Cases

1. Commonwealth v State of Tasmania http://en. wikipedia. org/wiki/Commonwealth_v_Tasmania 2. Lee v Knapp In Lee v Knapp [1967] 2 QB 442 an Act required that a motorist â€Å"stop† after an accident. The defendant claimed that they did in fact momentarily halt, before proceeding, therefore complying with a commonly accepted literal meaning of â€Å"stop†. The judge found that in this circumstance â€Å"stop† meant halt and wait for police or other officials to investigate the accident. A literal interpretation was against the purpose of the law. 3a Smith v Hughes SMITH v HUGHES (1960) 1 WLR 830 LORD PARKER CJ: These are six appeals by way of case stated by one of the stipendiary magistrates sitting at Bow Street, before whom informations were preferred by police officers against the defendants, in each case that she ‘being a common prostitute, did solicit in a street for the purpose of prostitution, contrary to section 1 (1) of the Street Offences Act, 1959. ’ The magistrate in each case found that the defendant was a common prostitute, that she had solicited and that the solicitation was in a street, and in each case fined the defendant. The facts, to all intents and purposes, raise the same point in each case; there are minute differences. The appellants in each case were not themselves physically in the street but were in a house adjoining the street. In one case the appellant was on a balcony and she attracted the attention of men in the street by tapping and calling down to them. In other cases the appellants were in ground-floor windows, either closed or half open, and in another case in a first-floor window. The sole question here is whether in those circumstances each appellant was soliciting in a street or public place. The words of s. 1 (1) of the Act are in this form: ‘It shall be an offence for a common prostitute to loiter or solicit in a street or public place for the purpose of prostitution. ’ Observe that it does not say there specifically that the person who is doing the soliciting must be in the street. Equally it does not say that it is enough if the person who receives the solicitation or to whom it is addressed is in the street. For my part, I approach the matter by considering what is the mischief aimed at by this Act. Everybody knows that this was an Act intended to clean up the streets, to enable people to walk along the streets without being molested or solicited by common prostitutes. Viewed in that way, it can matter little whether the prostitute is soliciting while in the street or is standing in a doorway or on a balcony, or at a window, or whether the window is shut or open or half open; in each case her solicitation is projected to and addressed to somebody walking in the street. For my part, I am content to base my decision on that ground and that ground alone. I think that the magistrate came to a correct conclusion in each case, and that these appeals should be dismissed. LORD PARKER CJ: These are six appeals by way of Cases Stated by one of the stipendiary magistrates sitting at Bow Street, before whom informations were preferred by the respondent in each case against the appellant for that she ‘being a common prostitute, did solicit in a street for the purpose of prostitution, contrary to s 1(1) of the Street Offences Act, 1959. The magistrate in each case found that the appellant was a common prostitute, that she had solicited and that the solicitation was in a street, and in each case fined the appellant. The facts, to all intents and purposes, raise the same point in each case; there are minute differences. The appellants in each case were not themselves physically in the street but were in a house adjoining the street. In one case the appellant was on a balcony and she attracted the ttention of men in the street by tapping and calling down to them. In other cases the appellants were in ground-floor windows, either closed or half open, and in another case in a first-floor window. The sole question here is whether in those circumstances each appellant was soliciting in a street or public place. The words of s 1(1) of the Act are in this form: ‘It shall be an offence for a common prostitute to loiter or solicit in a street or public place for the purpose of prostitution. ’ Observe that it does not say there specifically that the person who is doing the soliciting must be in the street. Equally it does not say that it is enough if the person who receives the solicitation or to whom it is addressed is in the street. For my part, I approach the matter by considering what is the mischief aimed at by this Act. Everybody knows that this was an Act intended to clean up the streets, to enable people to walk along the streets without being molested or solicited by common prostitutes. Viewed in that way, it can matter little whether the prostitute is soliciting while in the street or is standing in a doorway or on a balcony, or at a window, or whether the window is shut or open or half open; in each case her solicitation is projected to and addressed to somebody walking in the street. For my part, I am content to base my decision on that ground and that ground alone. I think that the magistrate came to a correct conclusion in each case, and that these appeals should be dismissed. HILBERY J: I agree. 9, Curzon Street, from the papers in front of us, appears to be let to two prostitutes who practise their profession from that address, and the way of practising it is shown by the Cases Stated, as my Lord has said; in one case by tapping on the window pane with some metal object as men passed by in the street in front of her, and then openly inviting them into her room. In the other cases it was done by tapping on the windows of various rooms occupied by these prostit utes and then, if the window was open, giving nvitations by way of solicitation or signals representing solicitation. In each case signals were intended to solicit men passing by in the street. They did effect solicitation of the men when they reached those men. At that moment the person in the street to whom the signal was addressed was solicited and, being solicited in the street, I agree with the conclusion of my Lord and for these reasons I have intimated that these appeals must be dismissed. DONOVAN J: I agree with both the judgments which have been delivered. Cases stated These were appeals by Cases Stated from the adjudications of one of the magistrates of the police courts of the metropolis sitting at Bow Street Magistrates’ Court as a magistrates’ court, before whom informations were preferred on 27 November 1959, 8 December 1959, 5 January 1960 and on a day unknown in 1960 by the respondents, police officers, that the appellants, Marie Theresa Smith and Christine Tolan being common prostitutes, did solicit in a street for the purpose of prostitution, contrary to s 1(1) of the Street Offences Act, 1959. There were two informations against Marie Theresa Smith, which were heard on 4 February 1960, when the following facts were found. The appellant was a common prostitute, living at 39, Curzon Street, W1, and using the premises for the purposes of prostitution. That on 4 November 1959, between 8. 50 pm and 9. 5 pm the appellant solicited men passing in the street for the purposes of prostitution from a first floor balcony of 39, Curzon Street, the balcony being some eight to ten feet above street level. The appellant’s method of soliciting the men was (i) to attract their attention to her by tapping on the balcony railing with some metal object and by hissing to them as they passed in the street beneath her, and (ii) having so attracted their attention, to talk with them and invite them to come inside the said premises by such words as ‘Would you like to come up here a little while? ’ at the same time as she indicated the correct door of the premises. That on 9 January 1960, between 12. 0 am and 1 am the appellant solicited men passing in the street for the purposes of prostitution from a closed ground floor window of 39, Curzon Street, the window being some three feet from railings, four feet high, which bounded the pavement on the side of the premises. That the appellant’s method of soliciting the men was (i) to attract their attention to her by tapping on the window pane with some metal object as they passed by in the street in front of her and (ii) hav ing so attracted their attention, to invite them in for a price which she indicated by extending three fingers of her hand and indicating the correct door of the premises. That on one occasion the price so indicated by the appellant was agreed and the man entered the premises, leaving some fifteen minutes later. On another occasion the price so indicated by the appellant was not agreed by the man concerned, who made a counter-proposal as to price by extending two fingers of his hand. This counter-proposal was not accepted by the appellant and the man walked away. There were four informations against Christine Tolan which were heard on 4 February 1960, two being heard also on 8 February 1960, when the following facts were found. That the appellant was a common prostitute living at 39, Curzon Street, London, W1, and using the premises for the purposes of prostitution. That on 4 November 1959, between 9. 25 pm and 9. 35 pm the appellant solicited men passing in the street for the purposes of prostitution from a half-open ground floor window of 39, Curzon Street, the window being some three feet from four feet high railings which bounded the pavement on the side of the premises. That the appellant’s method of soliciting the men was (i) to attract their attention to her by half leaning out of the window towards the men as they passed by in the street in front of her and (ii), having so attracted their attention, to talk with them and invite them inside the premises by such words as ‘A short time for ? 3’ at the same time as she indicated the correct door of the said premises. That on 4 December 1959, at about 10. 50 pm the appellant solicited men passing in the street for the purposes of prostitution from a ground floor window of 39, Curzon Street. That the appellant’s method of soliciting the men was (i) to attract their attention to her by tapping on the window pane with some metal object as they passed by in the street in front of her and (ii), having so attracted their attention, to invite them inside the premises by smiling and indicating the correct door of the premises. That on one occasion a man accepted the appellant’s suggestion and went towards the door of 39, Curzon Street, which the appellant was holding open ready for him to enter. However, when a police officer came up, the appellant hastily slammed the door and the man left (not having entered the premises). About five minutes later a second man left the premises. That on 5 December 1959, at about 10. 40 pm the appellant solicited men passing in the street for the purposes of prostitution from a closed ground floor window of 39, Curzon Street. That the appellant’s method of soliciting the men was to attract their attention to her by tapping on the window pane with some metal object as they passed by in the street in front of her and (ii) having so attracted their attention to talk to them and invite them inside the said premises at the same time as she indicated the correct door of the said premises. That on 15 December 1959, between 10. 30 pm and 10. 50 pm the appellant solicited men passing in the street for the purposes of prostitution from a partly open first floor window of 39, Curzon Street, the window being about ten feet above street level. That the appellant’s method of soliciting the men was (i) to attract their attention to her by tapping on the window pane with some metal object as they passed by in the street beneath her and (ii) having so attracted their attention, to invite them in by gestures and for a price she indicated by extending three fingers of her hand and indicating the correct door of the premises. It was contended for the appellants that the balcony; the interior of the premises behind a closed or half closed window on the ground floor; and the interior of a building behind a slightly open window on the first floor were not ‘in a street’ within the meaning of s 1(1) of the Street Offences Act, 1959, and accordingly no offence had been committed. It was contended for the respondents that the soliciting had taken place ‘in a street’ within the meaning of that Act. The magistrate was of opinion that the said soliciting had taken place ‘in a street’ within the meaning of s 1(1) of the Street Offences Act, 1959, and accordingly convicted the appellants. 3. Carlill v Carbolic Smoke Ball Co. [1983] 1QB 256 (p259) Background The British influenza epidemic of 1891-92 extracted a heavy toll on human life. To the purveyors of quack medicines it provided a wonderful opportunity. The last decade of the nineteenth century was the golden age of quackey and the carbolic smoke ball patented by Frederick Roe in December 1989 was merely one of a range of devices that were aggressively promoted to a naive public at that time. Roe’s patent application described his smoke ball as ‘An improved device for facilitating the distribution, inhalation and application of medicated and other powder’ Although the patent specification envisaged other powders being used, Roe confined himself to using carbolic acid or phenol in powder form, this being the standard germ killer of the time. Early advertisement for this smoke ball made typically extravagant claims: Will positively cure Influenza, catarrh, Asthma, Bronchitis, Hay fever, Neuralgia, Throat deafness, Hoarseness, Loss of voice, Whooping cough, Croup, Coughs, Colds, and all other ailments caused by Taking cold. Facts An advertisement that offered a reward of ? 100 ‘ to any person who contracts the increasing epidemic, influenza, colds,†¦after having used the ball according to the printed directions’. Gave rise to litigation. The company was so convinced of the infallibility of its product that its advertisement pointed out that it had deposited the sum of ? 000 with its bank as ‘proof of its sincerity’. The advertisement that gave rise to the litigation first appeared in the Pall Mall Gazette on 13 November 1891. Mrs Carlill bought a carbolic smoke ball from a chemist shop, and used it three times daily for two weeks in accordance with the written instructions, she nevertheless c ontracted influenza. When the company refused to pay the ? 100 reward, Mrs Carlill sued for breach of contract. Issues In this defence the Carbolic smoke ball co. raised virtually every possible argument that was available to deny the existence of a contract. In summary he company argued that: †¢ The newspaper advertisement was not an offer †¢ Even if it was an offer, Mrs Carlill had not validly accepted the offer. †¢ Even if she had, the arrangement was not intended to create the legal relations †¢ Even if it was, she had provided no consideration in exchange for the company’s promise †¢ Even if a contract had been formed, it was of no effect since it failed to meet certain statutory requirements. Decision The English court of appeal dismissed all of these arguments and held that a valid contract had been formed and consequently Mrs Carlill was entitled to the ? 100. Implications For present purposes, the main implications of the case are in the way that court of appeal rejected the various arguments advanced to suggest that the advertisement didn’t constitute an offer. The company’s argument that the advertisement was not a statement that people would take seriously (it was a ‘mere puff’) was rejected by reference to the statement that ? 1000 had been deposited with the Alliance Bank to show the company’s ‘sincerity in the matter’. Lindley LJ(at 261) stated: Now, for what was the money deposited or that statement made except to negative the suggestion that this was a mere puff and meant nothing at all? The deposite is called in aid by the advertiser as proof of his sincerity in the matter- that is, the sincerity of his promise to pay this ? 100 in the event which he has specified. I say this for the purpose of giving that point to the observation that we are not interring a promise, there is the promise, as plain as words can make it. The company argued that the advertisement was so vague and incomplete that reasonable people wouldn’t interpret it. To contain any legal promise. For example, the advertisement didn’t specify any time limit within which a person had to contract influenza in order for them to claim the reward. Neither was there any way for the company to check that smoke ball had been correctly used. Bowen LJ held that: The answer to that argument seems to me to be that if a person chooses to make extravagant promises of this kind he probably does so because it pays him to make them, and, if he has made them, the extravagance of the promises is no reason in law why he shouldn’t be bound by them. Lindley LJ conceded that the language was vague and uncertain in some respects but nevertheless considered that ‘business people or reasonable people ‘ would understand it to mean that ? 00 would be paid to anybody who used the smoke ball three times daily for two weeks according to the printed directions, and who contracted influenza within a reasonable time after so using it. In response to the company’s argument that an offer had to be directed at a particular person or persons and couldn not be made to the whole world. Browen LJ stated that: It was also said that the c ontract is made with all the world. †¦that is †¦with everybody, and that you can not contract with everybody. it is not a contract made with all the world. There is fallacy of the argument. It is an offer made to all the world,and why should not any offer be made to all the world which is to ripen into a contract with anybody who comes forward and performs the condition? It is an offer to become liable to any one who, before it is retracted, performs the condition, and although the offer is made to the world, the contract is made with that limited portion to the public who come forward and perform the condition on the faith of the advertisement. 4. Havey v Facey [1983] (p259) 5. Pharmaceutical society of Great Britain v Boots Cash Chemist (p258) 6. Fisher v Bell (p257) 7. Partridge v Crittenden (p257) 8. R. Clarke (p265) Clarke, had claimed ? 1000 from the police in the following circumstances. In May 1926 the commissioner of police gave notice by proclamation that he was authorized by the government of western Australia to ‘offer a reward of ? 1000 for such information as shall lead to the arrest and conviction of the person who committed the murders’ of an inspector of police and a sergeant of police, and that the governor would be advised to extend a free pardon to any accomplice not being the person who actually committed the murders who should first give the information. In June, one Treffene and Clarke were arrested and charged with one statement which led to the arrest of one coulter. Coulter and Treffene were convicted of the murder, Clarke giving evidence in accordance with is statement. Clarke was released and claimed the reward. The R alleged inter alia by way of defence that his statement was not made with a view to obtaining the reward. His petition was dismissed at first instance, the judge finding that he had not acted on the faith entering into any contract, but rather that he acted to save himself from the unfounded charge of murder. The plaintiff failed in an action to claim a reward offered for information leading to the conviction of a murderer. He knew of the reward but be admitted in court he gave the information to save himself from being charged with the murder and with the reward’ not present to his mind’. Higgins J, 241 stated that: The motive inducing consent maybe immaterial but the consent is vital. Without that there is no contract†¦Clark had seen the offer, indeed, but it was not present to his mind.. he had forgotten it, and gave no consideration to it, in his intense excitement as to his own danger. There can not be assent without knowledge of the offer, and ignorance of the offer is the same thing whether it is due to never hearing of it or forgetting it after hearing. (Acceptance must be made in reliance on the offer) 9. Hyde v Wrench June 6. The defendant wrote to the plaintiff offering to sell his farm for ? 1000. The plaintiff’s agent immediately called on the defendant, and made an offer of ? 920 which the defendant wished to have a few days to consider. June 27, the defendant wrote to say that he could not accept this offer. June 29, the plaintiff wrote ‘accepting’ the offer of June 6. The plaintiff brought an action for specific performance. The defendant filed a general demurrer. The Master of the rolls: Under the circumstances stated in this bill, I think there exists no valid binding contract between the parties for the purchase of the property. The defendant offered to sell it for? 1000, and if that had been at once unconditionally accepted, there would undoubtedly have been a perfect binding contract. Instead of that, the plaintiff made an offer of his own, to purchase the property for ? 950, and he thereby rejected the offer previously made by the defendant. I think that it was not fterwards competent for him to revive the proposal of the defendant, by tendering an acceptance of it, and that, therefore, there exists no obligation of any sort between the parties, the demurrer must be allowed. 10. Stevenson Jacques & Co. v McLean The plantiffs and the defendant were negotiating about the sale of a quantity of iron for which the defendant held warrants. Saturda y: The defendant wrote: â€Å"†¦I would now sell for 40s. net cash,open till Monday. † Monday: The plaintiffs telegraphed: â€Å"Please wire whether you would accept forty for delivery over two months, or if not, longest limit you would give. The defendant received the telegram at 10. 01am and subsequently sold the iron to a third party. 1. 25pm: the defendant telegraphed that he had sold the iron. 1. 3pm: the plaintiffs, having had no reply to their telegram, telegraphed again, accepting the offer to sell at 40s. cash. 1. 46pm: the defendant’s telegram arrived. The plaintiff sued for breach of contract, and the defendant objected that the telegram sent by the plaintiffs on the Monday morning was a rejection of the defendant’s offer and a new proposal on the plaintiffs’ part, and therefore that the defendant had a right to regard it as putting an end to the original negotiation. Lush J: Looking at the form of the telegram, the time when it was sent, and the state of the iron market, I can not think this is its fair meaning. The plaintiff Stevenson said he meant it only as an inquiry, expecting an answer for his guidance, and this, I think, is the sense in which the defendant ought to have regarded it. Stevenson, Jacques & Co v. McLean (1880) 5 QBD 346 is an English contract law case concerning the rules on communication of acceptance by telegraph. Its approach contrasts to the postal rule. McLean wrote to Stevenson, Jacques & Co. n Middlesbrough asking if he could get an offer for warrants on iron ore. He said 40s per ton in cash was the lowest price, the offer open till Monday. At 7. 42am, Stevenson telegraphed saying ‘Please wire whether you would accept forty for delivery over two months, or if not, longest limit you could give. ’ McLean did not answer, and sold at 1. 25pm to someone else. Stevenson, before hearing, telegraphed saying he had secured a price. McLean refused to deliver the iron, and Stevenson brought an action for non-delivery. Lush J held that the plaintiffs’ telegram at 9. 42 was not a rejection of the offer but a mere inquiry about whether the terms could be modified. Although McLean was at liberty to revoke the offer before Monday finished, that was not effective until it reached the plaintiffs. Therefore McLean’s offer was still open when Stevenson accepted it. 11. Power v Lee(266) 12. Felthouse v Bindley (p265) 13. Household Fire Insurance v Grant (267) 14. Holwell secutrities v Hughes (p267) 15. Brinkibon Ltd v Stahag Stahl und Stahlwarenhandelsgesellschaft mbH Brinkibon Ltd v Stahag Stahl [1983] 2 AC 34 is a leading decision of the House of Lords on the formation of a contract using telecommunication. The Lords largely accepted the earlier leading decision of Entores v Miles Far East Co. [1955] 2 QB 327 on acceptance via telex. Brinkibon was a London company that purchased steel from Stahag, a seller based in Austria. Brinkibon sent their acceptance to a Stahag offer by Telex to Vienna. Brinkibon later wanted to issue a writ against Stahag and applied serve an out of jurisdiction party. They would only be able to do so if the contract had been formed in England. The question at issue was where the contract was formed. The Lords decided that the contract was formed in Vienna. They accepted the principle in Entores v Miles Far East Co where in the case of instantaneous communication, which included telex, the formation occurs in the place where the acceptance is received. Lord Wilberforce, however, did not see the rule as applying to all circumstances: Since 1955 the use of Telex communication has been greatly expanded, and there are many variants on it. The senders and recipients may not be the principals to the contemplated contract. They may be servants or agents with limited authority. The message may not reach, or be intended to reach, the designated recipient immediately: messages may be sent out of office hours, or at night, with the intention, or on the assumption that they will be read at a later time. There may be some error or default at the recipient’s end which prevents receipt at the time contemplated and believed in by the sender. The message may have been sent and/or received through machines operated by third persons. And many other variants may occur. No universal rule can cover all such cases; they must be resolved by reference to the intentions of the parties, by sound business practice and in some cases by a judgement where the risks should lie. 16. Dickinson v Dodds (1876) (p261) Dodds offered to sell Dickson some houses for ? 800. This offer was stated ‘to be left over Friday, 9am’. However, Dodds sold the houses to someone else on the Thursday. Dickson heard of this sale indirectly but still handed Dodds a formal acceptance of the offer before 9am. Friday, it was held that no contract was formed with Dickson. The offer had been revoked before acceptance since Dickinson had actually received notice of the revocation even though this was not from the offeror. (General rule: an offer can be revoked (withdrawn or cancelled) by the offeror any time before it is accepted. A revocation is not effective until the offeree becomes aware of it. It is not necessary that offeror personally communicate the revocation to the offeree. It is sufficient if a reasonable person would be aware that the offer had been withdrawn. 17. Byrne & Co. v. Van Tienhoven & Co. October 1: The defendants, in Cardiff, posted a letter to the plaintiffs, in New York, offering to sell them 1000 boxes of tinplates. October 8: The defendants posted a letter revoking their offer. October 11:The plaintiffs telegraphed acceptance October 15: The plaintiffs confirmed their acceptance by letter. October 20: The defendants’ letter of revocation reached the plaintiffs. (Revocation is effective when it arrives. Postal acceptance Rule) 18. Rose & Frank Co. v Crompton & Bros. The defendant manufactured carbon paper in England. The plaintiff bought the defendant's paper and sold it in New York. After dealing with each other for a number of years they entered into a written agreement as to the plaintiff having exclusive rights to buy and sell the defendant's goods. The agreement stated: â€Å"This agreement is not a formal or legal agreement. It will not be subject to the jurisdiction of either the British or American courts. It is a record of the intention of the parties to which they honourably pledge themselves and is to be carried out with mutual loyalty and friendly co-operation. Following a series of disputes the plaintiff claimed that the defendant was in breach of the agreement and the trial judge held that it was legally binding. The defendant appealed and the Court Of Appeal overturned the decision – it was quite possible for parties to agree that a legal relationship would not be formed. Bankes LJ said that an intention to be legally bound was essential. With business arrangements it usual ly follows as a matter of course that legal relations are intended. Whilst it was â€Å"most improbable† that firms engaged in international business arrangements should not have intended legal consequences there is no legal obstacle to prevent them from doing so. He added further that there is no law or issue of public policy that should preclude this rule. Thus after reading the agreement in its ordinary meaning, he said â€Å"it is manifest that no action can be maintained on the basis of it. † (Intention to create relations) 19. Balfour v Balfour (p271) 20. Merritt v Merritt The court held that the presumption that agreements between husband and wife are not intended to create legal relations doesn’t apply when they are not living in amity but are separated or about to separate. H had left W and was living with another woman. He agreed to pay W ? 40 a month. And signed a written agreement that, in consideration of W’s paying off the mortgage on their jointly owned house, he would then transfer it to her sole ownership. W paid off the jointly owned house, he would then transfer it to her sole ownership. W paid off the mortgage, Stamp J, made a declaration that W was the sole beneficial owner. H’s appeal was dismissed. Lord Denning said:’In all these cases the court does not try to discover the intention by looking into the minds of the parties. It looks at the situation in which they were placed and asks itself: would reasonable people regard this agreement as intended to be binding? † (google)A husband and wife separated. They then met to make arrangements for the future. After this the husband agreed to pay ? 40 per month maintenance, out of which the wife would pay the mortgage. When the mortgage was paid off it was agreed he would transfer the house from joint names to the wife's name. He wrote this down and signed the paper, but later refused to transfer the house. It was held that when the agreement was made, the husband and wife were no longer living together, therefore they must have intended the agreement to be binding, as they would base their future actions on it. This intention was evidenced by the writing and therefore the husband had to transfer the house to the wife. 21. Jones v Vernons Pools Ltd (p272) 22. White v Bluett (p277) 23. Roscorla v Thomas (p277) 24. Re Casey’s Patents (google) A and B owned a patent and C was the manager who had worked on it for two years. A and B then promised C a one-third share in the invention for his help in developing it. The patents were transferred to C but A and B then claimed their return. It was held that C could rely on the agreement. Even though C's consideration was in the past, it had been done in a business situation, at the request of A and B and it was understood by both sides that C would be paid and the subsequent promise to pay merely fixed the amount. (past consideration is good if: Must be done at the promisor's request Parties understand that the act was to be rewarded. Payment must have been legally enforceable had it been promised in advance) 25. Collins v Godefroy This case (Collins v Godefroy [1831] 1 BAd 950) is the archetype of cases where a duty imposed by law cannot be taken as Consideration to support a Contract. Godefroy promised Collins six guineas if he would attend court to testify on his behalf. At his agreement, Collins was subpeonaed. Godefroy refused to pay. In his defence, he claimed that there was no consideration moving from Collins, as he was obliged to attend court anyway. This view was upheld by the court. (It was held that as Collins was under a legal duty to attend court he had not provided consideration. His action therefore failed. ) 26. Ward v Byham The father of an illegitimate child agreed to pay the mother a sum of money for maintenance, provided that the child be well looked after and happy, and that the mother offer the child the choice of which parent to live with when she was old enough to understand. The father made payments until the child's mother married, and then he refused. The mother sued for breach of contract. The father's defence was that there was no consideration to the agreement, as the mother was legally obligated to care for the child. The Court of Appeal ruled that the mother had exceeded her statutory duty by bringing up the child in a particular way, and in accordance with the wishes of the father, and this was sufficient consideration. (Do more than public duty is good consideration) 27. Dunton v Dunton (p277) 28. Glasbrook Brothers Ltd v Glamorgan County Council (p278) 29. Stilk v Myrick (p278) 30. Musumeci v Winadell Pty Ltd (p278) 31. Shadwell v Shadwell (279) 32. Hartley v Ponsonby (p279) 33. Pinnel’s case ( ) The plaintiff sued the defendant for the sum of ? 8 10s. The defence was based on the fact that the defendant had, at the plaintiff's request, tendered ? 5-2s-6d before the debt was due, which the plaintiff had accepted in full satisfaction for the debt. payment of a lesser sum on the day in satisfaction of a greater, cannot be any satisfaction for the whole, because it appears to the Judges that by no possibility, a lesser sum can be a satisfaction to the plaintiff for a greater sum: but the gift of a horse, hawk, or robe, etc. in satisfaction is good†¦ [as] more beneficial to the plaintiff than the money. The rule is obiter dicta. In Pinnel's Case itself the debt was paid before the date of satisfaction, which was considered good consideration. 34. Foakes v Beer (p279) 35. Central London property Thust Ltd. v High Tress house Ltd. (p281) 36. Waltons Stores (interstate)Ltd. v Macher (p281) 37. Donoghue v Stevenson (p172) 38. Perre v Apand (p201) 39. Bolton v Stone (p187) 40. Haley v London Electricity Board (photocopy) 41. Pairs v Stepney BC (p190) 42. WATT v HERTFORDSHIRE COUNTY COUNCIL [1954] 1 WLR 835 DENNING LJ: †¦ It is well settled that in measuring due care one must balance the risk against the measures necessary to eliminate the risk. To that proposition there ought to be added this. One must balance the risk against the end to be achieved. If this accident had occurred in a commercial enterprise without any emergency, there could be no doubt that the servant would succeed. But the commercial end to make profit is very different from the human end to save life or limb. The saving of life or limb justifies taking considerable risk, and I am glad to say there have never been wanting in this country men of courage ready to take those risks, notably in the fire service. In this case the risk involved in sending out the lorry was not so great as to prohibit the attempt to save life. I quite agree that fire engines, ambulances and doctors’ cars should not shoot past the traffic lights when they show a red light. That is because the risk is too great to warrant the incurring of the danger. It is always a question of balancing the risk against the end. Full text SINGLETON LJ: The plaintiff was employed in the fire service under the control of the defendants and he was stationed at Watford. He had a serious accident on 27 July 1951, as a result of which he brought this action, claiming damages for negligence. His case is that the defendants undertook to exercise the care which they owed to him and to other men employed in the fire service, and he gives particulars of negligence. There are always firemen on duty at the fire station at Watford, and on 27 July 1951, an emergency call was received there to the effect that there had been an accident and that a woman was trapped under a heavy vehicle about two hundred or three hundred yards away. In view of the nature of the emergency the officer in charge, Sub-officer Richards, gave directions that two teams of men should go out, and he himself went with the first team. It was clear that there might be need for lifting apparatus of some kind, and at the fire station there was a jack capable of raising heavy weights. The jack did not belong to the fire service. It was the property of London Transport Executive, whose practice it is to lend out jacks of this kind to various fire stations, and, perhaps, to other bodies, so that they can be on call in case of need. Thus, the jack was on loan to the defendants at this fire station. It is only on rare occasions that there is an emergency call requiring the services of a jack of this kind. The plaintiff had been in the fire service in Hertfordshire since 1939, and he had only known of one emergency call on which a jack was required. The defendants had an Austin vehicle fitted to carry this jack. The fire station at Watford is not a large one, and it had not a great many vehicles. The Austin vehicle was the only one fitted to carry the jack, but it was not kept purely for that purpose. It had other services to perform during part of the week, and on this day it was properly out on other service. The jack stands on four small wheels, two of which are castored, which means that they may turn all the way round the circle. There was at the fire station only one vehicle on which the jack could be carried in the absence of the Austin vehicle, a Fordson lorry, and before leaving with his team Sub-officer Richards told the leading fireman in charge of the second team, of which the plaintiff was a member, to take the jack on the lorry. Consequently, the five men in the second team lifted up the jack, which weighed between two and three hundredweight, and put it on to the flat Fordson lorry, which had boards at the sides and a tailboard. They got on the lorry themselves, two in the front seat, and three sitting in the body. The plaintiff was in the forward part of the body on the right-hand side, and the other two men there were, perhaps, a little further back and on the other side, and they held the jack somehow. Obviously there might be movement of the jack in the lorry, for there were no means of securing it, no place on which anything could be tied, and no built-in system which would prevent movement. There was, therefore, a risk. The men knew what they were doing. They started their journey, which was only two hundred or three hundred yards. But on the way something happened to cause the driver to apply his brakes suddenly, the jack moved inside the lorry, the plaintiff’s leg was caught, and he was injured. In these circumstances he claimed that the defendants, his employers, were negligent in that they ‘(a) failed to load or secure the said lifting jack in such a way that it could not become dislodged;(b) loaded the said lifting jack in such a way that they knew or ought to have known it was likely that if the said lorry pulled up suddenly the same would become dislodged and cause injuries to any person riding on the back of the said lorry;(c) permitted and/or caused the laintiff to ride on the back of the said lorry on to which the said lifting jack had been loaded as aforesaid;(d) caused or permitted the said jack to be transported on the said lorry which as the defendants knew or ought to have known was not provided with clips straps or other suitable means to secure the same;(e) failed to provide any or any adequate supervision of the loading of the said jack on to the said lorry’; and it was claimed that the plaintiff’s accident was due to negligence, and that he was entitled to recover damages against the defendants. Barry J heard the action, and on 16 December 1953, he gave judgment in favour of the defendants, holding that it was not shown that they had been guilty of any negligence towards the plaintiff or towards their other employees. I am in complete agreement with his judgment. The fire service is a service which must always involve risk for those who are employed in it, and, as counsel for the plaintiff pointed out, they are entitled to expect that their equipment shall be as good as reasonable care can secure. An emergency arose as often happens. Mr Richards, the sub-officer who had given the order, was asked in re-examination: ‘From your point of view you thought it was a piece of luck, with this unfortunate woman under the bus, that the Fordson was available and you could use it? A. – Yes. It is recognised in the service that we use our initiative at all times, and in doing so any reasonable step you take is considered satisfactory if it is a question of saving life. You have to make a sudden decision. ’ It is not alleged that there was negligence on the part of any particular individual, that the driver was negligent in driving too fast, or that Sub-officer Richards was negligent in giving the order which he did. The case put forward by counsel for the plaintiff in this court is that, as the defendants had a jack, it was their duty to have a vehicle fitted in all respects to carry that jack, from which it follows, I suppose, that it is said a vehicle must be kept at the fire station at all times, or that, if there is not one, the lifting jack must not be taken out. Indeed, counsel claimed that, in the case of such an occurrence as this, if there was no vehicle fitted to carry the jack, the sub-officer ought to have telephoned to the fire station at St Albans and arranged that they should attend to the emergency. St Albans is some seven miles away, and it was said an extra ten minutes or so would have elapsed if that had been done. I cannot think that is the right way to approach the matter. There was a real emergency. The woman was under a heavy vehicle. These men in the fire service thought they ought to go promptly, and thought they ought to take a lifting jack, and they did so. Most unfortunately this accident to the plaintiff happened. The duty owed by employers has been stated often. Lord Herschell in Smith v Baker & Sons said ([1891] AC 362): ‘It is quite clear that the contract between employer and employed involves on the part of the former the duty of taking reasonable care to provide proper appliances, and to maintain them in a proper condition, and so to carry on his operations as not to subject those employed by him to unnecessary risk. The employee in this case was a member of the fire service, who always undertake some risk, though, according to counsel for the plaintiff, not this risk. Is it to be said that, if an emergency call reaches a fire station, the person in charge has to ponder on the matter in this way: Must I send out my men with the lifting jack in these circumstances, or must I telephone to St Albans , seven miles away, to ask them to undertake the task? I suppose he must think about his duty, but what would a reasonable man do placed as he was? Would the reasonably careful head of the station have done anything other than that which Sub-officer Richards did? I think not. Can it be said, then, that there is a duty on the employers here, the defendants, to have a vehicle built and fitted to carry this jack at all times, or, if they have not, not to take the jack for a short journey of two or three hundred yards? I do not think that will do. Asquith LJ in Daborn v Bath Tramways Motor Co Ltd & Trevor Smithey said ([4946] 2 All ER 336): ‘In determining whether a party is negligent, the standard of reasonable care is that which is reasonably to be demanded in the circumstances. A relevant circumstance to take into account may be the importance of the end to be served by behaving in this way or in that. As has often been pointed out, if all the trains in this country were restricted to a speed of five miles an hour, there would be fewer accidents, but our national life would be intolerably slowed down. The purpose to be served, if sufficiently important, justifies the assumption of abnormal risk. ’ The purpose to be served in this case was the saving of life. The men were prepared to take that risk. They were not, in my view, called on to take any risk other than that which normally might be encountered in this service. I agree with Barry J that, on the whole of the evidence which was given, it would not be right to find that the defendants as employers were guilty of any failure of the duty which they owed to their workmen. In my opinion, the appeal should be dismissed. DENNING LJ: It is well settled that in measuring due care one must balance the risk against the measures necessary to eliminate the risk. To that proposition there ought to be added this. One must balance the risk against the end to be achieved. If this accident had occurred in a commercial enterprise without any emergency, there could be no doubt that the servant would succeed. But the commercial end to make profit is very different from the human end to save life or limb. The saving of life or limb justifies taking considerable risk, and I am glad to say there have never been wanting in this country men of courage ready to take those risks, notably in the fire service. In this case the risk involved in sending out the lorry was not so great as to prohibit the attempt to save life. I quite agree that fire engines, ambulances and doctors’ cars should not shoot past the traffic lights when they show a red light. That is because the risk is too great to warrant the incurring of the danger. It is always a question of balancing the risk against the end. I agree with my Lord that this appeal should be dismissed. MORRIS LJ: I also agree. The accident in this case came about as a result of a somewhat unusual concatenation of circumstances. There had for a long time been no call for the use of the jack. Any such call, according to the evidence, was extremely rare. It so happened that a call came at a time when the Austin vehicle which would normally have carried the jack was otherwise engaged. I do not think it can be said to have been unreasonable to have had the Austin vehicle for use in the way that was arranged. Had the fire station been larger, had there been unlimited resources, unlimited space, and an unlimited number of vehicles, then it may be that another fitted vehicle would have been available. But that was not reasonably practicable or possible. When the call for the jack came, Mr Richards had to decide what to do, and I do not think that it would have been in accordance with the traditions of the fire service if he had said that he could do nothing other than call on St Albans. What he decided to do was in accordance with the practice of the fire service. Mr Bottin, the assistant chief officer in the London Fire Brigade, speaking of the provision of jacks, pointed out that in London there are twenty-nine sets of lifting gear, one being provided for every two stations. He said in evidence: ‘Q. Can you always undertake that that one vehicle will be available for the transport of a jack? A. – No. Q. – In your view is it reasonably practicable for a fire service to adapt all of its vehicles for the transport of jacks? A. – No. I would not think it was reasonable. Q. – You have been a station officer, have you not? A. – I have. Q. – Supposing you found yourself in charge of a stati on, and supposing the equipment available was not that most suitable for the purpose but you found that human life was in danger and you might save it by adopting a method not entirely suitable, what in your view would be your duty as a station officer? A. – I have had that experience, and I did not hesitate to get the equipment there as quickly as possible. ’ As I have said, I think Mr Richards acted in accordance with the traditions of the service, and I cannot for one moment think that the employers could be held responsible as having failed in the performance of their duties. I agree that the appeal fails. 43. Rogers v Whitaker (p189) 44. Barnett v Chelsea Hospital 45. March v E. & M. H Stramare Pty. Ltd.

Food and the Endless Waltz Essay

Akira Kurosawa’s seminal work Seven Samurai is a stirring and heart-rending commentary on 16th century Japan. The movie focuses on the rigid caste system of Japan where warriors fight while peasants farm to support them. The film’s artistic value makes it worthy of being called a Kurosawa masterpiece. However, it is in the lesson the film seeks to impart that is perhaps where the true genius of Kurosawa is seen. Set in the Sengoku Jidai, the century of war, the haughty warrior class are locked in an endless waltz of bloodshed while the food producing peasant, the true heart of Japan, are ignored though they always win in the end. For pure production value alone Seven Samurai was a masterpiece. Kurosawa introduced a number of filming techniques that would soon be mainstream fare for action films the world over. One example is the use of slow motion filming to emphasize the death of a main character. It was also the most expensive Japanese film of its time and is possibly the most successful Japanese film period. The premise of the film is as common as rice in Sengoku Jidai Japan. A group of bandits, either masterless samurai called Ronin or desperate peasants driven to banditry by the loss of their farms to the constant warfare, are terrorizing a village. Peasants lacking the skills and weapons to fight back they seek help from the Gentleman Warrior class known as Samurai. After much hardship they find Seven Samurai, well six considering that Kikuchiyo was just a pretender, who after much blood shed succeed in fending of the bandit. Ironically, instead of a victory parade or laurels they are ostracized by the people they just bled for. The main theme is the separation between the Warrior class and the peasants. The peasants humbly admit that they are incapable of fighting and are forced to go to the city and recruit Samurai who are willing to fight for mere three meals a day since that is all they can afford to pay. The haughty Samurai reject this offer since, as member of the gentleman warrior class they deserve better than three peasant meals a day as wages for their services. With the help of a grizzled veteran Samurai named Kanbei they managed to recruit Six Samurai plus a straggler named Kikuchiyo. They receive a cold welcome from the other villagers who fear them as much as they feared the bandits. This theme continues to be played out during the movie. In the past wounded, fleeing Samurai were killed and robbed by the villagers when the Samurai sought refuge there. The Seven Samurai are enraged at this brutality and nearly turn on their employers. The farmers are worried that the Samurai would take their young women and in fact one of the Samurai does carry on an affair with a village daughter. All this is the result of the age old tradition that only certain worthy individuals could become Samurai warriors. The rest of the rural folk are consigned to becoming peasants. The Samurai choose to break this tradition by training the local peasants to help them defend the village, albeit with limited success. The end of the movie displays the most poignant scene in the whole film. Four of the Samurai are slain but the village is sucessfully defended. Instead of showing gratitude, the villagers ignore the surviving Samurai and busy themselves with planting next year’s crop. Kanbei lament that â€Å"He has never won a battle† is given new meaning. Doubtless, the three surviving Samurai will move on to another of the endless battles of the era known as â€Å"The century of war† leaving the villagers in peace. Victory belongs not to the slain bandits nor the ostracized surviving Samurai but to the common peasants. They won because their life can now go back to normal to planting the life giving rice that sustains Japan to this day. True, they are maltreated by their lords, helplessly slaughtered in the battles, and at times forcibly conscripted as they were in the film. But the peasant’s life will continue, planting rice, water and tend the crop, then harvest just as he had for centuries, just as he will continue to do.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Another theme is the superiority of modern technology over the old. Many subplots in the movie are about disabling the firearms of the bandits. There are fourty bandits and only seven Samurai but the Samurai are better skilled only the firearms give the bandits the upper hand. In fact all four of the Samurai killed died due to gunfire and not in honorable single combat.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Finally there is the wisdom of Kikuchiyo. He was a phony Samurai lacking the high-birth of a proper member of the warrior class. Yet with the exception of Kanbei perhaps he had the most significant role in the movie. He is the one who sucessfully breaks the ice and convinces the Villagers to flee from their hiding places and meet the other Samurai. He was also the one who pointed out that the reason the fleeing Samurai are maltreated by the villagers is because they too absorbed cruel treatment from the warrior class. It was mainly through his wisdom and understanding, he is not actually a Samurai but a farmer’s son, that the Samurai and the villagers are able to work together in harmony. Truly, despite his unworthy roots and oafish behavior he is probably the most ‘Samurai’ of the seven. He dies a noble and worthy death avenging a fallen comrade and slaying the leader of the bandits.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   As stated earlier, Seven Samurai is a testimony to the skill of Akira Kurosawa in both writing and directing. The films shows the suffering of the peasants during the Sengoku Jidai. The Samurai win victories only to waltz on to another of the endless battles perhaps to win or perhaps to die. But after the warrirors leave the food producing peasant will stay in his field and contiue planting his life giving crop. Sources Kurosawa, Akira â€Å"Seven Samurai† (26 April 1954)   

A Day in the Life of a STEM Major

For a high school student who hasn’t experienced life on a college campus, it’s hard to know exactly what to expect. How busy will you be on a daily basis? How much time will there be for extracurricular clubs or socializing? And how many hours can you expect to spend in the library? It’s hard to foresee exactly what your daily life will look like, and that can be an intimidating uncertainty. There are many factors not yet determined that will affect your routine. What college you ultimately attend, what major you pursue, and which extracurriculars you choose to participate in will all play integral roles in your day-to-day routine.   If you’re considering a STEM major, you might have heard that there’s a lot of work ahead of you. Indeed, STEM courses are known as time-consuming and intensive. Will it be overwhelming? Will you still have time for the other commitments that are important in your life? A little bit of insight can go a long way, and here at we have a team of experts who have been in your shoes. Read through our breakdown of a STEM major’s daily life, and then check out our Mentor Program . You’ll have access to the insights of peer mentors who have been through a competitive STEM program and are ready to share with you all the ins and outs of life on the STEM path. STEM is an acronym for science, technology, engineering, and math, and it encompasses some of the quickest growing career industries. In 2010, there were estimated to be 7.6 million STEM workers in the United States, accounting for about 1 in 18 workers. STEM occupations were projected to grow by 17% from 2008 to 2018, compared to a projected 9.8% growth for non-STEM occupations. STEM workers also earn more than their non-STEM counterparts—26% more on average. Furthermore, STEM degree holders continue to earn more regardless of whether they work in STEM or non-STEM occupations. STEM careers also tend to require higher levels of education, with more than two-thirds of STEM workers holding a college degree, compared to less than one-third of non-STEM workers.       While it’s clear that a degree in STEM will serve you well, it’s also known that it won’t be easy. A 2014 study by the National Center for Education Statistics revealed that nearly half of all college students who pursue STEM degrees leave the field or drop out. While this attrition rate is roughly the same as other fields, it is being targeted for improvement by colleges, based on the steep rate of job growth demanded by the STEM industry. Basically, in order to meet the growing demand, colleges need to graduate more STEM majors. In response to this quickly increasing demand, more and more colleges and universities are identifying risk factors for leaving STEM fields and implementing support systems to help STEM majors stay on track. Students are more likely to drop out of a STEM program if they take lighter credit loads in STEM courses in the first year, take less challenging math courses in the first year, or perform more poorly in STEM classes than non-STEM classes. To support these students, many colleges and universities are providing increased office hours and tutoring sessions during entry-level STEM classes. With such a quickly growing industry, it’s important that students interested in pursuing STEM are supported as much as possible.       Like any degree, pursuing a STEM degree is a significant commitment. In fact, many sources point to it being a more rigorous and time-intensive commitment than other majors. There are many factors that will weigh into how busy you are as a STEM major. Here are the biggest ones: In order to be considered a full-time student at most colleges and universities, you will need to take at least 12 credit hours each semester. This means spending 12 hours in class on a weekly basis. While this is the minimum course load to be considered full-time, most students need to take 15 credit hours to be on track to graduate in four years. The course load is impacted by required coursework. Each major has specific course requirements and students who are considering graduate school or med school will have even more courses to consider in order to qualify for these postgraduate programs. Furthermore, many colleges and universities have specific graduation requirements that include broader coursework than that prescribed by a single major. These requirements are intended to expose students to a variety of content areas and produce more well-rounded graduates. If you’re considering a STEM major, it’s important to realize that it’s not uncommon to be required to take classes in other disciplines as well. Sometimes, students who are enrolled in STEM majors will select classes widely perceived as â€Å"easy† in order to fulfill non-STEM requirements. This makes sense due to the often more intensive time commitment required in STEM courses. There are usually many interesting choices to fill course requirements in the humanities or social sciences, and these classes don’t necessarily have to take time away from your STEM studies. Our Early Advising Program helps students in 9th and 10th grade discover their passions and build strong academic and extracurricular profiles to succeed in high school. STEM majors put in a lot of work outside of their regular class hours. If you’re considering a STEM major, you can plan on spending about 20 hours studying each week, according to a 2011 study by the National Survey of Student Engagement . Furthermore, these study hours do not include any time that you might spend attending your professor’s office hours or even discussing your coursework amongst friends, both of which are regular occurrences for STEM majors. Many college students hold jobs in addition to their coursework. These jobs are sometimes required through work-study programs or are financially necessary. In 2011, 71 percent of the nation’s 19.7 million college undergrads held jobs. Of that number, one in five students worked at least 35 hours per week. More commonly, though, students work 10-15 hours in the average week. Students in STEM fields might be able to find a paid research position through their school to fulfill their work requirements, but if this isn’t the case, sometimes STEM majors volunteer as research assistants or interns. In other cases, students might be able to receive course credit for their research. Extracurriculars are a valuable component of any college education and have been associated with a positive impact on the academic experience of students ranging in age from middle school to undergrads. On average, undergraduate engineering majors spend about the same amount of time on extracurriculars as students in other majors. This averages about eight hours per week and includes things like sports, clubs, and student government or volunteer associations. As you can see, there are a number of factors that influence how busy you will be as a STEM major. Although no two student experiences are exactly alike, using the studies and statistics available, it’s easy to get a picture of what the average STEM student can expect in college. Keeping all of this in mind, here is what you can expect on an average day as a STEM major: 8:00 AM: Wake Up! You have a full day ahead of you and you’ll need to grab a quick bite of breakfast before you get started. Take a quick shower and get moving. 8:30 AM: Head to the dining hall or a local cafe to grab some coffee and a bite to eat on your way to your first class. 9:00 AM: Your first class of the day begins. Maybe it’s organic chemistry or calculus II. Either way, don’t forget your notebook! 10:30 AM: You’re done with your first class of the day. Time to squeeze in some studying and maybe pick up another coffee. 12:00 PM: With a solid hour plus of studying under your belt, now is time to grab some lunch before your afternoon classes begin. 1:00 PM: Class again. Maybe this time it’s a lab or a school-required humanities class. 2:30 PM: You’re done with classes for the day! Before you rush out though, you might stop in for office hours to ask some questions or get a little guidance on your newest problem set. 3:00 PM: After you hit office hours, it’s time to rush to soccer practice. Don’t be late! 5:00 PM: Practice is done, have a quick shower and squeeze in some study time before dinner. 6:30 PM: You have a little time to get dinner before you go to work. 7:00 PM:   Work. Maybe you’re in the lab with a professor, or maybe you’re serving coffee at the campus cafe. Either way, it’s money in your pocket. 9:00 PM: Your shift is over, phew! Maybe you can squeeze in a little more study time. 10:00 PM: Have you finished your homework? If so, now you get some time to catch up with friends, relax, and get ready for the day ahead. 11:00 PM: Hit the sack! You’ve got to do it all again tomorrow. This day sounds busy, but if you break it down, it’s actually pretty well-rounded. You’ve spent three hours in class. You’ve studied or done homework for three or four hours, worked for two hours, and gone to soccer practice. You had some time to enjoy meals with friends, touch base with a professor during office hours, and even hang out and socialize a little before bed. Does it sound busy? Sure! Does it sound impossible? No way! Of course, no matter what major you pursue, there will be some days that do seem impossibly busy, while others will seem luxuriously slow. Life as a STEM major might be busier than the average college student’s life, but it isn’t crazily so. If you’re genuinely interested in STEM industries and you’re willing to invest some time and energy into getting yourself there, you may ultimately be rewarded with job security and a solid paycheck. If you’re interested in hearing more about life as a STEM major, don’t forget to contact ’s Mentoring Program , which provides practical advice on topics from high school activities and college applications to career aspirations, all from successful college students who have been in your shoes.

Geography Essay Example | Topics and Well Written Essays - 1000 words - 1

Geography - Essay Example In the video titled Oregon: A Fight for Water (which is part of Regions and Economies section of the series), all facts pertaining to the initial problem are presented. Eastern Oregon is separated from the lush and fertile Pacific coast by a mountain range. Often called simply as the Coast Range, this geographical feature is the key to many of the climatic, hydrographic and vegetation patterns of the region. The Coast Range acts as a barrier between the two sides and blocks water-bearing clouds from reaching the eastern side, which is why the Pacific coast side is lush in vegetation and abundant in water, whereas the rest of the state is semi-arid and heavily dependent on the water provided by the Umatilla River. Hence there is competition between different communities to get access to the scarce water resource that the Umatilla provides. It is as a way of finding solution to this scarcity that dams were built along its course. The water stored by the dam was diverted through irrigat ion canals to the various circular agricultural fields that dot the landscape of the riverbank. While agriculture (especially high-grade potato farming) has benefitted from this arrangement, the indigenous tribes who live further downstream are adversely affected. For Native American tribes, water holds a meaning far beyond its everyday utility. And hence, negotiating with them on practical terms is not fair on part of the State. Moreover, the Salmon that travels upstream to spawn in the upper reaches of the Umatilla is also severely affected by the raising of the dam. A similar conflict exists in the California-Nevada border, with each group making claims on the limited water resource provided by the Truckee River Basin. To supply water to the growing population in the Reno-Sparks area, dams have to be constructed. But this has disturbed the natural habitat of cui-ui fish, which is considered sacred by a

Mango's Business Model Essay Example | Topics and Well Written Essays - 3000 words

Mango's Business Model - Essay Example Mango has developed unique advantages in terms of product and related design processes, quality, production, logistics, and HR policies as well as in the implementation in the state of the art technology. Product Through the process of subcontracting their product designs and the related prototypes, the company itself maintains the entire process of designing the product to making the product available to the end consumers. The entire chain of production has been subcontracted to various markets across the globe like China, Morocco and even to the markets in Turkey. By the process of outsourcing their designs, the company has developed the unique advantage to promote four collections in the markets on an annual manner. Quality In an attempt to maintain the standard of quality for the products, which are manufactured by following an outsourcing model distributed throughout the globe, consistent quality checks are carried out at various points of the distribution channel, ranging from the factory premises to the store premises. This provides the advantage of supplying quality materials to the consumers. Design The brand Mango focuses on providing their clothing line to the end consumers under the most perfect in store conditions with the same level of convenience offered to consumers all over the world. Design is considered as a highly critical factor in case of the brand Mango, for luring in customers to the store. As a matter of fact, in order to maintain the same kind of store image, Mango maintains an entire team of window dressers, coordinators, and supervisors whose main job is to offer the similar kind of in store feeling to consumers all over the world by offering them with the same kind of in store design and related accessories. Culture Mango being an international company has a highly integrated product line, which is manufactured by outsourcing them to other companies. Though Mango follows the outsourcing model, yet the collections are made as prototy pes at the company and then outsourced for mass manufacturing, while following a centralized hierarchy. But in order to make their production lines for their collections appeal to the customers all over the world, the collections are designed keeping in sync with the cultural tastes that are prevalent in various parts of the world like the countries in the Middle East. This provides the advantage of being able to cater to the diversified cultural tastes for Mango’s clothing line for the young target audience, prevalent in various parts of the globe that prefer to be attired in a different clothing line altogether, yet at a consumer friendly price. Production Mango follows an outsourcing model, as described earlier for the production of its clothing line. In every season, an entire range of new suppliers are detected to match the technical requirements as well as the surge in production. In an effort to maintain long term relationships with the suppliers, a system of collabora tion is followed and maintained by the brand like indulging in constant dialogue and

Hackney Homes - A Strategic Report Essay Example | Topics and Well Written Essays - 3250 words

Hackney Homes - A Strategic Report - Essay Example Many recommendations are made for improvement of the organization in this report. Table of Contents Content Page Number Introduction 4 The Company 4 Competitor Analysis 5 External Environment Analysis 8 Overall Environment 12 Conclusion and Recommendations 14 References 16 Hackney Homes-A Strategic Report 1. Introduction Hackney Homes is one of the most famous organizations in UK which manages the council homes there. In this report, a strategic analysis of Hackney Homes is done using relevant academic models. Based on the definition by Waal (2007), the success of an organization needs to be evaluated based on its targets as well as the strengths and weaknesses .The targets are examined by mission and vision statements and the strengths and weaknesses are evaluated through internal and external analysis. The various positive (opportunities) and negative (threats) external factors influencing the performance of an organization are evaluated through external analysis. This analysis is very relevant for assessing a company’s present situation in order to develop new strategies or change existing strategies by making use of the opportunities and threats to the company. In this report, the services offered by Hackney Homes, its targets and strengths and weaknesses are examined through different academic models. The report has six sections. Section two discusses the targets and services offered by Hackney Homes. Section three discusses the competitive environment of the company. Section four analyses the external environment of the company .Section five examines the overall environment of the company. Section six concludes the report and makes recommendations. 2. The Company The main services offered by the company include management of council homes, rent collection as well as repair and maintenance of these homes (Hackney Homes, 2011a).Community service is the main aim of this organization. According to Collins and Porras (1996), the mission statement of a c ompany gives its important ideology and visionary components. The three major components of the mission statement are generally identified as the committed core values, core purpose and the visionary goals to be followed by the firm to fulfil its mission. The mission of the organization is to ensure the delivery of homes to people which are excellent, accessible and high quality homes (Hackney Homes, 2011b).It works as an agent which manages the Hackney Council. It was formed in 2006 as a subsidiary of Hackney Council and is formed as an Arms Length Management Organization called ALMO (Hackney Homes, 2011b). Based on the mission statement, the main objectives of the company include provision of services which are excellent and accessible, delivery of modern homes, sound management of homes and neighbourhood improvement. The main values of the organization include service, honesty, achievement, respect and pride (Hackney Homes, 2011b). In the next sections, the competitive position a nd the general and specific environment of the company are examined using relevant academic tools. 3. Competitive Analysis According to Coulter (2005), there are both specific environment, like customers, competitors, suppliers etc which influence directly the company’s strategic decision and general environment like political, economic, social and technological sectors that indirectly

Organizational Behavior - What Is A Learning Organization Assignment

Organizational Behavior - What Is A Learning Organization - Assignment Example As the paper stresses organizations try to involve them in single-loop learning. After having detected the mistakes, the rectification procedure depends upon past routines as well as present policies. However, the learning organization generally makes use of the double-loop learning. In this case, the errors that are detected are corrected by means of adjustment of the goals of the organization, its strategies and the standard schedules. From the report it is clear that there are five main features of a learning organization. The members of the organization have shared vision which is mutually agreed among them. People often do not follow their old ways of thinking and make use of the standard routines in order to resolve the problems or perform their task. It has been observed that the employees of the organization consider the organizational processes, interaction with the environment, activities as well as functions to be significant components of scheme of inter-relationships. It is often believed that people of the organization try to communicate openly with all the members of the organization without fear of criticism or punishment. People reduce their personal interests as well as portioned departmental interests to work together and attain the shared visions of the organization. Advocates of the learning organization envisage such organization as a remedy for three basic problems intrinsic in traditional orga nizations, such as fragmentations, competitions as well as reactions.

Stigma and discrimination add to the suffering and disability Essay

Stigma and discrimination add to the suffering and disability associated with mental disorders - Essay Example Patients of mental conditions, their friends, families and health care workers such as nurses concur that these patients are exposed to quite high levels of social stigma and discrimination due to their mental ill health (Margaret & Janine, 2011). These discriminations and stigma make it rather difficult for mentally ill people to recover and worsens their pains and suffering.Given the prevalence of mental health conditions in current society, the effects of stigma and discrimination on mental patients can be said to affect a rather large portion of the population That is, these problems extend to and affect mental health patients’ friends, families, colleagues, care providers and the larger society. In the UK, statistics show that about one in four people are likely to experience a mental health problem at some stage in their lives. Globally, there are 450 million people with mental health problems (Patel & Prince, 2012). On a rather positive note, most victims of mental illn esses recover fully to live and manage normal lives, especially when they get appropriate and timely help. The social stigma associated with mental illnesses has been closely associated with the discrimination that mentally ill people face in different aspects of their lives (Corrigan & Kleinlein, 2005). Notably, many of these patients’ pain, suffering and other problems are worsened by the stigma and the resultant discrimination they experience from the public and their families, friends, colleagues and employers (Kitchener & Jorm, 2002).This study seeks to explore the extent to which stigmatization and discrimination add to the suffering and disabilities of the mentally ill. Rationale/Background/Justification From literatures and studies conducted in the field of mental health with reference to stigma and discrimination, it is quite clear that the stigma and discrimination faced by the mentally ill really aggravate their suffering, exacerbate their disabilities and reduce t heir chances of partial or full recovery. In other words, stigma and discrimination not only worsen these patients’ health problems but also impede their receipt of assistance, treatment and recovery (Hilton, 2006). The other effects of mental-health stigma and discrimination are social isolation, poor housing, unemployment and poverty (Burke, 2010). Purpose of the Study 1. Establish the existence and the severity of the stigma and discrimination faced by the mentally ill in society 2. Explore the various causes of the stigma and discrimination faced by the mentally ill in society 3. Explore the extent to which the subject of the stigma and discrimination faced by the mentally ill in society has been researched 4. Propose techniques by which stakeholders such as nurses, families, friends, governments, institutions and NGOs may combine efforts to reduced this stigma and discrimination Research Question Do the stigma and discrimination faced by mental health patients add to the ir suffering and disabilities? Keywords Stigma, mental disorders, discrimination, disabilities, suffering, mental illness, Stereotypes Literature Review The methodology to be used in searching literatures in this research will encompass diverse categories of print and non-print resources that focus on the issues and subjects of mental health, mental illnesses, stigma and discrimination and their effects on mental health patients, their friends, families and caregivers. Other subjects to be focused on will be the extent to which stigma and discrimination affect the recovery of mental health patients and the future prospects for mental health stakeholders with regards to the stigmatization and discrimination that the mentally ill face (Weare, 2000). Inclusion and Exclusion Criteria The accessed and reviewed literatures will have to meet certain rigorous exclusion and

EVIDENCE BASED PRACTICE Assignment Example | Topics and Well Written Essays - 1500 words

EVIDENCE BASED PRACTICE - Assignment Example This paper discusses the strengths and the weakness of the evidence-based method. This paper also discusses the future and current state of clinical guidelines and the limitations of the guidelines as well. Evidence-based medicine is about solving clinical problems, it does this through a process of bringing together the best evidence of clinical experience and patient values. Clinical efficacy is a critical assessment of anything you do which is aimed at making a change in practice as a result of having a positive outcome. The main purpose is to improve patient and care experience. Clinical effectiveness measures outcomes on an individual patient level. Clinical effectiveness studies help healthcare professionals to understand how to design treatments based on patient variation rather than cost. Clinical effectiveness is about the right people, doing the right thing, the right way, in the right place, at the right time with the right result (Graham 1996). In the context of my practice as a  podiatrist, the right person would primarily be well-trained and a member of the Health and Care Professions Council (HCPC), with knowledge of the new advances in podiatry, such as local anaesthesia, nail surgery, diabetic feet and gait analysis. All the above specialities need extended training such as Continuing Professional Development. Clinical effectiveness doing the right thing is aimed at making clinical practice more accurately based on the use of investigations that have been proven to be effective relative to the specific patient needs (Graham 1996). To do things in the right way it is necessary to have a well-trained and competent work-force that has clear responsibilities and works together in this new era of podiatry to deliver the best value healthcare possible. The right result refers to the maximization of health effects,

An inspector calls & by J. B Priestly Essay Example for Free

An inspector calls by J. B Priestly Essay As the curtains rise the light (dim) focuses on Mr Birlings factory. Outside, protesters are trying to convince Mr Birling to increase their wages. Lightning strikes a tree near the protesters and everything goes dark. The light brightens a little and focuses back on the factory where all the protesters are gone. As the light brightens more, Mr Birling walks out of the factory and locks the main doors. The night is dark and eerie; the deep mist envelops his feet as he moves. He walks along a path past Milwards, the palace variety theatre and up to the house. Set up of the stage Top view After Mr Birling enters the house the rest of the stage goes dark and is cleared apart from the house. The front of the house lifts up to show the dining room. The lights dim and focus on the dining room where the four Birlings and Gerald are sitting. Mr Birling pushes the port towards Eric. They talk about port for a while until Edna leaves. When Mr Birling starts his first speech about the miners strike being almost over, Last month, just because the miners came out on strike, theres a lot of wild talk about possible labour trouble in the near future. Dont worry weve past the worst of It. The lights focus on the screen just next to the house as well, where miners are going on strike again. After he has finished the focus goes completely on the dining room again. Mr Birling starts his second speech, saying that theres not going to be a war. Just because the Kaiser makes a speech or two, or a few German officers have too much too drink and begin talking nonsense, youll hear that war is inevitable. The screen shows pictures of World War 1. Mr Birling starts his third speech, when he says about the titanic being unsinkable, The Titanic forty six thousand eight hundred tons and unsinkable, absolutely unsinkable. Theres a slight pause and the light focuses on the screen in the background, it shows the titanic sinking. The inspector comes on the stage and walks up to the house, he stops and looks for a while and then goes up to the house. Edna opens the door and lets the inspector in, she shows him into the dining room. I went to the Milton Keynes theatre on Wednesday 8th November to see An Inspector Calls. The play had some symbolism in: the house represented the familys security, the house was on stilts it was like each member of the family was a stilt and when one of them were damaged the whole house falls apart; the inspector is a representative of the audience, he asks the family questions that you want to know. The play was set in the Second World War, I think that it should have been set before the First World War as it was in the original play because the play has references to class difference and that was more pronounced at that time. The director didnt change important things in the script that told you it was before World War 1, This girl left us nearly two years ago. Let me see it must have been in the early autumn of nineteen-ten. They are only small parts of the play but make a big difference to the set out of the play. However it was good to have it set in the World War 2 because Mr Birling talks about the mining strikes in one of his speeches and there was a lot more of them before World War 2 than World War 1.

Tisco (tata iron and steel company limited)

Tisco (tata iron and steel company limited) 1. Introduction TISCO (Tata Iron and Steel Company Limited) is the worlds sixth largest steel company which was established by Indian businessman Jamshetji Nusserwanji Tata in 1907. It is also the largest private sector steel company in India in terms of domestic production. The company is the fifth largest steel producer in the world as it produces 18 million tons of steel in India and 52.32 million tons overseas. [1] The aim of the company was to maintain its reputation in the steel industry. For this they had to do some advancement in their technology because, the legacy system was outdated. Basically they wanted to transit from a production-driven company to customer-driven company which will make them more Customer friendly. [2] For the improvement in the system they had implemented ERP SAP 3 which later on resulted in a success of company. Generally its not so easy to be successful in the ERP implementation process, but as the company had taken right decision on right time, they were able to get the desired results from the implementation 2. ERP Implementation 2.1 Need of an ERP System TISCO was facing two main problems. Firstly, the systems which were they using were outdated and it was also having some errors. Secondly, the system was mostly designed for the process and which made them to pay less attention to the customer needs. [3] Finally, company decided to implement a new ERP system which is error-free as well as less complex and which will also help them to become more Customer friendly. 2.2 ERP System Selection The company wanted such an ERP system which would satisfy the factors such as time, profit, cost, compatibility, support, transparency and future requirements. While working on these factors company was also forecasting the condition which will become in the future after implementing any ERP system. So finally after a thorough study, the company ended up with the SAP 3 ERP which was fulfilling all the requirements of the company. [2] 2.3 ERP Implementation Process The ERP implementation process is a very time consuming because it has to go through some major factors like planning, designing and testing. Most important thing is that the system should meet the companys demands. Thus, to implement the SAP ERP system, a period of 8 months was allotted which was a big challenge for the company. [3] But the company was able to meet the deadline successfully. 3. Factors Contributing to Success 3.1 Planning The initial step for the company was to list out the goals that are is to be achieved. According to the goals they designed the process plan. TISCO wanted to create such an environment which will always make them to learn something new by which they can make changes to make the system more efficient. They had also planned about the changes that can affect the system in future. By this they can immediately implement the solutions for the changes without wasting the time. The company wanted the software to work in such a way that it would improve the products and services which will make the company to maintain its reputation in the steel industry. 3.2 Process Organization Its always good when the process is divided into some parts so that each process can be handled separately with less complexity. So the company had divided the whole process into two parts. The process which was more complex and had more transactions was defined as the ‘Hubs and the process with less complexity and transaction was defined as the ‘Spokes. [2] Hubs are the major part whereas the Spokes are the minor parts. Spokes were attached to the Hubs because finally the whole process was going to run together. These processes were designed into the SAP modules. Enough training had been given to the developers to work on these modules so that they can handle the problems which might occur while testing these modules. The company had given deadlines for each module because the final task was to run all these modules at the same time. And at this point if any kind of errors would occur then, there should be enough time to work on it. So, In order to run all these modules together the developers had to do the proper implementation of their knowledge. 3.3 Final Stage At this stage the company was ready with all the modules and was preparing to go live with the entire project. This stage was very crucial for them because this is the moment when they will get to know the results. As the company did not face any problems while working on the project, the desired results were expected. They had done the thorough analysis of the whole process and implemented the solutions for the changes where they were required. So the company was quite confident about the outcomes. 3.4 Result Finally TISCO got success in SAP ERP implementation project. This project helped the company in terms of financial, technical and managerial aspects. [3] This project made company to update its customers daily and providing a good quality of service across the country which led to the improvement of customer management. This project had led company to an improved productivity, enhanced customer service, speed delivery and reduced cost. The system was less complex and a user friendly which was the biggest advantage. This project helped the company to reduce the product cost and gain more profit in the industry. 3.5 Future Steps The success of this project was motivating for both the TISCO and the ERP vendors. Now TISCO is not only using this software but they are also going to work on it further to gain more benefits for the company as well as for the stakeholders. [3] This will help company to make more profits and satisfy the customer needs efficiently. In this way the company can keep its existing hold in the steel industry. 4. Conclusion Many big companies have failed to implement ERP systems. Due to this fact many companies doesnt prefer to implement ERP. But this fact did not affect TISCOs morale. They worked very hard on the project which made them more confident about the results. The speed at which they worked and the way they synchronized all the work was remarkable. This was one of the major contributing factors for the success. Finally the project gave the desired results and fulfilled all their expectations. 5. References 1. Wikipedia (2007) http://en.wikipedia.org/wiki/Tata_Steel 2. Bhavish Sood, (2001): Indian Express Group (Mumbai, India) http://www.networkmagazineindia.com/200210/case5.shtml 3. Crewind Technologies Pvt. Ltd. (2009) http://www.erpwire.com/erp-articles/saperp-success-in-tisco.htm

1984 compared to cults Essay -- essays research papers

  Ã‚  Ã‚  Ã‚  Ã‚  In the book 1984, written by George Orwell, there is a group portrayed that is similar to what society would call a cult. A cult is defined as a religion or religious sect generally considered to be extremist or false, with its followers often living in an unconventional manner under the guidance of an authoritarian, charismatic leader. Totalism is described as the principle of complete and unrestricted power in government. The books main themes include language as mind control and psychological and physical intimidation and manipulation. In the book, the people live in a city which is very out of the ordinary and also overseen by a charismatic leader, Big Brother. This society, portrayed by George Orwell has all the elements of a cult-like and totalist society.   Ã‚  Ã‚  Ã‚  Ã‚  Oceania, which is the Americas, the Atlantic islands including the British Isles, Australasia, and the southern portion of Africa, is where Winston Smith lives in the book 1984. Ingsoc, newspeak for English Socialism, is the political ideology of Oceania. â€Å"War is peace, freedom is slavery, ignorance is strength,† is the slogan of Oceania, which is displayed on the pyramid of the Ministry of Truth. The Ministry of Truth is where they change books to reflect the party’s ideology. â€Å"The language of the totalist environment is characterized by the thought-terminating clichà ©. The most far-reaching and complex of human problems are compressed into brief, highly reductive, definitive-sounding phrases, easily memorized and easily expressed. These become the start and finish of any ideological analysis† (Lifton). Big Brother used this method to break down the party’s complex theories and put them into one phrase. â€Å"War is peaceà ¢â‚¬  is the part that keeps all the people of Oceania united. Big Brother makes the people of Oceania think that they are in a state of constant war. By making the people think this, the people stay united against the other countries that â€Å"threaten† them. â€Å"Freedom is slavery† is used to scare people into remaining loyal to Big Brother. The party is saying that anyone who strays from Big Brother will surely fail. â€Å"Ignorance is strength† means that the inability of the people to realize how the party is keeping power is how the party stays in power. This type of language puts people on a leash and the more they repeat the party’s sl... .... These men called him Christ, which translates into â€Å"Chosen One†. Another example of religions starting out as a cult is Buddhism. Buddhism was founded by Siddhartha Gautama, also known as Buddha, who rejected the principles of Hinduism and found acceptance for his new ideas among a group of disciples. Big Brother never claimed to be the chosen one because he wasn’t taking power for religious purposes.   Ã‚  Ã‚  Ã‚  Ã‚  They called him Big Brother because the name sounds like he would be one to protect his people, but he is just brainwashing them. Big Brother uses the same methods of control that are used by every cult and totalist leader. He uses lies to convince the people that he is protecting them, but he is just putting them on a leash that gets smaller and smaller with each day. He prevents the flow of information within Oceania just like cults makes their own newspaper and books. Not one person has left Oceania and came back to tell about it because if anyone left, they wouldn’t even be able to realize that all they’ve known is false. Now I understand Orwell when he wrote, â€Å"Who controls the past controls the future. Who controls the present controls the past.†

Progressivism In the Classroom :: Education Teaching Teachers Essays

Progressivism In the Classroom A good education has always been drilled into my head ever since I was a little girl. Boy did I hate that, all I wanted to do was goof off and have fun with my friends. But as the years went on I started to realize how important it was to have a good education. Not that that made me like school anymore than I did; but I was realizing the different ways I was learning and how different people taught. I remember saying one day, when I was a freshman in high school, that if I was teaching this class I would have never taught it that way. Unfortunately, my teacher overheard me and I was forced to go to the front of the room and explain to the class the way it should be taught since I knew so much about teaching. Needless to say I did an awful job of it. That is when I started thinking about becoming a teacher. I know that does not make sense because I did such an awful job and was humiliated doing it. I did not like the way that man taught and I was determined to take his job. However, the reason I am here today is not that I want to take a teacher’s job; it is because I have the desire to make a difference in the lives of many students. I hope I will be a good teacher so that I will never have to hear a student say something bad about my teaching. I think that the nature of knowledge is relative. Not all children can learn in the same environment. I believe that if a child is put in an environment in which they cannot learn they should be placed in another environment so that they can. Some students learn at a slow pace and others learn at a fast pace. Then there are the students that learn better by lectures and others that learn better by activities. If you mix these children in the same class, than there are usually some lost kids in the class? I know that in my experiences with school, I would have never made it in a normal classroom since I learned so much slower than the other kids did.

hangover helpers :: essays research papers

Hangover Helpers   Ã‚  Ã‚  Ã‚  Ã‚  This article gives advice of remedies for a hangover. It explains what you can do before you drink; what to do while drinking; as well as suggestions for after you drink. Hangover symptoms may include headaches, nausea, diarrhea, tremors, and fatigue. Hangovers are generally more severe if you haven’t been getting enough water or sleep.   Ã‚  Ã‚  Ã‚  Ã‚  Before drinking, the advice that they listed was that you eat fatty foods, eat high- fiber foods, take vitamin C, and try hangover prevention formulas. Foods that are fatty or high in fiber help breakdown alcohol and absorb it, which keeps it from reaching the blood stream quickly. One of the hangover prevention formulas that were included suggested that you take an over - the- counter mixture of B vitamins and prickly pear extract. These help to fight stress and inflammation.   Ã‚  Ã‚  Ã‚  Ã‚  While drinking, there are a number of things that were suggested. The first tip was that you avoid congeners. Congeners are compounds that give liquor it’s flavor and color. To avoid these compounds, one should buy lighter- colored, highly filtered alcohol. They may tend to be more expensive, but they can reduce your causes of getting a hangover. Other precautions to be aware of while consuming alcohol is to stick to one kind of drink, avoid carbonation, alternate with water, and to order onion soup gratinee. The reason behind this is that onions are high in sugar, which speeds the body’s metabolism and burns alcohol. Also, the cheese is dairy, which slows alcohol’s entry into the bloodstream.   Ã‚  Ã‚  Ã‚  Ã‚  When you are finished drinking, you should drink lots of water because it cleans out your system. You should also drink fruit juices due to the fact that the fructose will restore a person’s blood sugar level. Other tips that were included was that one should: drink pedialyte, not drink bloody Mary's, eat bland carbohydrates, eat eggs, eat honey, try activated charcoal, try liver care, try milk thistle, try alka- seltzer morning relief, take anti inflammatory, and take Pepto- Bismol.

How Thomas Hobbes and John Locke influenced Enlightenment Thinkers Essay

The Age of Enlightenment saw many great changes in Western Europe. The Age of Enlightenment or simple â€Å"the Enlightenment† was an intellectual movement during the 18th century. Its purpose was to reform society and to advance knowledge using reason and the scientific knowledge. It supported scientific thought and opposed superstition with its favorite target being the Catholic Church. The phrase was frequently used by writers of the period itself, implying that they were emerging from centuries of darkness and ignorance into an enlightenment period fueled by reason and science. The ones who sparked the enlightenment can be traced to the 17th century. They include the two political philosophers Thomas Hobbes and John Locke. Thomas Hobbes was born on April 5, 1588 and he was best known for his work on political philosophy. His book Leviathan established the foundation for most of Western political philosophy. In Leviathan, Hobbes set out his doctrine of the foundations of states and legitimate governments. Much of the book demonstrates the necessity of a strong central authority to avoid chaos and disorder. Hobbes hypothesizes what life would be like with no government, a state which he calls the state of nature. In that state, each person would have a right to everything in the world. However, he argues that it would lead to a â€Å"war against all† because he believed that all people were evil and selfish. In order to avoid this state, people establish a civil society and conceive a social contract. According to Hobbes, society is a population under a supreme authority. Thomas Hobbes is a supporter of absolutism but he also developed some of the fundamentals of liberal thoughts such as the rights of an individual and equality for all. He was also one of the founders of modern political science as well. His understanding on humans as being matter and following the same concepts and laws as other matter remains extremely influential. John Locke was born on August 29, 1632 and he was one of the most influential English philosophers during the enlightenment period. Locke’s theory of mind is referred to as the origin of conceptions of â€Å"self† and â€Å"identities†. He theorized that the mind is a blank slate and that we were born with only instinctive ideas and that knowledge is only derived from experience. The founding fathers of the United States used many of his political ideas as the bases for the declaration of independence. Locke believed in a democratic rule and that everyone is entitled to their own rights and liberty. He thought that nobody should have absolute power so he came up with the idea of â€Å"separation of powers† meaning that the church and judicial system operate independent of the ruling class so theoretically no one can commit a crime and get away with it. Even though Thomas Hobbes and John Locke were both influential social contract theorists and great political philosophers, their ideas completely contradict each other. While Locke believed that humans were born with a clean slate and only gain knowledge through experience and experiment, Hobbes theorized that all humans were born with an evil and selfish nature which cannot be contained without a supreme authority to rule. In terms of political power, Locke believed in democratic rule while Hobbes believed in an absolute power to rule over the evil and selfish humans for if there is no absolute power, our savage instincts will take over and we will do whatever it takes to satisfy our greedy nature. As for rights, Locke believed all men are equal rights but Hobbes concluded that we should give up our rights to the government in exchange for protection. The Enlightenment was a great step in humanity to make strides in science and let reason explain our lives. Enlightenment ideas and works have been especially influential in politics. Many of the world’s democracies are built on the ideas of Locke and other political philosophers in the enlightenment period. Democratic nations, such as the United States are founded upon enlightenment ideas such as individual rights and liberty, the rights of citizens, and people’s rights to participate in the government. However, different political philosophers have different ideas about what’s best for their government. For instance, Thomas Hobbes believed in absolute monarchs, an idea which is still used today in places like Canada, Japan, Spain, and the United Kingdoms. The Enlightenment completely revolutionized the way people have thought about religion, politics, and science. It was one of the greatest events in history because it gave people the idea to challenge what they’ve always been taught to be right. It gave people a mind of their own and not fall to one supreme ruler. The legacy of the enlightenment shall never be forgotten.