of social welfare and development office, and the other national agencies which are responsible for expending humanitarian services Specifically, the study would be greater help by giving black and white written result of the survey and this would encourage unity and collaboration among all other sectors in the society. Scope and Limitation The research work is focus on the impact of senoding survivor relocation situation in their relation family, educational, and social growth in development Those who are victims of sendong survivor family who where victims of typhoon sendong last December 17, 2011. Respondent. Actual interviewed 9 heads of the family beneficiaries. Income. They are provided in kind material, food, health, education material and their psychosocial activity needs Chapter 3 RESEARCH METHODOLOGY AND DESIGN My research procedure required actual interview from the Sendong Victim beneficiary. The facts gathered were analyzed and became the basis of recommendation/suggestions to the authority concern for proper resolution Research Design The survey was conducted through guide questionnaire presented and answered by respondents which hdone on the 25th day of August 2012. Emotion, psychological and mental condition of respondents were taken seriously by human consideration, respect and understanding. The results of the survey were strictly kept confidential and official. Research Environment The study was conducted at Barangay Sta. Elina, Iligan City. Where the Sendong Survivor was relocated and most of them are from Barangay Bayug Island. Respondent The respondents of the study are the Sendong Survivor which has been relocated at Sta. Elina, the respondents of this inquiry representing 100% of the total population. Data Gathering Instrument The said questionnaire was distributed by the researcher personally but most of them are personal interviewed. The questionnaire that has been distributed would be left and retrieved after I finish my interview to the other respondents. This allowed the researcher to remind the respondents understanding and persuasive in conducting this survey and personally interview. Research Instrument The instrument used in this study employed structured questionnaire to gather the necessary data from the respondents. The draft of the questionnaire was writing out based on their situation in Barangay Sta. Elina. In the preparation of the instrument, the requirements in the design of good data collection instruments were considered. For instance, statement describing the situation or issues, of relocating the Sendong Survivor Respondents. In this way, the instrument is authorized to obtain valid response of the readers. Preference for the use of the structured questionnaire is premised on several research assumptions such as a) cost of being a least expensive means of gathering data, b) avoidance of personal bias, c) less pressure for immediate response and giving the respondents a greater feeling of anonymity. In the end, in encourage open response to sensitive issue at hand. Statistical Treatment of Data The researcher used percentage method as the statistical tool in analyzing and calculating the gathered data. Responses were converted into percentage using formula to determine the percentage per group data. The frequency of each group was simply divided by the total (N) of the population. Thus, the total percentage were equal to 100% P = (f/N)*100 Where: P = Percentage F = frequency N = total number of respondents Thus, P = (f/9)*100 Where, 6= total number of respondents Chapter 4 PRESENTATION, ANALYSES, AND INTERPRETATION OF DATA This chapter comprises the analysis, presentation and interpretation of the findings resulting from this study. The analysis and interpretation of data is carried out in two phases. The first part, which is based on the results of the questionnaire, deals with a quantitative analysis of data. The second, which is based on the results of the interview and focus group discussions, is a qualitative interpretation. Analysis of Questionnaires Of a total of 9 questionnaires distributed, only 3 completed questionnaires were the base for computing the results. The remaining (3) are non-response. This means that 3 questionnaire out of 6 questionnaire distributed, were completely discarded from the analysis. The rest, (3 questionnaire) were used to interpret the results. Data gathered through the questionnaire was subjected to frequency counts. In other words, the subjects responses for each individual question were added together to find the highest frequency of occurrence. These responses to the question, which are qualified, are then presented in percentage forms. This analysis is presented in tabular form. The researcher uses containing a variable and in some cases, combines two or more variables in single table. The first section of the questionnaire sought to identify the subject what are their coping mechanism did they uses in able to overcome their situation. It enables the researcher to identify the responses of those subjects who had never used a coping mechanism and exclude them from the analysis. 4. 1. 1 Profile of Respondent by Gender Gender Frequency Percentage Male 2 20% Female 4 70% Total 6 100% Table 1 shows that out of (6) respondents, two (2) or (20%) are male, while four (4) or (70%) are female. It shows that majority of the respondents are male. 4. 1. 2 Profile of Respondent by Gender Civil Status Frequency Percentage Single 0 0 Married 6 70% Total 6 100% Table 2 shows that all of the respondents are married. It implies that all of them have their siblings. 4. 1. 2 Profile of Respondent by Gender Educational Attainment Frequency Percentage High school level 0 0 High school graduate 1 10% College level 2 30% College graduate 3 60% Total 6 100% Table 3 shows that out of (6) respondents one (1) or (10%) of the respondents are in the high school graduate. The two (2) or (30%) is in the college level. While the last three (3) or (60%) of the respondents are college graduate. It implies that majority of the respondent are knowledgeable. 4. 1. 3How did you overcome to the things happing in your life, did you use sort of coping mechanism? VARIABLEFREQ. PERC. A = YES 4 70% B= NO 2 20% Table 3 shows that only 4 (70%) of the subject are using the coping mechanism in order to overcome the tragedies happing in their life. The rest 2 (20%) of the population are not using the coping mechanism, although there is a vast difference in the number. The total number of those who use coping mechanism will be used as a total sample size. The result is based on the subject’ experiences and not on speculation or what they believe or think, and should therefore be reliable. It also interesting to note the high number of subject who are using coping mechanism more than once. Chapter 5 SUMMARY OF FINDING, CONCLUSION, AND RECOMMENDATION While the preceding chapters conferred the findings and analysis of this study, this chapter presents the summary of the findings, conclusion, and recommendation based on the previous chater. Summary of Findings The major findings of the study are the following: 1. Majority (70%) of the respondents are female 2. All (100%) of the respondents are married 3. Majority (60%) of the respondents are college graduate 4. Some (70%) are using the coping mechanism

Promissory estoppel is a controversial exception Essay Example

Promissory estoppel is a controversial exception Essay There are three exclusions to the regulation inPinnel’s instance. They are composite understanding, payment of debt by 3rd party and promissory estoppel. The regulation inPinnel’s instance ( 1602 ) 5 CoRep117ais that portion payment of debt is non good consideration to waive the balance. Thus the creditor may action for the staying debt unless there is fresh consideration. Promissory estoppel like proprietary estoppel is popular types of just estoppel. The importance of just estoppel was stated inCrabb V. Arun DC ( 1976 ) 1 Ch 179that â€Å"equity comes in †¦Ã¢â‚¬ ¦.. to extenuate the cogency of rigorous jurisprudence †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ . it prevents a individual from take a firm standing on his rigorous legal rights †¦ . when it would be unjust for him to make so holding respects to the traffics which has taken topographic point between the parties† . We will write a custom essay sample on Promissory estoppel is a controversial exception specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Promissory estoppel is a controversial exception specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Promissory estoppel is a controversial exception specifically for you FOR ONLY $16.38 $13.9/page Hire Writer An illustration of promissory estoppel is where A promises B that he would non implement his legal rights and B acted and relied on it without giving any consideration, equity would non let A to renegue on on his promise to B. The modern construct of promissory estoppel was developed in the instances ofCardinal London Property trust Ltd V. High Tree House Ltd. ( 1974 ) 1 KB 130andEntire Metal Manufacturing Ltd V. Tungsten Electric Co Ltd. ( 1955 ) 1 WLR 761. Promissory estoppel differs from common jurisprudence estoppel because it has less rigorous demands and it may originate from promise of future behavior or purpose. Promissory estoppel is traceable toHughes V. Metropolitan Railway( 1877 ) 2 App Case 439. Here the landlord gave his tenant 6 months to mend the belongings else hazard forfeiture. Within the 6 months, dialogue for the sale of the rental was opened between landlord and renter. The dialogue failed after 6 months and the renter failed to mend. The landlord sought to implement forfeiture. It was held that the landlord had led the renter by his behavior to believe that the landlord would non implement forfeiture. InHigh Tree House Ltd instance,the landlord promised to have from the tenant half of the land rent because of the trouble of happening renters during wartime period. After the war, the flats became occupied and the landlord sued for outstanding arrears during the wartime. The tribunal germinating the rule of promissory estoppel held that the landlord was non entitled to the arrears rent of the wartime period. Promissory estoppel occurs when there is a contractual relationship between parties. Like when there is a legal relationship between the promisee and the promiser. It remains unsettled whether promissory estoppel may originate in pre-contractual relationships. However, Lord Denning inBrinkom Investments Ltd V. Carr ( 1979 ) Calciumwas of the position that promissory estoppel may originate from promise made by parties negociating contracts. Similar positions was expressed in Durham Fancy Goods V. Michael Jackson ( 1969 ) 2 QB 839 where Donaldson J. held that contractual relationship is irrelevant provided that there is â€Å"a preexistent legal relationship which could, in certain fortunes, give rise to liabilities and penalties† . The first demand of promissory estoppel is that the promiser must give clear and unambiguous statement that he does non mean to implement his legal rights. The promise may be express or implied. The 2nd demand is that promisee must hold acted on that promise made by the promiser. Promissory estoppel frequently originate where promisee in trust on that promise suffered hurt as inAjayi V. Briscoe ( 1964 ) 1 WLR 1326; or where he alters his place as a consequence of trusting on that promise when though he suffers no hurt. InAlan Co. Ltd V El Nasr A ; Import Co. ( 1972 ) 2QB 18, Lord Denningheld that hurt is non an indispensable component of promissory estoppel. Therefore, for a supplication of promissory estoppel to win, there must be a alteration in fortunes of the promisee. The 3rd demand of promissory estoppel is that it would be unjust for the promiser to renegue on on his promise and claim his rigorous legal rights after the promisee had relied on it. The 4th demand of promissory estoppel is that it can non non be enforce against the promissor. Thus it can be used merely as a defense mechanism and therefore can non be used as a blade. In Combe V. Combe ( 1951 ) CA, the tribunal held that promissory estoppel does non make a cause of action and as such the demand of consideration in formation of contract is still relevant. Promissory estoppel is a regulation of grounds that prevents the promissor from denying the truth of statement which the promisee had relied. However, this demand seemed changed in visible radiation of the determinations inRe Wyven Developments ( 1974 ) 1 WLR 1097andEvenden V. Guildford City AFC ( 1975 )QB 917, here the tribunals held â€Å"that promissory estoppel can be a cause of action† . The tribunals use an nonsubjective trial to find whether it was sensible to trust on a promise. Thus certain promises like menaces would non amount to promissory estoppel where tribunal decides that trust on it was unequal. Furthermore, if the promisee did non trust on the promise, there would be valid statement that it was non unjust for the promiser to travel back on his promise. Promissory estoppel may for good snuff out the rights of the promissor to claim ball amount after part-payment. InD A ; C Builders v Rees ( 1965 ) 2QB 617,Lord Denningexpressed that the â€Å"promissor would non be allowed to return to his rigorous legal rights and that the promissory estoppel will be concluding if promisee understood the promise to intend concluding extinction of promissors’ rights rigorous legal rights† . However, for periodic payment promissory estoppel simply suspends the right of the promissor to the debt until such clip when it becomes just to claim the balance. Therefore, in periodic payments, promissory estoppel may snuff out the right of the promissor to claim payment for the suspended period but can do claim for subsequent periods after giving sensible notice or when the fortunes that gave rise to the fortunes alterations. InEntire Metal instance, the tribunal held that â€Å"on giving sensible notice to the other party, revert to their legal entitlement to have the compensation payments†

America and the Thirteen Original Colonies essays

America and the Thirteen Original Colonies essays Every person born and raised in America, within the past half century, has at one time or another heard the song "Fifty Nifty United States"; the song which pounds the memorization of the fifty American states into one's head. If you were to ask any person from the age of ten to thirty, they would most likely be able to recite every single state, alphabetically. Towards the beginning of the brilliant masterpiece, there is a line which exclaims, "Fifty Nifty United States/ From thirteen original colonies..." The line, having horrible melodic doggerel, is right about these colonies. Thirteen colonies established by the British were satellites used in a system of mercantilism; they provided the natural resources while England would manufacture the goods to sell back to them. Unlike many other attempts at establishing previous settlements, these particular colonies, over a period of time, began to take their own form and question the mother country. The colonies developed their own ideas and beliefs and eventually broke away from England to for the United States of America. Among the so-called Thirteen Original Colonies, which included those of New England, the Middle Colonies, and the Southern Colonies, were certain common institutions and philosophies. The first colonies of America, the quintessential "thirteen" of them, had certain elements that caused them to be similar. Geographically, every colony was on the eastern coast of America, and everyone had similar environmental and land features. In the New England colonies, although a bit colder, had necessary farming land with some forest area; in the Middle colonies, farmland was abundant and waterways were important to trade; and in the Southern colonies, farmland was a very important factor and it was generally warmer than the other colonies. Geography also had a large impact on the economy, logically, seeing as if the three sections of colonies did not have distinguishing characte...

Film summary title never let me go Movie Review Example | Topics and Well Written Essays - 500 words - 1

Film summary title never let me go - Movie Review Example One of their teachers, Miss Lucy tells the pupils of the way that they are, that they live so that they could become organ donors at one point. Tommy and Cathy become great friends but Ruth spoils the relationship by attempting to snatch Tommy from Cathy, she is successful for a while. The three friends shift to some cottages in a farm where they encounter other young adults that came from schools that resembled theirs. At some point, they find a person whom they perceive to be a clone for Ruth making the three friends to arrange for a trip to go and see her. Unfortunately there is little semblance, an aspect that rages Ruth a lot. Hearing that there was a possibility for ‘deferral’, Tommy gets to the gallery of Hilsham to check on whether the artwork would predict true love. However, he never sent any artwork hence a deferral cannot be established between him and Ruth. A split in the relationship occurs where Cathy sets herself from the rest to take the role of supporting organ donors. Also immediately, the relationship between the Tommy and Ruth ends. Ten years later, Cathy meets a frail Ruth who organizes for a meeting of the three friends to seek for forgiveness. She donates her last organ and dies. Consequently, Tommy and Cathy become friends aga in but the play culminates when he is donating his last organ as Kathy is looking onto him on the other side of the glass window. The film is a science fiction that presents incidences that have been at the center of research. Organ donation is an aspect that of presented in the film, here focusing on growing individuals specifically for organ donation. Jealousy in relationships is real especially where there is an act of desperation. Ruth was worried that she may be unable to find a friend just like Cathy because of the limited interactions. Tommy was the only man around them, so she opted to compete with her. Another issue is the aspect of superstition;

The temperature and forms of energy and alternative Essay

The temperature and forms of energy and alternative - Essay Example Energy is known to have existed in different forms and by law of conservation, it is neither gained nor lost, only transformed between such forms. Humans have since time hugely benefitted from utilizing energy with light, heat, gravitation, and sound. Scientific studies, moreover, allowed discoveries of other convertible energy forms such as mechanical energy, electrical energy, chemical energy, and nuclear energy. It is of primary significance to life that each energy form is capable of operating a specific engine or machinery to aid men in their means of comfortable living and advancement toward a more sustainable economy. Out of these forms, energy is further classified as either originating from resources or non-renewable resources. In particular, biofuels like the ones based on algae are a renewable alternative fuel used in producing electricity. Besides the renewably drawn energy derived through biomass, geothermal energy, hydroelectric energy, wind, and solar powers, good fuel alternatives are present as well in bioalcohols, non-fossil methane and natural gas, ammonia, and vegetable oil. These safer options create possibilities of reducing air pollution since less hazardous substances are involved during the crucial stages of extraction and emission processes. This way, state investments may be allocated for concerns other than for setting up

Factory job Essay Example for Free

Factory job Essay I am seriously going to explode one day. That Mr Birling is being totally out of order, he pays us girls nothing more than 20 shillings a day and that cant keep me alive for much longer. I have spoken to the girls and they agree with me that we should go on strike. That will make him think about the wages he gives the girls and me. I would rather quit but that would show the wrong side of me I am not a quitter, I am a fighter. I should of taken the job in the bakery but no I had to choose the factory job which could have been good and well paid but no they lied to me about the wages. Anyway I saw my Nan today, she is really ill I need the extra money for her medicine but if you ask me I think she will be going soon. I wish I could see my mum but she is in Yorkshire. I could not stay there because there was no work. There was work but I would never stoop that low. My sister got into that kind of work and she got pregnant out of that sort of business. This all the countrys fault I had to move here because of the lack of jobs in Yorkshire its ridiculous. The strike will still go on. Talk soon, thank you for listening. I am sacked now, looks like I need to starve my self once again all because I wanted more money to actually stay alive, hence I am starving myself now. Most of the girls got their jobs back and I loose mine that fair. Mr Birling has to learn that it is not business all the time, he has to think about other peoples lives that are not rich. I told him that and he obviously did not understand about higher and lower class, all he concentrates on is higher class and spends money like a fire in a wood. I better look for a job soon other wise I will die like my Nan did poor and helpless. I am living in my Nan house but I will probably not stay here that long because she has probably given the house to sally her friend on the street. Thank you for listening bye. I am so happy, I went to a interview last week with Milwards and I have a job now and its good pay and I can help sewing the dresses which is my life long dream. I have not got the house any more, Sally and Frederick her boyfriend live there now and I live in a run down hovel and nothing in it. I have no money and I have changed my name to Sarah so I can get a job because I got sacked and you what Mr Birling is like, he knows everyone. I am gradually getting richer but not much, I have got 40 shillings and I need to save that so I cant eat again. Hopefully this job will be successful and its nearly Christmas bonus but I wont get my hopes up. I have realised that my behaviour at Mr Birlings factory was bad but I was desperate and I need the money. I need to be really polite in this shop because lots of posh and higher class shop here and like I said I dont want to work on the street. Thank you for listening. I got sacked once again. I have not been a pain but I did make a funny look when Miss Birling was showing her dress to mum. Even her mum didnt like the dress, you could tell by her face. I laughed as well but that was because I tripped other the stall. I think she complained about me and said to Samantha the boss to sack me. The Higher class always gets their way and bosses always want money. Thank you for listening. It has come to the worse now. I am getting money but I hate sleeping with scummy old men who smell of beer and sometimes dont even pay you for your time. I really did not want to become a slut and sleep around but I am and I had to change my name again. My name is Daisy Renton now. I have lost two stone. I am probably going to die one day and probably poor, helpless and with no family by my side. I might go back to Yorkshire but I have myself into a business. I am going out with Gerald. He was a customer but he likes talking to me and he bought me food recently and I that was touching. I met him in the palace bar. I was there for business and business is good there because all the rich people are there and have no lady of there own because they are so ugly. Gerald is so sweet. Talk soon. I am really depressed and my live is over now because Gerald has left me he gave me some money but I love Gerald I need him he kept me away from trouble. A man recently beat me up and Gerald looked after me. He is a star and he always will be. The money has been going down the drain I need more money, I might need to do extra nights and double shifts a night. Old men are the worst they are so old and horrible. I need a good job because I have not got a enough money for the place I am renting. I will talk to you soon bye.

Mary Shelly’s Frankenstein Essays -- essays research papers

Mary Shelly’s Frankenstein Responsibility is the key to experimentation, those lacking the maturity fail. In Mary Shelly’s Frankenstein, Victor Frankenstein experiments in creating life. However creating a monster, the reader finds out that Victor is not mature enough to handle the responsibility of his actions. Even though Victor Frankenstein is the creator/father of the monster, he has characteristics of a child and the monster has the maturity of an adult. When Henry Clerval arrives at Frankenstein’s door after his experimenting, he experiences Victor’s child-like actions. As Victor explains, â€Å"I was unable to remain for a single instant in the same place; I jumped over the chairs, clapped my hands, and laughed aloud.†(36) This shows the sheer giddiness of Victor after being isolated from friends and family for months working on his experiments. Victor was immature when handling the isolation so he bottled up emotions which were let loose when the sight of his friend arrived. Frankenstein even mentions that his actions are child-like when he enters his home. â€Å"I threw the door open forcibly, as children are accustomed to do when they expect a spectre to stand in waiting for them on the other side.†(37) Like a child does, victor could not control his feelings and thus acted out in an irregular manner for an adult. After Frankenstein creates the monster, his actions, also became that of a scared child. â€Å"One hand was stretched out, seemingly to detain me, but I escaped, ...

Patterns in Strategy Formation Essay

A critical summary of the article â€Å"Patterns in strategy formation† written by Henry Mintzberg, published in Journal Management Science Vol. 24, No. 9, (1978) A short overview The paper,†Patterns in strategy formation†, outlines a new kind of description to the much misunderstood process of strategy formation in organizations. After giving a short summary of the theme, the author, Henry Mintzberg, describes the term â€Å"strategy† and shows how the definition leads to the choice of a research methodology. Following this, he details the four steps of research methodology. With to completed, major studies about two organizations (Volkswagenwerk and the United States government in Vietnam) Mintzberg analyzes three central themes. The first is that strategy formation can be viewed as the interplay between a dynamic environment and bureaucratic momentum, with leadership mediating between the two. Second, that strategy formation over periods of time appears to follow distinct regularities, for example life cycles or change-continuity cycles within life cycle. And third the study of the interplay between intended and realized strategies may be central to the strategy formation process. Definition of strategy and the research methodology In the first section of the paper, Mintzberg describes the term †strategy†. Strategy is generally defined, whether in game, military or management theory, as a deliberate, conscious set of guidelines that determines decisions into the future. In common terminology, a strategy is a plan. Mintzberg illustrates that defining strategy as a plan is not sufficient, because if strategies can be intended, surely they can also be realized. A definition that encompasses the resulting behavior is therefore required. The author proposes to define strategy in general as a pattern in a stream of decisions. To clarify this definition of strategy, he introduces a few illustrations. For example, when Picasso painted blue for a time, that was a strategy †Blue Strategy†. This definition of strategy necessitated the analysis of decision streams in a organizations over time periods to detect the development and breakdown of patterns. Therefore Mintzberg subdivided the analysis of the studies into four central steps. 1st step: Collection of basic data. 2nd step: Inference of strategies and periods of change. 3rd step: Intensive analysis of periods of change. 4th step: Theoretical analysis. After giving a brief review of the periods of strategy in two organizations, using the terminology of the research, the author comes to the core of the paper, which is the presentation of some theoretical conclusions about strategy formation. Strategy formation as the interplay of environment, leadership and bureaucracy Mintzberg outlines strategy formation in most organizations as the interplay of three basic forces revolving around the dynamic environment that changes continuously but irregularly, organizational management or bureaucracy that attempts to stabilize the actions of the organizations whilst operating in the dynamic environment, and leadership of the organizations whose role is to mediate between the two forces. From this point of departure, the author provides a definition of strategy and of strategic change. †Strategy can then be viewed as the set of consistent behaviors by which the organization establishes for a time its place in its environment, and strategic change can be viewed as the organization’s response to environmental change, constrained by the momentum of the bureaucracy and accelerated or dampened by the leadership†. Mintzberg illustrates, that the two organizations (Volkswagenwerk and U.S. government in Vietnam) are stories of how bureaucratic momentum constrains and leadership dampens strategic change. In 1965, for example, when the United States government escalated the Vietnam war in a way that made the escalation inevitable, the new leadership, named Johnson, dampened the strategic change, under the environmental and bureaucratic pressures. Also in 1960, when action was needed in the face of an increasingly changed environment, the central leadership of Volkswagenwerk was not forthcoming. Patterns of strategic change According to Mintzberg, patterns of strategic change are never steady, but rather irregular and ad hoc, with a complex intermingling or periods of change, continuity. Even so, he recognizes some patterns in strategy formation that may enable organizations to understand better their strategic situations. The first pattern is the life cycle of an overall strategy, based on four phases: conception, elaboration, decay and death. The author illustrates that the case of Vietnam represents the classic strategic life cycle. The second pattern is the presence of periodic waves of change and continuity within the life cycle. This second pattern suggests that strategies do not commonly change incrementally. Rather, change takes place in spurts, each followed by a period of stability. Mintzberg notes, that nowhere is the change-continuity cycle better demonstrated than in the stepwise escalation of the Vietnam metastrategy. According to the author, the reason for the periods of change and continuity is that human do not react to phenomena continuously, but rather in discreet steps, when changes are large enough to be perceived. In a similar manner, strategic decision processes in organizations are not continuous, but irregular. Based on both studies, Mintzberg notes, that there are dangers in incremental changes. He argues that strategy-makers seem prepared to assume positions in incremental steps that they would never begin to entertain in global ones. On the other hand, global change is very difficult to conceive and execute successfully. According to the author, this is perhaps the strategy-maker’s greatest dilemma. The danger of incremental changes versus the difficulty of global changes. Interplay between intended and realized strategies The author identifies two kinds of strategies: intended and realized. He illustrates, that these two can be combined in three ways: Intended strategies that get realized, which are called deliberate strategies (e.g. the Volkswagen strategy of 1948 to 1958). Intended strategies that do not get realized, which are called unrealized strategies (e.g. Kennedy’s intended strategy of 1961 of advising the Vietnamese). Realized strategies that were never intended, which are called emergent strategies (e.g. the U.S. strategy of finding itself in a fighting instead of advising role). Furthermore, Mintzberg argues that it is possible to find a number of other relationships between intended and realized strategies, such as intended strategies that, as they get realized, change their form and become emergent; emergent strategies that get formalized as deliberate ones; or intended strategies that get overrealized. This view challenges the tenets of planning theory, which postulates that the strategy-maker formulates from on high while the subordinates implement lower down. Mintzberg argues that this dichotomy between strategy formulation and strategy implementation is a false one under certain conditions – e.g. the formulator isn’t fully informed or the environment isn’t sufficiently stable -, because it ignores the learning that must often follow the conception of an intended strategy. According to Mintzberg, another important point is that the formalization of an emergent strategy as the new, intended strategy is hardly incidental to the organization. The author states that the very act of explicating an implicit strategy changes fundamental the attitude of the bureaucracy and of the environment. He further argues that the very fact of making a strategy explicit provides a clear and formal invitation to the bureaucracy to run with it. But the author also notes that sometimes it can be risky to make strategy explicit, notably in an uncertain environment with an aggressive bureaucracy. He makes the point that the strategy-maker may awake one day to find that his intended strategy has somehow been implemented beyond his wildest intentions. It has been overrealized. Conclusion and critique on the paper In my estimation, the paper †Patterns in strategy formation† is very well-written. The author, Mintzberg, first describes what the paper will be all about. After that, he introduces the theme, strategy as a pattern in a stream of decisions, and shows how this definition leads naturally to the choice of a research methodology. After that, he explains the four steps of the analysis he will use to reviews the major periods of two organizations (Volkswagenwerk and U.S. government in Vietnam). By using these major studies he arouses the reader’s interest and creates a fundamental basis to examine and prove aspects, that strategy formation can be viewed as the interplay of environment, bureaucracy and leadership, that that strategy formation appears to follow distinct regularities and that the study of the interplay between intended and realized strategies may be central to the strategy formation process. Furthermore, he admits that this studies constitute a limited data base, but they do call into question a number of assumptions about the process of strategy formation in organizations, e.g. that a strategy is not a fixed plan, that dichotomy between strategy formulation and strategy implementation is a false one under certain common conditions or that it can sometimes be risky to make strategy explicit. Some general conclusions suggested by these studies are complex and very difficult to understand but, nevertheless, the well-disposed reader understands the approach. This is mainly because, he explains his statements on this two studies closely. To sum up, the paper is well-structured and of a good concept. Furthermore, the paper ties in with very important and interesting research-fields in strategy management.

A Tort Law - Free Essay Example

Sample details Pages: 11 Words: 3232 Downloads: 10 Date added: 2017/06/26 Category Law Essay Type Cause and effect essay Tags: Tort Essay Did you like this example? Introduction Based on the question, Mark had suffered property damage due to the fire that was set by the youths. Therefore, we are required to advice Mark in respect of any claims he may have against various parties: the Amber Borough Council (hereinafter ABC), Chigley Services, Home Office, Justin and Jason, and the Fire Brigade. Technically, Mark could bring an action for economic loss under negligence and vicarious liability which are governed by the law of tort. Don’t waste time! Our writers will create an original "A Tort Law" essay for you Create order Since we are advising Mark to take an action for economic loss, we will be discussing pure economic loss before considering the potential liabilities of each party. Economic Loss First and foremost, the law of tort has always been willing to compensate losses resulting from tort that are described as economic with damages[1]. Generally, there are 2 types of economic loss: the consequential and pure economic loss. There is a case which illustrates the difference between the types of loss, Spartan Steel v Martin[2]. Here, the claimant was unable to carry out their operation due to the defendantà ¢Ã¢â€š ¬Ã¢â€ž ¢s negligence and claim under three heads: firstly, the damage to the metal that was in the furnace at the time of the power cut; secondly, the loss of profit that would have been made on the sale of that metal; and thirdly, the loss of profit on metal which would have been processed during the time the factory was closed due to the power cut. A majority of the Court of Appeal held that the first two claims were recoverable as the first claim belongs to physical damage to property while the second claim categorized as economic loss arising from damage to property. However, the third claim was not recoverable as the court held that it was pure economic loss and due to policy reasons. Thus, pure economic loss is not recoverable as it does not result from damage to property or physical injury but rather claim through insurance by virtue of the case of Marc Rich v Bishop[3]. By referring back to the facts, it was found that the fire set out by the youths had caused damage to the neighbouring property including Markà ¢Ã¢â€š ¬Ã¢â€ž ¢s bakerà ¢Ã¢â€š ¬Ã¢â€ž ¢s shop. Therefore, it is likely that Mark would be able to claim for consequential economic loss. However, each partyà ¢Ã¢â€š ¬Ã¢â€ž ¢s tortious liability needs to be established first in order for Mark to be able to succeed in his claims. Justin Jason Based on the question, the youths who ha d broken into the disused school and set fire to it had been clearing rubbish from a neighbouring stream and were supposed to have been supervised by Justin and Jason, both of whom are Chigley Services employees. However, both of them had gone for a cigarette break and left the youths unsupervised at the time the break-in occurred. Thus, Mark could bring an action against them under negligence. As per Baron Alderson in Blyth v Birmingham Waterworks[4], he defines negligence as à ¢Ã¢â€š ¬Ã…“omission to do something, which a reasonable man, guided upon those considerations, which ordinarily regulate the conduct of human affairs, would do, or doing something, which a prudent and reasonable man would not do.à ¢Ã¢â€š ¬Ã‚ [5] Therefore, in order for negligence to be actionable, there are three main elements to be established as stated by Lord Wright in Lochgelly Iron Co v McMullan[6]: The defendant must owe the claimant a duty of care; The defendant must breach that duty of care; That failure must cause damage to the claimant and the damage is not too remote. Duty of care First and foremost, Mark must prove that both Justin and Jason owe him a duty of care. If he fails to establish this, his suit will be unsuccessful regardless of how careless the defendant is or the defendant carelessness that caused the damage. In regard to the establishment of duty of care, we are required to look into Lord Atkinà ¢Ã¢â€š ¬Ã¢â€ž ¢s groundbreaking judgement in the early case of Donoghue v Stevenson[7]. In this case, Lord Atkin had developed the neighbourhood principle which states that the duty of care is owed to à ¢Ã¢â€š ¬Ã…“persons who are so closely and directly affected by my act that I ought reasonably to have them in contemplation as being so affected when I am directing my mind to the act or omission called into questionà ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã‚ [8] Therefore, once the neighbour principle is satisfied, the person will be assumed to have duty of care towards the claimant. Despite a two-stage test was set down in Anns v Merton[9] after the case of Donoghue, in 1990, it has been overruled by Caparo v Dickman[10] which laid down the modern three part test and it was said to be the basic test for duty of care which is still applicable until today. Thus, in order to decide whether there was a duty of care, the court must now consider: Whether the consequences of the defendantà ¢Ã¢â€š ¬Ã¢â€ž ¢s act were reasonably foreseeable; Whether there is a relationship of proximity between the parties; and Whether in all the circumstances it would be just, fair and reasonable to impose a duty Firstly, the defendant must have foreseen the risk of harm to the claimant at the time he is alleged to have been negligent. As stated by Lord Lloyd in Page v Smith[11], à ¢Ã¢â€š ¬Ã…“the test in every case ought to be whether the defendant can reasonably foresee that his conduct will expose the claimant to the riskà ¢Ã¢â€š ¬Ã‚ [12] By referring back to the question, Justin and Jason were supervising a group of youths from a young offenders institution, hence, it is reasonable to foresee that by leaving the youths unsupervised, it would expose Mark to a certain risk. Even though Justin and Jason might try to argue based on the case of Topp v London Country Bus[13] where the bus company did not owe a duty of care when leaving a bus unattended and joy riders stole the bus and injured the claimant. It is unlikely that they will succeed as the bus was not operating at that time. Secondly, Mark must prove that there is a relationship of proximity between him and the defendants. P roximity must be a legal one rather than factual proximity. Following the case of Sutherland Shire Council v Heyman[14], proximity could be said as involving the notion of nearness or closeness, a nexus or relationship; embracing physical proximity between the parties or their property; concerning proximity in relationships such as employer and employee or of a professional man and his client; including causal proximity in the sense of the closeness or directness between the course of conduct and the loss and injury sustained; or reflecting an assumption by one party of a responsibility to take care to avoid the injury, loss or damage to another, or where a party relies on such care. Based on the question, there is a relationship of proximity between Mark and the defendants as the bakerà ¢Ã¢â€š ¬Ã¢â€ž ¢s shop was located nearby the school. Thirdly, the court must consider whether it is just, fair and reasonable to impose a duty on the defendants. The test of fairness is closely associated and inevitably intertwined with the first two elements. Therefore, it is the judgesà ¢Ã¢â€š ¬Ã¢â€ž ¢ discretion to impose a duty of care if it is just fair and reasonable. Breach of duty of care After proving that there was a duty of care owed to Mark, he must now prove that Justin and Jason have breached the duty of care. The second element of the negligence refers to the standard of care that is appropriate to the duty owed. Therefore, when the party owing the particular duty falls below the standard of behaviour that is required that is required by the respective duty, breach of duty occurs. Before accessing in detail, we must first identify whether Justin and Jason is an ordinary or skilled defendant. Based on the question, it could be seen that they are ordinary person. Therefore, the appropriate standard of care would be based on reasonable manà ¢Ã¢â€š ¬Ã¢â€ž ¢s test and the conduct of Justin and Jason are measured against that of a reasonable person in the same circumstances. In deciding whether there was a breach of duty, the court will take into account the following four factors: the degree of risk involved, the practicability of taking precautions, the seriousness of harm and the social importance of the risky activity. In the case Walker v Northumberland[15], the courts held that the defendants was in breach of their duty due to failing to take reasonable steps to avoid psychiatric injury after knowing of the social workerà ¢Ã¢â€š ¬Ã¢â€ž ¢s likelihood to suffer a subsequent nervous breakdown. This could be a good illustration to the facts of the question because by applying it, Justin and Jason would be in breach of their duty of care for failing to take reasonable steps to avoid the risk involved since the youths had track records of juvenile behaviour to commit offences again. Causation After establishing the first two elements, the third element that needs to be established by Mark is the element of causation. In the ca se of Barnett v Kensington[16], the court adopted the à ¢Ã¢â€š ¬Ã…“but forà ¢Ã¢â€š ¬Ã‚  test in regards to factual causation. By referring to the question, it is certain that à ¢Ã¢â€š ¬Ã…“but forà ¢Ã¢â€š ¬Ã‚  the breach of duty of care by Justin and Jason the incident would not have occurred. Nevertheless, Justin and Jason might rely on novus actus interveniens by stating that the action of the youths, the fire brigade and the Amber Borough Council have break the chain of causation. It is highly likely that Justin and Jason will quote the case of Smith v Littlewood[17] stating that the youths broke the chain of causation by setting the fire. On the other hand, Mark could argue by distinguishing the facts in Smith as the cinema owners in that case did not know about previous acts of vandalism but on the facts the local residents reported that youths had broken into the site on a number of occasions. Remoteness of damage The final element of proof in negligence is whet her there is a causation in law, which also known as remoteness of damage. In order for Mark to succeed in claiming under negligence, it is essential for him to prove that the damage is not too remote. In the case of Wagon Mound 2[18], the court held that the defendants were liable even though the likelihood of harm was low, the seriousness of harm was high and it would have cost nothing to prevent it.[19] Therefore, by applying back to the case, it is highly likely that Justin and Jason would be held liable for the property damage suffered by Mark due to the seriousness of harm and the likelihood of the youths to cause damage. Even though Justin and Jason would argue based on the case of Wagon Mound 1[20] which lies the test of whether the damage is of a kind that was foreseeable and argue that the damage caused by the youths was unforeseeable, it is likely that they would fail. Thus, Mark would be successful in claiming from Justin and Jason. Chigley Services In order to act in the best interest of the client, we could advise Mark to bring an action against Chigley Services under the tort of vicarious liability to claim for damages since Justin and Jason are the employees of Chigley Services. This is because an employer will be in the best financial position to meet a claim rather than an individual and therefore, Mark would be able to claim a higher amount of damage. The tort of vicarious liability is a form of joint liability since an employer is being made liable for the tort committed by his employee. In pursuance of establishing vicarious liability, there are a few elements that need to be established. First and foremost, whether the person committing the primary tort is an employee; secondly, was there a tort that has been committed; and thirdly, was the tort committed in the course of employment or so closely connected to the employment. The court would refer to the Employment Rights Act 1996[21] in determining the employment status. It is no do ubt that Chigley Services is the employer of Justin and Jason and both of them had committed tort. Hence, the only issue that we need to consider would be whether the tort committed was in the course of employment. Mark would argue that both Justin and Jason had carried out an authorised act in an unauthorised manner by having a cigarette break owing to the case of Century Insurance v Northern Ireland Transport Board[22]. Per contra, Chigley Services could bring in the case of Hilton v Thomas Burton[23] to support their rebutment by stating that the tort was committed outside the course of employment and Justin and Jason were à ¢Ã¢â€š ¬Ã…“on a frolicà ¢Ã¢â€š ¬Ã‚ . Therefore, Mark would not be likely to succeed in claiming from Chigley Services by virtue of this case. Home Office Duty of Care Based on the neighbor principle in Donoghue, it is possible for Mark to bring his case against the Home Office to claim for economic loss under the tort of negligence. As discussed above, Mark needs to satisfy the four elements as required so that his claim would be successful. Therefore, the Caparo test would be used again to consider whether the Home Office owes Mark a duty of care. However, it must be noted that since the Home Office is a public authority and act under a statutory duty, the courts are withdrawn from imposing duty due to policy reasons. Policy Reasons The policy reasons are the main consideration for the courts to decide whether or not to impose liability. As stated by Winfield and Jolowicz, à ¢Ã¢â€š ¬Ã…“the court must decide not simply whether there is or is not a duty, but whether there should or should not be one.à ¢Ã¢â€š ¬Ã‚ [24] The liability of public authorities is subjected into misfeasance and non-feasance. In this case, it would be a non-feasance liability and the traditional approach is in the case of Home Office v Dorset Yacht [25] which is very similar to the present case. In Dorset, it was held that the Home Office owes a duty of care towards the claimant as they were in control of the 3rd party and was reasonably foreseeable that harm would result in their action. On the other hand, the Home Office could support their argument by using the case of Lamb v London Borough of Camden[26] as Lord Denning, for a unanimous court, rejects the Home Officeà ¢Ã¢â€š ¬Ã¢â€ž ¢s test for being too expansive and allowing damages to be assessed when they should not. He further stated that in all of these types of cases what really lies behind the judicial decisions is public policy.[27] Besides, the Home Office could reinforce their argument by stating that there was no sufficient proximity between Mark and the Home Office as per the case of K v Secretary of the State for the Home Department[28]. Hence, the court would not impose liability on the Home Office based on policy reasons. Fire Brigade Further, Mark could bring an action against the fire brigade under negligence. Without doubt, it is reasonabl y foreseeable that the fire would continue to spread and caused injury or property damage due to the negligence of the fire brigade and therefore the issue of proximity will be accessed. Based on the case of Hill v CC of West Yorkshire[29], the court will generally render insufficient proximity between public authority and general public. However, Mark could cite the case of Kent v Griffiths[30] to strengthen his argument that the fire brigade owed him a duty of care and there was sufficient proximity between the parties. In this case, Lord Reid stated that if a person who is foreseeable to suffer further injuries by a delay in providing an ambulance and there was no reason why it should not be provided, it is important in establishing the necessary proximity and duty of care in the case. On the other hand, the fire brigade would rely on the case of John Munroe v London Fire and Civil Defence Authority[31] to exclude liability. The fire brigade could distinguish Kent by stating that in the present case, the Amber Valley Fire Brigade was unavailable at that time, which means that they had other duties to carry out aside from Markà ¢Ã¢â€š ¬Ã¢â€ž ¢s. Besides, the other fire engine dispatched from Leicester who got lost because they put the wrong address in the sat-nav may be acceptable as they might be unfamiliar of Amber Valley. Thus, the court would discharge the fire brigadeà ¢Ã¢â€š ¬Ã¢â€ž ¢s liability due to policy reasons. ABC Last but not least, Mark could pursue an action under negligence to claim from ABC as well. The duty of care will be establish if Mark able to satisfy the Caparo test as discussed above. Since the site had broken into on a number of occasions, ABC could be found reasonably liable and there was sufficient proximity between the parties since the bakery shop was nearby the school. The question will lie on whether ABC had breach the duty of care. Mark could apply the case of Miller v Jackson[32] in contrast with Bolton v Stone[33] at his favor. Due to the site was broken into on a couple of times, the likelihood of injury would be high and therefore ABC would be in breach of duty. Besides, the à ¢Ã¢â€š ¬Ã…“but for testà ¢Ã¢â€š ¬Ã‚  also in favor of Mark because à ¢Ã¢â€š ¬Ã…“but forà ¢Ã¢â€š ¬Ã‚  the breach of ABC the youth would not have enter into the site and conduct any offences. However, ABC could challenge on the ground of legal causation and held that the damage done was too remote by relying on Wagon Mound 1. Thus, Mark would be likely to fail in his claim. Conclusion In a nutshell, Mark could pursue an action against these parties but he will only be successful in claiming damages from Justin and Jason. 1 [1] Catherine Elliott Frances Quinn, Tort Law ( 7th edition, Pearson Education Limited 2009 ) pg.27 [2] Spartan Steel Alloys Ltd v Martin [1972] 3 WLR 502 [3] Marc Rich v Bishop Rock Marine [1996]1 AC 212 (HL) [4] Blyth v Birmingham Waterworks Company [1856] 11 Ex Ch 781 [5] Ibid. [6] Lochgelly Iron and Coal Co. v. McMullan [1934] AC1, 25 [7] Donoghue v Stevenson [1932] UKHL 100 [8] Ibid [9] Anns v Merton London Borough Council [1978] A.C. 728 [10] Caparo Industries plc v Dickman [1990] UKHL 2 [11] Page v Smith [1995] UKHL 7 [12] Ibid [13] Topp v London Country Bus (South West) Ltd [1993] CA [14] Sutherland Shire Council v Heyman (1985) 157 CLR 424 [15] Walker v Northumberland County Council [1995] IRLR 35 [16] Barnett v Chelsea Kensington Hospital Management Committee [1968] 1 All ER 1068 [17] Smith v Littlewoods Organisation Ltd [1987] UKHL 18 [18] Overseas Tankship (UK) Ltd v The Miller Steamship Co or Wagon Mound (No. 2) [ 1967] 1 AC 617 [19] Available at https://www.e-lawresources.co.uk/The-Wagon-Mound-No-2.php accessed 17th January 2014 [20] Overseas Tankship (UK) Ltd v Morts Dock and Engineering Co Ltd or Wagon Mound (No. 1) [1961] UKPC 1 [21] Employment Rights Act 1996 [22] Century Insurance Co v Northern Ireland Road Transport Board [1942] AC 509 [23] Hilton v Thomas Burton (Rhodes) Ltd [1961] [24] Chris Turner Sue Hodge, Unlocking Torts (3rd edition, Hodder Education, 2010) [25] Home Office v Dorset Yacht Co Ltd [1970] UKHL 2 [26] Lamb v London Borough of Camden [1981]2 All ER 408 (CA) [27] Ibid [28] K v Secretary of the State for the Home Department [2002] EWCA Civ 983 [29] Hill v Chief Constable of West Yorkshire [1988] 2 WLR 1049 [30] Kent v Griffiths [2000] 2 All ER 474 [31] John Munroe v London Fire and Civil Defence Authority [1997] QB 1004 (CA) [32] Miller v Jackson [1977] QB 966 [33] Bolton v. Stone [1951] AC 850, [1951] 1 All ER 1078