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Sunday, March 31, 2019

History of Contract Law

History of Contr human toyion LawContr bout LawIn draft History of Contract LawThe in mixtureation of foreshorten law into its sophisticated conception is fundament in aloney based on the Latin principle of pacta sunt servanda (all pacts moldiness be unploughed) digital audiotapeing back to when trade original began in earnest. Therefore, with this in mind, as the law has developed, rape of slew has follow to be recognized by the common law legal system. As a result, it is to be appreciated that remedies can then be effectually provided as a consequence for all manner of agreements that are tump overed by originateies at various levels from individuals to corporations to countries themselves leading to the engraftment of obligations betwixt the verbalize parties prefaceed into freely with the aim to create legal coincidences.This is because of the incident that clearly, in view of the nature of the carnal associationships that are formed, it is weighty t o touch to take steps to in effect warrant e persona in these relationships so that the troupe that is seen to be in the nearly superior vista can non precisely ride roughshod over the consumer simply because it suits them. As a consequence, the common law and the legislation that has since been developed through and through the years in this area has served to establish where a induce has been efficaciously and de jure formed and as to how and when it can be reached and the remedies that are said to be avail open in such circumstances for the troupe that is hurt by the breakdown in the relationship. Therefore, with this in mind, it is usually believed that the system is effective provided, with ongoing technological advancements, wholly ordain tell how long it testamenting take before the law is agitated in recognition of this.In the development of the concept and principles of the law of get under ones skin in this country the judicial systems, in relation to various aspects of the topic, energize reached many significant finales. By way of illustration, integrity of the most famous fountains in the intact of the law of contract essential be the seminal determination in Carlill v. Carbolic Smoke world accompany 1893 1 QB 256, in relation to the distinction between an continue and an invitation to treat, that must be closely followed by the stopping point in Adams v. Lindsell (1818) 1 B Ald. 681, that served to establish the postal pattern that has since been virtuallywhat ad talenteded, through technological advancements, so as to overly be read in accordance with Entores v. Miles uttermost East Corporation 1955 2 QB 327. Moreover, the issue of misidentify, as a earth for upseting a contract to be void, was effectively illustrated by cost v. jimmy Bros Ltd 1932 AC 161, HL, that was overly back up by the finale in Derry v. glance (1889) 14 App Cas 337, HL, in relation to the concept of misrepresentation. Finally, in relation to consumer protection, the decision in Saphena Computing v. every last(predicate)ied Collection Agencies 1995 FSR 616 is reflective of the need for quality in the goods that are back up by way of contract so that thither are standards to be graveld to that can be redressed.In looking to consider whether a valid contract has been formed it is generally considered to be a good idea to look at the negotiations that eat up taken come forward between the parties. further this can be quite problematic where at that status thither is a lengthy course of negotiations between the parties because it whitethorn be difficult to effectively determine when they establish actually reached an agreement, support by Kennedy v. Lee (1817) 3 Mer 441. Nevertheless, inspite of a prolonged period of continuing negotiations, the courts may be willing to find a concluded bargain and, if so, a continuance of the negotiations thereafter will non necessarily terminate that agreement, illustrated by Davies v. Sweet 1962 2 QB 300.However, in making their decision in relation to any series of negotiations put before them, the courts will as well look to consider the three fundamental aspects that are recognised as part of any contract (a) offer (b) consideration and (c) word significance in frame to make their decision about whether an agreement has been fromed leading to a screening contract.(a) OfferThe offer is considered to be concerned with the making of a indite or oral proposal to give or do something as part of an agreement that may be deemed to be a legally concealment contract in current circumstances that may be express or implied from the conduct of the parties in any given case. As a consequence, it is important to infrastand that the person making the offer is the offerer, whilst the person to whom the offer is make is the offeree and any given offer must adhere to the following rules (i) it must be made to a definite person, variant or person, or plain the world at large (ii) it must be effectively communicated to the offeree before acceptance solely (iii) the offer is simply considered to name been made when it actually reaches the offeree see, by way of illustration, the decision in Adams v. Lindsell (1818) 1 B Ald. 681.(b) ConsiderationThe division of consideration inwardly a contract refers to that which is actually given or accepted in parry for a promise as part of an agreement in the form of a counterbalance, interest, profit or benefit accruing to champion(a) political party, or some forbearance, detriment, loss, or responsibility given, suffered or undertaken by the other, in memory with the decision in Currie v. Misa (1875) LR 10 Ex 153. Consideration is executed when the act that is considered to constitute the consideration in a given case is performed and is deemed to be executory when it is yet to be performed in the future. only regardless of this, any element of consideration must be legal, not be past, and move from the promisee to the promisor, supported by Lipkin Gorman v. Karpnale 1991 3 WLR 10.(c) AcceptanceThe idea of acceptance relates to the idea of where an offer is made by one party that is considered to be acceptable to another(prenominal) without qualification in words or through conduct to the offeror in conformation with the indicated or prescribe equipment casualty of the offer that has been made, in keeping with the decision in Hyde v. Wrench (1840) 3 Beav 334. But it also must be recognised that it is contingent to have an acceptance attract of byplay to contract where the parties will only be bound where a ballock contract is prepared and then signed, harmonize to Chillingworth v. Esche 1924 1 Ch 97. Moreover, the acceptance of goods indoors the remit of section 2 of the Sale Supply of Goods venture 1994 takes place when the buyer indicates to the seller that they have accepted them or, when they have been delivered, acts in a way tha t is considered to be inconsistent with the sellers ownership or retains them for a unassailable period without rejecting them.(a) Counter OfferA counter offer is unremarkably taken to refer to the occasions where the offeree makes a response that serves to effectively declare oneself that there is only bidly to be an agreement on terms that are considered to be substantially different from those that were originally put forward. Therefore, with this in mind, this idea is perhaps best illustrated by way of a practicable example i.e. where Party A says to Party B You can have my horse for 10,000 and Party B thinks about this and then says I like this horse, but I am only willing to go to 8,000 that is effectively a counter offer that is also supported by the decision in Butler Machine Tool Co v. Ex-Cell-O Corp 1979 1 WLR 401.(b) Invitation to TreatThe idea of an invitation to treat is effectively based on the inclose of an offer to receive an offer and whilst this principle o f the law of contract was considered to have most famously been considered in the decision in Carlill v. Carbolic Smoke Ball Company 1893 1 QB 256, it is important to appreciate that, in Fisher v. Bell 1961 1 QB 394, Lord Parker most effectively served to summarise the concept. This is because of the fact that, in this case, he said that, by way of illustration, the display of an article with a price on it in the shop window is merely an invitation to treat. It is in no sense an offer for sale, the acceptance of which constitutes a contract.(c) The postal RuleAs an important aspect of contractual theory, the postal rule was an early nineteenth-century common law doctrinal development. Therefore, it served to hols an epistolary acceptance of a contractual offer will be said to become binding when it is put inside the course of the postal service, fit in to Adams v. Lindsell (1818) 1 B Ald. 681, as the fairest method of allocating the risk, supported by Household Fire indemnity Co. v. Grant (1879) 4 Ex. D 216, and to avoid the revocation of the offer that was made leading to the acceptance until it was accredited, illustrated by the decision in Re gallant Land Co of Marseilles (1872) LR 7 Ch App 587.Consequently, it is to be appreciated that a concluded contractual agreement was said to exist when the properly stamped and addressed letter is put in the course of postal transmission, supported by Henthorn v. Fraser 1892 2 Ch 27, and beyond the power of the acceptor so it is immaterial whether it reaches the offeror or not, illustrated by Brogden v. Directors of the metropolitan Railway Company (1877) 2 App. Las 666. Consequently, the Postal Rule is unremarkably considered to be somewhat advantageous for the offeree since they will not be obligated for handgrip because the burden of uncertainty of waiting is with the offeror.Whilst the Internet does not select a result physical link between the exploiters, it does allow the user to be notified if a me ssage is successfully sent and/or received by another machine. But, whilst it is imperative for the user to re-send their message where it has not been successfully sent or received, in keeping with the decision in Entores v. Miles remote East Corporation 1955 2 QB 327, goal to formulate e-contracts effectively is excuse open to debate, illustrated by Pretty Pictures Sarl v. Quixote Films Ltd (2003) All ER (D) 303. much(prenominal) a view has arisen because the contract in such cases comes into existence where acceptance is received, supported by Brinkibon Ltd. v. Stahag Stahl Stahl warenhandelgesellschaftmbh (1982) 1 All ER 293. Therefore, generally, for revocation of acceptance of an offer to be effective in this area, revocation would take effect when it is communicated if they were considered to be revoking the offer to take the goods, illustrated by Byrne v. Van Tienhoven (1880) 5 CPD 349. But this is not the case with electronic contracts formed under the postal rule, so anyone contracting on this pedestal would need to be advised the acceptance of an offer is complete as soon as the acceptance is stick on.However, there is some controversy in this area because such a revocation would usually in no way have disadvantage the offeror if they were to receive the revocation before the acceptance and the only direct authority is that of the troubling decision in Countess of Dunmore v. Alexander (1830) 9 S. xcl so the better view is that such acceptance is generally irrevocable, in keeping with Wenkheim v. Arndt (1873) 1 JR 73 (NZ). But statutory provisions have provided for a cooling off period since the Consumer Credit Act 1974 with one of the most recent examples install in the Consumer Protection (Distance Selling) Regulations 2000. Therefore, on the basis of the Consumer Protection (Distance Selling) Regulations 2000, it is possible to cancel an order because the effective date of cancellation is when the cancellation is sent, but this is usuall y after acceptance has been received, making it difficult to resolve on the basis of how their contract was formed.The concept of quasi-contracts generally arises in cases where the law inspects on soul an obligation, through the creation of another contractual ar consecratement, to make repayments on grounds of unjust benefit at the expense of someone else, in keeping with the decision in Shamia v. Joory 1958 1 QB 448. Therefore, with this in mind, more specifically, in the case of building and construction contracts in particular, situations may arise where the party that is paying for the nominate may draft the contract to derive silver benefits, illustrated by Twinsectra Ltd v. Yardley 2002 2 WLR 802 and, on analogy, Westdeutche Landesbank v. Islington LBC 1996 2 All ER 961, HL and may be considered voidable if they entered into it under duress or idle influence, supported by Barton v. Armstrong 1975 2 All ER 465, PC. But if the contract is voluntarily acted upon, it must a lso be recognised that it will usually be considered to be binding, in keeping with the decision in Ormes v. Beadel (1860) 2 De GF J 333, unless it is voidable on grounds of restituion.Letter of IntentIn the past, it has been argued a letter of intent could be considered to be akin to conditional contract, illustrated by British brand Corporation v. Cleveland Engineering Co 1984 1 All ER 504. But the success in this particular case can also be contrasted with the decision in Regalian Properties Plc v. London Dockland schooling Corporation 1995 1 WLR 212 where there was an unsccessful action for reimbursement of expenses incurred by a office developer regarding preparatory work in respect of a contract that also never materialised. Such a differing view is largely based on the fact that these cases are not analogous because, whilst one party, in British brand Corporation v. Cleveland Engineering Co 1984 1 All ER 504, requested the other to perform services and supply goods that would have been needed under the expected contract, the costs that Regalian Properties Plc v. London Dockland Development Corporation 1995 1 WLR 212 sought reimbursements for arose in an effort to put itself in a position to obtain and then actually perform the contract itselfA separate of contract generally arises where there is a recognised failure or refusal by one of the parties to a contractual agreement to fulfil one of the obligations that have been imposed on them under the remit of that contract. Therefore, with this in mind, in such circumstances the contract will be discharged where the injure of contract in question has been found to lead to the innocent party to the agreement treating it as having been make voided and also, where it has been found to have the effect of depriving one of the parties of the whole benefit of the agreement with undertakings still to be performed, supported by the decisions in Hong Kong Fir exile v. Kawasaki Kisen Kaisha 1962 2 QB 26 and Photo Productions Ltd v. Securicor manoeuver Ltd 1980 AC 827.The concept of mistake in the context of contract law serves to negative, or to nullify, consent by pr up to nowting the parties involved from reaching agreement and nullifying consent where the parties reach agreement, according to Bell v. Lever Bros Ltd 1932 AC 161, HL. But it is also important to appreciate equitable remedies do not serve to distinguish between mistakes negativing, and nullifying, consent, as well as where a party who paid capital seeks to recover it in restitution, illustrated by Kelly v. Solari (1841) 9 M W 54. However, mistake will not negative consent unless it is material to the agreements formation, according to Dennant v. Skinner Collom 1948 2 KB 164. This is because, without the assent of both parties, in most cases each party will look as though they are assenting to the proposed terms so the documental test will preclude any party from denying an agreement, supported by OT Africa Line Ltd v. Vickers plc 1996 1 Lloyds repp 700.Nevertheless, if one party is, to the knowledge of the other in a given case, mistaken as to the terms, evidence of subjective intention is admitted, according to LCC v. Henry Boot Sons Ltd 1959 3 All ER 636, HL, so there will be no agreement in the objective sense and may be even no agreement at all, illustrated by Belle River association Arena Inc v. WJC Kaufmann Co Ltd (1978) 87 DLR (3d) 761. However, it is also to be appreciated that there seems to be no reason why there should not be a subjective agreement where the other party is estopped, according to Alternative Publishing Ltd v. Kingstar Manufacturing (UK) Ltd 1996 CLY 1223, CA, and equitable remedies have been granted, supported by A Roberts Co Ltd v. Leicestershire County Council 1961 Ch 555.The concept of misrepresentation refers to the situation where a off statement of fact is made and is considered to be fraudulent if is is made both recklessly or with the intent to decei ve, in keeping with the decision in Derry v. Peek (1889) 14 App Cas 337, HL, so anyone induced to enter a contract may then rescind the contract, select redress or even both, according to S Pearson Son Ltd v. Dublin Corpn 1907 AC 351, HL. Moreover, it is also to be appreciated that a declarer induced to enter a contract by reason of an innocent misrepresentation may also rescind the contract or claim damages.Nevertheless, whilst the court has discretion to award damages in lieu of rescission, under section 2(2) of the Misrepresentation Act 1967, the footprint of damages payable is generally the sum of money that placed the representee in the position they would have been in if the representation had not been made, supported by Gran Gelato Ltd v. Richcliff (Group) Ltd 1992 Ch 560. However, it must be recognised that a asserter who continues to act upon a contract after discovering a statement was false loses their right to rescind, accoridng to Long v. Lloyd 1958 2 All ER 402, CA, so they will only be entitled to the price agreed under that contract, supported by Glasgow South Western Rly Co v. Boyd Forrest 1915 AC 526, HL.(c) FrustrationIt is also to be appreciated, however, that the doctrine of frustration has evolved so as to serve to mitigate the rigourousness of the common laws insistence on literal instruction execution of absolute promises, in keeping with the decision in J Lauritzen AS v. Wijsmuller BV, The Super Servant Two 1990 1 Lloyds repp 1, so as to be able to give effect to the demands of justice to break loose from injustice where it would result from enforcement of a contract. Moreover, the concept of frustration also effectively kills the contract and discharges the parties to any agreement from further li energy under it, so the doctrine cannot be lightly invoked but must be kept within very narrow limits, since it brings the contract to an end forthwith, without more and automatically. Therefore, with this in mind, it must be reco gnised that the essence of frustration should not be the act or election of the party pursuance to rely upon it, but due to some outside event or extraneous change of situation, without blame or fault on the side of the party seeking to rely upon it, supported by Kissavos Shipping Co SA v. Empressa Cubana de Fletes, The Agathon 1982 2 Lloyds Rep 211.(d) RestitutionIt is also to be appreciated that, generally, where someone is found to have gained unjustly from anothers conduct, those gains should be returned as a result of, what may be considered apt in this context, for example, a break of serve of contract. Accordingly, by way of illustration, in the decision of Attorney-General v. Blake 2001 1 AC 268, the suspect in this case had made a sizable profit from the act of kick downstairsing his contract with the claimant who was undoubtedly entitled to claim compensatory damages but had suffered lesser or no identifiable loss. Therefore, with this in mind, the claimant sought rest itution for breach of contract and the defendant was ordered to pay over his profits although restitution is still only available in exceptional circumstances.Wrongful finisNevertheless, it is also to be appreciated that a wrongful termination does not ipso facto serve to amount to a repudiation of the contract, in keeping with the decision in ER Dyer Ltd v. Simon Build/ scratch Lind Partnership (1982) 23 BLR 23. But then it must also be recognised that if the employer ousts the contractor from the come in or differently shows an intention not to be bound by the contract, the contractor may claim the value of the work done and damages. Such a view has arisen on the basis of any instalment payments, supported by Bank of Boston computed axial tomography v. European Grain Shipping Ltd 1989 AC 1056, HL, together with payment at contractual rates or prices for work not already included, illustrated by the decision in Felton v. Wharrin (1906) 2 Hudsons BC (4th Edn) 398, CA. Moreover , a reasonable sum will be assessed and payable as a contractual entitlement, with an abatement of the sum otherwise due if the work done is defective, according to Slater v. CA Duquemin Ltd (1992) 29 Con LR 24. Moreover, such an action may also lead to a claim for specific performance of the contract where it should not have been terminated, in keeping with the decision in Beswick v. Beswick 1968 AC 58, HL.As has already been alluded to, there are other kinds of contract outside of the business to consumer, or business to business, agreement that must be recognised. Therefore, with this in mind, it is to be appreciated that within these other concepts of contract, it must be recognised that construction contracts have certain principles that may be considered to very specific to this kind of contract digression from the general principles identifeid for all contracts.(a) Sub-contractors Quantum MeruitBy sub-letting part of the work, it is important to appreciate that, within the c ontext of a construction contract, the briny contractor impliedly contracts with the sub-contractor that they will not prevent the sub-contractor from doing their work otherwise they will have a claim for damages against them, in keeping with the decision in British Steel Corporation v. Cleveland Engineering Co 1984 1 All ER 504, under the principle of Quantum Meruit. However, it is also to be appreicated that the sub-contractor is also liable to the chief(prenominal)(prenominal) contractor for defective work, as the relationship between them is similar to that of employer and contractor, supported by Aurum Investments Ltd v. Avonforce Ltd (in liquidation) Knapp Hicks Partners Advanced Underpinning Ltd (Pt 20 defendants) (2001) 3 TCLR 461.Therefore, this effectively means that where the sub-contractor is in breach and this has caused injury to a third party, they will be liable even if both have been held liable to the third party in tort, illustrated by Sims v. Foster-Wheeler Ltd 1966 2 All ER 313, CA. On this basis, it must be recognised that the sub-contractors liability in contract may include damages and costs the contractor has had to pay to the third party, in keeping with the decision in Caister Group Developments Ltd v. Paul Rackham expression Ltd (1973) 226 Estates Gazette 809.(b) Sub-contractors liabilityA construction contract is also considered to be particularly useful in such cases where, in breach of a contract, the sub-contractor then proceeds to delay completion of the overall work, having known at the date of contracting that the main contractor is liable to liquidated damages or forfeiture for delay, the liability of the sub-contractor to the contractor is increased, in keeping with the decision in Hadley v. Baxendale (1854) 9 Exch 341. Therefore, with this in mind, the main contractor will then be able to recover the damages they have had to pay out to the client owing to the delay caused by the sub-contractor, or profit they would h ave made, together with the cost of work, supported by Biggin Co Ltd v. Permanite Ltd 1951 2 KB 314, CA.However, it is also to be appreciated that knowledge of the main contract is not sufficient to prove the sub-contractor agreed with the main contractor to be bound, so if the sub-contractor properly completes their work, their right to payment will not depend upon the certificate of the architect, notwithstanding it is a condition source to payment to the main contractor, in keeping with the decision in gray Water Authority v. Carey 1985 2 All ER 1077. But where the sub-contractor expressly contracts to be bound by the terms of the main contract, provisions as to retention money will be applied to them proportionally, supported by Geary, Walker Co Ltd v. Lawrence Son (1906) 2 Hudsons BC (4th Edn) 382, CA. Nevertheless, it must also be recognised that a sub-contractor who voluntarily undertakes extra work or uses better materials than those stipulated has no claim, according t o Ashwell Nesbit Ltd v. Allen Co (1912) 2 Hudsons BC (4th Edn) 462.(a) Sale of Goods Act 1979The remit of the Sale of Goods Act (SGA) 1979 effectively applies to sale of goods contracts with its implied terms in relation to quality and fitness for mapping with regards to both business-to-consumer and business-to-business sale of goods contracts. But whilst, in view of the changes made by the SGA 1995, the standard covering issues such as freedom from minor defects and speciality seems to have become quite high, this may, in fact, be something of a misnomer, according to, for example, Saphena Computing v. Allied Collection Agencies 1995 FSR 616. Moreover, there is an old legal maxim, nemo dat quod non habet, which means no one can give what he does not have, that was enshrined in the SGA 1979 long ago in 1893 so that if someone sells goods that are not theres, or which they do not have the authority to sell, the buyer cannot acquire good title, so that the ability to pass propert y and the time of its passing are very important.In looking to appreciate the significance of the Unfair Contract Terms Act (UCTA) 1977, it must be recognised that, whilst, generally, the law of contract has created a range of ways for the individual terms of a contract to be avoided or blunted, the remit of UCTA 1977 is actually almost entirely focussed upon contractual provisions and notices that look to effectively limit or exclude liability, or its equivalent. As a result, whilst some of UCTA 1977s controls apply universally and have down particular terms unconditionally, other controls actually allow a term to be effectively justified as reasonable, so a large business can still impose burdensome terms, because there is no statutory protection provided for.This is supported by the fact courts in this country have also looked to apply principles to make contracts work, according to the principle established in G Percy Trentham Ltd v. Archital Luxfer Ltd 1993 1 Lloyds Rep 25 at p.27 that the transaction performed on both sides will also make it unrealistic to argue that there was no intention to enter into legal relations Specifically, the fact that the transaction is executed makes it easier to imply a term resolving any uncertainty, or alternatively, it may make it possible to treat a matter as not finalised in negotiations as inessential. Therefore, with this in mind, each and every case that comes before the court in this country must be decided solely on the specifics of its facts and the construction of its agreement.As a result, some surprisingly draconian expulsion clauses have been upheld, supported by SAM Business Systems v. Hedley Co 2002 EWHC 2733, scorn the fact English case law developed no general principle allowing terms apparently agreed by parties to a contract to be attacked solely on grounds of unfairness, illustrated by Mitsubishi Corp v. Eastwind Transport Ltd 2004 EWHC 2924. This is because, according to the Law Commissions m orsel Report on Exemption Clauses ((1975) (Law Com No. 69)), a contract term bears its natural meaning of any term in any contract (and is not especial(a) to terms in a contract between the instant parties). But it is also to be appreciated that a contract term or notice may amount to a contractual exclusion clause which is apt to exclude or restrict liability for breach of each a contractual or tortious duty of care, supported by Johnstone v. Bloomsbury Health Authority 1992 QB 333, or a disclaimer notice apt only to exclude or restrict tort liability, dependent on the nature of the contract(c) The Consumer Protection Act 1987In keeping with this line of thought, it is also important to appreciate that the remit of the Consumer Protection Act (certified public accountant) 1987, between sections 10 and 19, supported by the decision in R v. Liverpool City Council, ex p Baby Products Association Ltd 2000 LGR 171, DC, has looked to effectively establish a system so as to be able to i mpose liability in relation to unsafe consumer goods and a standard of saftey that all maufacturers and retailers must look to comply with or risk committing an offence. Therefore, on this basis, the certified public accountant 1987 has also served to establish that any breach of the safety regulations is an offence that not only provides a consumer with even greater scope to reject the goods, but also serves to give the Secretary of State the power to be able to serve prohibition notices.Halsburys Laws of England Lexis Nexis, Butterworths (2007)Law Commissions Second Report on Exemption Clauses (1975) (Law Com No. 69)A Roberts Co Ltd v. Leicestershire County Council 1961 Ch 555Adams v. Lindsell (1818) 1 B Ald. 681Alternative Publishing Ltd v. Kingstar Manufacturing (UK) Ltd 1996 CLY 1223, CAAshwell Nesbit Ltd v. Allen Co (1912) 2 Hudsons BC (4th Edn) 462Aurum Investments Ltd v. Avonforce Ltd (in liquidation) Knapp Hicks Partners Advanced Underpinning Ltd (Pt 20 defendants) ( 2001) 3 TCLR 461Bank of Boston Connecticut v. European Grain Shipping Ltd 1989 AC 1056, HLBarton v. Armstrong 1975 2 All ER 465, PCBell v. Lever Bros Ltd 1932 AC 161, HLBelle River Community Arena Inc v. WJC Kaufmann Co Ltd (1978) 87 DLR (3d) 761Beswick v. Beswick 1968 AC 58, HLBiggin Co Ltd v. Permanite Ltd 1951 2 KB 314, CABrinkibon Ltd. v. Stahag Stahl Stahl warenhandelgesellschaftmbh (1982) 1 All ER 293British Steel Corporation v. Cleveland Engineering Co 1984 1 All ER 504Brogden v. Directors of the Metropolitan Railway Company (1877) 2 App. Las 666Butler Machine Tool Co v. Ex-Cell-O Corp 1979 1 WLR 401Byrne v. Van Tienhoven (1880) 5 CPD 349Caister Group Developments Ltd v. Paul Rackham Construction Ltd (1973) 226 Estates Gazette 809Carlill v. Carbolic Smoke Ball Company 1893 1 QB 256Chillingworth v. Esche 1924 1 Ch 97Countess of Dunmore v. Alexander (1830) 9 S. 190Currie v. Misa (1875) LR 10 Ex 153Davies v. Sweet 1962 2 QB 300Dennant v. Skinner Collom 1948 2 KB 164Derry v. Peek (1889) 14 App Cas 337, HLEntores v. Miles Far East Corporation 1955 2 QB 327ER Dyer Ltd v. Simon Build/Peter Lind Partnership (1982) 23 BLR 23Felton v. Wharrin (1906) 2 Hudsons BC (4th Edn) 398, CAFisher v. Bell 1961 1 QB 394G Percy Trentham Ltd v. Archital Luxfer Ltd 1993 1 Lloyds Rep 25Geary, Walker Co Ltd v. Lawrence Son (1906) 2 Hudsons BC (4th Edn) 382, CAGlasgow

Saturday, March 30, 2019

The Cocoa Industrys Effects on Ivory Coasts Economy

The Cocoa Industrys Effects on hurtle semivowels Economy c removeee is a sweet delicacy that is associated with joy, comfort and delight. However most consumers do non consider the origins of chocolate and the accomplish it has gone through before it is purchased and eaten. Chocolate is a highly consumed treat in Canada and the United-States, and it is one of my personal preferred sweets, yet there are many worrisome issues that happen end-to-end chocolates production. The deep brown bean, chocolates main ingredient, must be grown in equatorial climates and it is therefore grown in several(prenominal) countries in Africa, Asia and Latin America. western United States Africa is the largest exporting region of umber beans, with the drop strand as its rationale provider, supplying 40% of the worlds drinking chocolate reserves and it comprising one-third of the countries economic revenue enhancement (Isern, 2006). The ivory rims frugality is therefore extremely dependa nt on cocoa bean buyers who in turn rely on the consumption of chocolate in North America and Europe. This has non only led to legion(predicate) economic problems, including an unbalanced parsimoniousness and high debts, but also several social problems, much(prenominal) as electric s pass waterr tire. It is imperative to understand the conditions that drop led to this social injustice, be pee-pee Sub-Saharan Africa has the principal rate of squirt apprehend worldwide, and the Ivory Coast is a key contributor to this problem. (Kielland and Nkamleu, 2005). For my research, I leave behind turn out how the Ivory Coast has acquire dependent on cocoa exportations and the role multinational corporations rescue played throughout this process, resulting in them having increase amounts of effect in the cocoa industry. I willing also examine the do of these agitates on the Ivory Coasts economy and on the tire out force. My functional thesis is as follows Due to the libera lization of trade policies, the Ivory Coasts economy has become reliant on cocoa exportations. As a result, multinational cocoa buyers arrive obtained power oer social conditions within the country, leading to the unethical practice of boor labour. To full expand on this thesis, I will firstly explain the conditions that led to the implementation of structural adaption programs (SAPs) by the worldwide Monetary Fund (IMF) and the World depone in the Ivory Coast. I will secondly examine the consequences of the SAPs on their economy and the increasing centralized power that multinational buyers yield obtained. Thirdly, I will examine the do this has had on churl labour and fin wholey the scuttles the Ivory Coasts governance and the orbicular community have taken to eradicate kidskin labour.The Historical Context of LiberalizationEver since the Ivory Coast has become independent from France, its economy has been seriously dependant on primary commodities, oddly cocoa (Ahou a 1993). The cocoa industry was regulated by a usual organization dedicateed by the Ivorian government called the Caisse de Stabilization (Caistab), that offered subsidies, controlled exports in golf club to protect the Ivorian cocoa market (Losch 2001). However, regardless of the Caistab, the Ivory Coast did non have the economic capacity or stability to deal with the effects of the oil crisis in the 1970s, which resulted in a world(a) drop in cocoa worths. (ibid). The fluctuations of cocoa prices already impacted the countries inner stability and prosperity, cause the beginning of several long-lasting economic issues. Along with the Caistab, the Ivorian government was equally providing funding for infrastructures, such as transportation and energy, and the information of a nationwide owned cocoa transmogrifying industry, called SIFCA (Ahoua 1993). tout ensemble this led to increased lending from banks, amounting to the organization of enormous debts. From 1987 to 1989, the Ivory Coast actively attempted to exert power on the globally dropping cocoa prices by withdrawing from the markets and stopping all exportations. (Losch 2001) However, the Ivory Coasts government was incapable of sustaining such a protest referable to their economys dependence on cocoa profits, forcing them to recommence exportations after two months (ibid). This had micro effect prices, since corporations had enough stored cocoa to sustain the protest, however it had disastrous effects on the Ivorian economy, pushing their already indebted economy into a crisis (ibid). All these issues created the conditions leading to the liberalization of the Ivory Coasts economy.To amend their problems, the Ivory Coast contend to receive loan from the International Monetary Fund (IMF) and World Bank (WB). To receive these loans, countries needed to implement Structural Adjustment Programs, fulfilling the stipulations dictated to them by these foreign organizations. Some conditions incl uded the dismantling of the Caistab, a further drop in the prices of Ivorian cocoa, a cutback in government subsidies given to cocoa growers, a reduction of tariffs on imports and lesser taxation on industries (Ahoua, 1993). These reforms were suppose to yield the country receive funding from transnational corporations, allowing them to repay their debt. Pardoning the countrys debt was not a considered option by the IMF or WB (ibid). Moreover, social reforms were promised, to ameliorate grooming and health care, however this was to be effectuated without receiving additional funding and by promoting privatization, which rendered no real improvements (ibid).The Increasing Power of Transnational CorporationsAll these adjustments were meant to decrease government spending in the cocoa industry and encourage privatization resulting in the development of the country. However, the profits coming from these initiatives were used to further develop the cocoa industry, and not other sector s of the country, increasing the countries cocoa dependency (Isern 2006). Initially, cocoa farmers had control over the markets since there were several buyers competing for their beans, however the centralization of cocoa producer and manu itemurers quick turned the industry into a buyer-driven market (Folds 2001). Three main cocoa bean buyers have subsequently emerged out of this process Barry Callebaut, Cargill and Archer Daniels inland (ADM) (Folds 2002). This oligopoly forces farmers compliance with the conditions demanded by the transnational buyers, otherwise famers are incapable of change their cocoa beans. The Ivory Coasts cocoa bean processor SIFCA was also bought by Cargill, rendering their governments attempts to influence the processing industry ineffective (Losch 2001). To fake matters worse, the global demand for cocoa is far inferior to the supply provided by the Ivory Coast and competing countries, such as Ghana and Indonesia (ibid). This is detrimental because the Ivory Coast is obligate to produce the best quality cocoa for the lowest price possible to attract the investment from the limited number of corporations, resulting in a further drop of the global cocoa (Losch, 2001). Due to this, farmers are a good deal forced to resort to kidskin labour to overcome these constraints.Another holding that limits the power farmers have in the market is the two-tiered nature of the cocoa industry. Folds (2002) distinguishes them into grinders, who transform cocoa beans into butter, powder or liquor, and branders, who then transform the cocoa into holy products. This division corporation create confusion when trying to designate whose right it is to ensure the use of ethical labour practices (Isern, 2006). For example, in 2005, Nestl, ADM and Cargill were sued by the International Labour Rights Fund (ILRF) for buying chocolate from farmers using child labour. Nestl denied its link by stating that it has no direct cocoa procurement in Ivory C oast, since the company directly buys transformed beans from ADM or Cargill (Orr, 2006). Additionally, ADM and Cargill buy their beans from middlemen, and not presently from the cocoa farmers, giving them the opportunity to once again pass off the blame (Parenti, 2008). As a result, consumers are increasingly disconnected from the process and conditions laborers are subjected to in chocolates production.However, certain initiatives have derived from trade liberalization that have helped empower farmers and strive for better labour conditions. There is a maturement consumer demand for products created under ethical conditions, creating special markets that can have prescribed effects in countries (FLO 2005). For example, the reasonable barter movement has aimed to eliminate child labour in the cocoa industry and allows consumer to demonstrate their support for this cause by buying products under these recording labels. (ICCO 2006). Specifically, the Fairtrade Labeling placement (FLO) has set standards to determine what is considered Fair Trade cocoa, and has certified compliant companies and countries, giving consumers the information needed to make responsible purchases (FLO 2005). The Max Havelaar Foundation has also contributed to this cause by providing amusement park wages to small-scale farmers, and supporting fair trade cocoa. (ICCO 2006). Nevertheless, Fair Trade cocoa has remained unpopular, representing 0.1 % of the market (ICCO 2006). Further more, Fair Trade cocoa is not unremarkably produced in the Ivory Coast, rendering zero sales in 2004 (FLO 2005). Although these organizations have been created through consumer demand for them, they have been unsuccessful in producing sustainable change in the Ivory Coast. This demonstrates the need for different initiatives coming from within the countries, as well as global initiatives to reduce child labour.The Consequences on peasant LabourSeveral initiatives have been established to eradicate child labour in the Ivory Coast and the cocoa industry. In fact, the Ivorian government has officially prohibited children under the age of 18 from working, and has subscribe the Harkin-Engel protocol to fully abolish child labour from cocoa farms (Parenti, 2008). The International Labour Organization and transnational corporations, such as Nestle and ADM, also voluntarily signed this protocol to abolish the worst form of child labour (Isern, 2006). taboo activities include wielding a machete, spraying pesticides and heavy lifting, since they are deemed as prejudicious forms of labour (Parenti, 2008). However, even with these attempts, little improvements have been made and issues of blame and certificate of indebtedness have been created. Does the Ivorian governments failed initiatives warrant an increase in activities by international organizations and transnational corporations within their country? Or is this an infringement upon the Ivory Coasts sovereignty? The global communit y answer to this is that transnational corporations should be held responsible. For example, in the newspaper name Slave Chocolate, protestors in San Francisco expressed their disproval of Nestls labour practices, determining that it is doubtlessly Nestls responsibility (Orr, 2006).A resolvent to ensure the responsibility of transnational corporations, originally proposed by The Harkin-Engel protocol, was to implement a child labour label on chocolate products, in order to easily inform consumers closely the labour conditions involved throughout their production. (Parenti, 2008) Although this seemed like a good initiative to reduce child labour, it could instead have harmful effect on the poorest farmers and likewise the Ivorian economy. Consumers would discriminate against chocolate produced with child labour, further punishing the poorest farmers who necessitate its use (Isern 2006). This would ultimately worsen the problem and increase the rates of child labour. This demonstra tes that policies will essentially need to target trade laws and try to establish a more just free market.On the other hand, it can also be argued that child labour in the Ivory Coast is not entirely a product of the economic dependency on cocoa exportations. In Kiellands (2006) study, she remarks that most forms of child labour were in fact seen as a socialization method giving families the opportunity to find out their children the proper methods of farming cocoa. She also remarks that community involvement is a more prevalent value in the Ivorian culture, and therefore child labour is oftentimes seen as the childs contribution to society. However, there are also many dangers with child labour such as trafficking, abuse and harmful labour practices. Additionally, children who worked on cocoa farms were less likely to attend school than those who did not farm cocoa (Kielland 2006). She suggested that more a more effective implementation of political policies would be necessary t o prevent child labour by, for example, providing social operate and ensuring that adult wages were sufficiently high, thus making child labour unnecessary (ibid). A stricter implementation of government policies surrounding school attending could also help eradicate child labour.ConclusionTo conclude, transnational corporations have obtained increasing amounts of power in the cocoa industry and the Ivory Coast because of trade liberalization and the centralization of the cocoa processing industry. This has had several consequences, such as an increased economic dependence on cocoa exports and high rates of child labour within the country. Although the Ivory Coasts government and international organizations have attempted several initiatives to reduce child labour, none have been successful in creating sustainable change. Therefore, it becomes important to try new initiatives that stage the issues of the free market, because there is a direct correlation between child labour and the liberalization of cocoa trade. Furthermore, it is important to understand the surrounding complexities involving child labour, for example the different power relationships that come into play, in trying to effectively abolish it. More research is necessary to find a solution that will allow the Ivory Coasts economy to develop without negatively impacting gay rights.

Individual Opinion on Homosexuality and Religion

idiosyncratic Opinion on Homo sex and ReligionSome spate in the rescript believe quirkiness to be an illness and that it could be rectified. silence almost of of the processes of round the revolve psychological therapies which expects to miscellany homo sexual sexuality to heterosexual), the worlds largest association of psychologists Ameri nooky Psychological Association (APA), stated thatBut the potently religion believes that exactlychity is a sinful act which is against the bible and is and has a direct breach of the bible and other religious books. still, roughly two founders of a ministry put to finish homophiles subsequently described their programme as in trenchant since non sluice one person was changed.The reward of eradicating livelyness has became a political debate in America, with Christian political organisations supporting the slogan of changing queerness through with(predicate) force of leave alone alone. They present that m any nation arg on leaving their homosexual lifestyles due to sexual celibacy and marriage issues.Option aloney, homosexual rights organisations argue that the views ab discover gays and lesbians views misunderstand the signifi fuelce of a gay,and this spr step to the fores to discrimination against the gay and lesbian multitude. additionally, the Ameri butt Psychological Association(APA) has carried out a systematic research, which have resulted to that the psychological strategies be neither effective nor do they at any time change the sexual orientation, tho instead they can cause a considerable harm.The views of the edict on gaynessThe research turn outs that the views concerning queerness argon specifically very delicate.in the community it depends on the culture and religios backgrounds.it is viewed that diffent people view the issue differently match to the cultural values of their company.gays and lesbians have civil rights which support their acts.however the religion does non agree wioth the acts since it views it as a sin and against the laws of the bible and any other sacred book.but in the recent past individuals have tried to talk terms religion inorder for them to be accomondated in the society.Due to the fact that homoeroticism is genetically inherited whence some persons thing its bad to call the transaction sinful.because this is untrue conclusion, and for serious reasons. Firstly, being wrongly prounounced, it stems up the the debate shoot course. The founders and staters of the church building deal with certain acts and doings but though not with such(prenominal) wrong terms as homosexuality. The question that rises in this is if homosexual traits are genetic, then how logical is to accuse such person of good- spiritd in a sinful actions of homosexuality?.The issue that arises here are that homosexuality should be devoted a better wording scorn the fact that the action is considered wrong.Despite the fact that largen sexual perfor mance may be due to the genetic composition of our bodies this do not gurantee that such persons with such large sexual require committing fornication is not sinfil but the fact remains that such actions are sinful before the holy book of God and its something to be shunnerd in the society and such acts are just want any other sin commitrted by a Christian. Sometimes the peoples genetic composition might make/ manoeuvre them to idle disposition and this is sinning meaning that inclining is sinning just like when such a person commits murder or treats people with emphasis in the societyGenerally, homosexual is considered as a deviance and fashion that do not comply with the social norms and values of the society, thus thusly is socially created. Since many persons in the United States society believes that homosexuality is wrongful, society has made and highlighted homosexuality to be a a good wrong. Since moralistic wrong is relative and not absolute to a society.Homosexua lity is not a universal form of sexual immorality. There are most cultures that allow and support this forms of homosexuality. The Western society defy it though, and generally this has clue to the non-accepting view resulting to discrimination towards homosexuals. But despite all this they should understand that homosexuality is a elan of survival for some persons even if minority in the society and they should be accepted and accomondated the way they are and not separate the in the society.The Church similarly encourages those who endure from the feel and passion of homosexuality. Additionally, the Church can usually and surely do a admierable work with this minority group that exists within her flock, more(prenominal)over it can alike reach out and accomondate them since such people, have much compassion especially when dealing with peoples who leap out from different sexual passions. Mo More so the Church is palliate should considers such sexual behaviors as passions even in the presence of neo scientific research that shows how homosexuality in particular have a genetic origin also. (Camperio-Ciani ).Problems of homosexualitythe moral, religious and legal attitudes in trials to tone dget sexual behavior have interfeared with a class view of the medical examination and psychological aspects of homosexuality. This phenomenon is probably much slight destructive of social aspects of our society and culture than is commandly believed, since it is actually more widespread than is generally acknowledged.( Norman Reider, pp 381-384)Homosexuality usually has hormonal,social and psychological factors,where the latter of which are the only ones which can be worked with successfully in our present state . A general practitioners task is to aid those who wish and need help with this problem in finding psychiatric treatment in the same way that persons with any other emotional disturbance are referred. This should be carried out without turn just as w ith any other emotional disturbance.( Norman Reider pp 381-384). ontogeny in the divorce cases due to increased engagement in the among gays and lesbian marriage hence reduced number of heterosexual marriages.also there is a significant number of unmarried men and women in the society.Also Homosexuals are unproductive in character this poses a threat to the societys survival -in the homosexual marriages the acts tough do not lead to production and this stems oup the issue of the society since this will lead to no tomorrows generation in the society hence therefrom thi act is considered immoral in the society and harmful.The recent studies and researches show that the homosexuals have a greater chance of getting psychiatric problems than the heterosexual.such problems are accompanied by some instances such as high grade of suicide,depressin and antisocial personality disorders also use of drugs or substance abuse.( By N.E. Whitehead, Ph.D. Author of My Genes Me Do It)Homosexuals p ose a threat to children-the presence of a couple of(prenominal) homosexuals who do not exercise their normalities. These persons sin against the creator and there is no doubt that they are leading to total destruction of the both the family and our nation. I Pat opposed homosexuals and will do he said that he could do everything he could to restrict the freedom of these people to spread their transmitted infection to the youth of our nation.( Pat Robertson, May 24, 1994 letter).Homosexuality is a heavyhearted and disillusioning lifestyle-this lifestyle is full of stressfull moments hence things are always stressfullhomosexuality poses and brings about the increased incidences of suicide among gay teenagers,the issues of isolation ,discrimination and the cases of violences increase in the societyHomosexuality causes back up and other sexually transimited diseases which are and deadly-hence it does not argue whether homosexuality immensely affects the society or not because homos exuals since AIDS more than heterosexuals this is due to the fact that the same sex are mo prone to such diseases. infact, it is successful to examine the kind of character s that are favourable to HIV infection, and such traits are shown and noticeable by and on the gaysHomosexuals needs whimsical political rights and systems.-Different homosexuals want various things in the real life of politics but there should be equivalence under the law implying that no special or unique or specific treatments or a favours should be performed to a certain unique group of persons alone but just incase such happens then the same should be granted to the othern persons in the same society.The most important areas specifically concerning homosexuality is, marriage laws and government discrimination.Homosexuality undermines religion therefore leading to stability in the society-The argument stems up problems in some several areas in the society,such areas are such as Firstly, many of people think its highly beneficial if religion is undermined and we furthermore think its not correct to compare the widespread of religion with stability (whatever that is probably, the definition is tautological, such that stability is defined as following some religion). As is clear from several essays on morality on my atheism page, it is quite affirmable to have a well-functioning society with caring individuals without any religion at all.Homosexual behavior is also linked with higher rates of promiscuity, tangible disease, mental illness, substance abuse, child sexual abuse and domestic violenceall things that meeting society negatively. Dont try to say homosexual behavior doesnt hurt societyit is a major force that tears down society and harms children.Causes of homosexualityThe causes of homosexuality in the modern society maybe due togenetics inheritance where t where,he baby is born with the gene of homosexuality u in him/her especially from the X-gene from the mother mostly.horm onal imbalanceDuring birth-.here the boy is born with features that are some common with the homosexuals than in the population. such traits might be inherited (genetic), magical spell others might have been caused by the change in the hormones Jeffrey suggests that someone without these traits will be somewhat less likely to become homosexual later than someone with the( Jeffrey Satinover,M.D. )Environmental factors.This comes on various developmental growth needs children kids have, needs for friendship with the grow of the same sex and age-mates of the same sex.Its through this that we understand that the children are not simply born with a reason of their own gender built is formed through the data links and friendships they form with the others, mostly the age bracket of the same sex age-mates.the children always look upon the prove of the same sex first and then to same peers to form their own sexul groupings inorder to understand how they suit in,and the value they own w hether male or female.If this connection lacks then children dont form a healthy same sex amaze and such needs for same sex go unsatisfied then they intensify and take another form. (Satinover, 1996).The developmental factors combined with genetic temperament, impacts perceptions, which all go to the development of homosexuality.Sexual abuse (molestation) or traumatic experiences.They channel to the development of same-sex affection(attractions). personal choice,prenatal hormone defect,lack of bondage between the child and the parent of the same sex.ReincarnationIs homosexual judged harshly?Yes, homosexuals are treated with abhorrence in the societythe reasons to show this discrimination are attached to a lower place-It is said that gays are not natural. And real Americans always reject supernatural things like eyeglasses, polyester, and air conditioning.The society things that gay marriage encourage people to be gays since the behaviuor of people affect others,It is ctritisic ed that encouraging gays to conjoin will lead open all kinds of crazy behaviors. And even people may even decide to marry their pets because a dog has legal standing and can sign a marriage contract.Straight marriage has been around a long time and hasnt changed at all like many of the principles on which this great country was founded women are still property, blacks still cant marry whites, and divorce is still illegal.Straight marriage will be less meaningful if gay marriage were allowed the sanctity of marriages like Britney Spears 55-hour just-for-fun marriage would be destroyed.Straight marriages are valid because they produce children. Gay couples, infertile couples, and one-time(a) people shouldnt be allowed to marry because our orphanages arent full yet, and the world needs more children.Its also assumed that obviously gay parents will raise gay children, since straight parents only raise straight children.Religion do not support marriage of gays . since in many countries the cultures and religions do not sccept such even in the country.Its also criticized that children cannot succeed without the usage models of the both sexes. Children can never succeed without a male and a female role model at home. Thats why we as a society expressly forbid single parents to raise children.Gay marriage will change the foundation of society we could never adapt to new social norms. secure like we havent adapted to cars, the service-sector economy, or longer life spansThe church which is judge to act as the guide to the society about the issue of homosexuality provides the guidelines for such other than the society being so harsh to the people with such minor traits.The church gives the guide lines on the issue-The church says that homosexuality is supposed to be seen as the result of humanitys rebellion against God, against his own nature and well-being and and its not supposed to be seen as a way of surviving and acting for men and women who are created in the likeness and the stick out of Gods.It also says that the people with homosexual tendencies are supposed to seek aid in discovering the specific causes of their homosexual orientation, and to work toward overcoming its harmful effects in their lives.The church also provides that homesexual persons who accept the Jewish-Orthodox faith and everyone else who believes and struggles,instructed and counseled in the Orthodox Christian doctrine and ascetical life hence therefore the persons still in need to justify their behavioral traits in the society may not be included and accomondated in the Churchs sacramental processes,this is due to the fact that the sct of doing so would not assist them but or else harm them.It also suggests that the psychiatrists who are involved and deal with persons with homosexual orientation should be given assistance inorder to help such peoples in their thoughts,actions and feelings with theb regard on the issue of homosexuality. Such assistance will be ideal especially if given to the necessary parents, relatives and friends of the affected individuals in the society.additionally, It is certainly necessary for pastors and church workers also to be given such assistance to be too involved in the rehabilitation of the same.These affirmations on marriage, family, sexuality, and the sanctity of life are issued by the Holy Synod of Bishops on the occasion of the Tenth All-American Council of the Orthodox Church in America (Miami, Florida, July, 1992)ConclusionIts evident that in all societal moral disorders,therefore it follows that homosexuality too leads to the prevention of ones self fulfillment of goals and objectives and the joy see by acting and complying with the creativity and the enduring wisdom of the god the nobleman and the moral values in the society.The Church, and the society in complete protest of the different erroneous opinions on the issue concerning homosexuality, do not by any means reduce neither does it limit b ut rather defends and selfishly oppresses the personal freedom and dignity realistically and authentically understood.Moreover the church is looked upto to regulate the societal moral values and the peoples behavior but at the same time it should leave a room for the minorities with stubborn opinions in the society.

Friday, March 29, 2019

Psychology Essays Human Aggression Violence

psychological science Essays Human Aggression force playHuman Aggression ViolenceThere is not iodine case-by-case Psychological possible action that house adequately history for tender-hearted enmity and madness.To what extent do you agree with this cl innovation?Aggression and forcefulness ar common occurrences in eachday society and some(prenominal)thing we argon exposed to every day. Barlow and Hill (1985) suggest that television in Britain shows a scene of strength every 16 minutes, whilst the Home office research instruction 276 (2004) effectuate 45% of women and 26% of men aged 16-59 stimulate experienced some form of interpersonal furiousness.There bind been many a(prenominal) attempts to apologise why hostility and violence occur, ranging from biological theories such(prenominal) as evolutionary (Buss, 1990), ethological (Lorenz, 1966) and psychodynamic (Freud, 1920) approaches, to the complaisant/bio brotherly explanations offered by the frustration/ onslaught (Dollard et al, 1939), complaisant teaching (Bandura, 1961) and excitement imparting theories (Zillmann, 1979). This essay will focus on the psychodynamic explanation of encroachment as an thought and the social learning supposition that suggests aggression is a learnt behavior. The aim is to critically evaluate these theories and to discuss to what extent they ar able to exempt aggression and violence. social learning theory focuses on the individuals interaction with his or her environment. The suggestion is that all conduct, in this case aggression and violence, is learnt socially. Bandura (1983) puts forward the idea that aggression and baseless behaviour entail obscure skills that require extensive learning, in some other(a) words we are unable to act in an fast-growing(a) or violent steering until we learn (from our environment) how to do it. To look at the role of imitation in aggression Bandura (1961) conducted the famous bobo doll experiment.Childre n were exposed to adults behaving in either truculent or non- assertive manners towards a bobo doll. They were then allowed to play in an selfsame(a) playroom to that previously discover children were shown to imitate rapacious behaviour. Many unlike trials of this experiment were conducted the most famous of these was allowing the children to watch a videotape. In other trials live models and cartoon videos were used. Although this is seen as important evidence to suggest imitation, the theory shadownot fully account for aggression and violence.Cumberbatch (1997) describes how the novelty of the Bobo doll may have had some influence over Banduras results. A follow up study showed the children who had previously been exposed to the toy were five times little violent than those who were new to it. It could besides be argued that the doll was designed to be abused. This also addresses the analogous nature of social learning theory can behaviour shown towards a doll be used to predict or explain behaviour towards a living world. Baron (1977) defines aggression as Behaviour directed towards the goal of harming or injuring another living being who is motivated to debar such behaviour. The acts of violence and aggression observed by Bandura fail to meet this exposition. The doll is of course not a living being and there is no way it could try and avoid any acts towards it.The social learning theory also relies heavily on correlation studies. Lefkowitz et al (1978), Maccoby (1992) and McCord et al (1961) have all pitch that children who have experienced physical discipline from their parents are generally more aggressive than those who have not. However is the parental discipline the only factor that can account for this violent and aggressive behaviour?Social learning theory fails to explain why not everyone who watches a violent film or plays and aggressive video game will imitate what they have seen. one and only(a) hundred children may watch a viol ent film besides only one may go out and copy the behaviour they have seen. This suggests that there is something more than imitation. The theory also fails to account to for nonstop aggressive or violent behaviour. Why does someone continue to wear in a violent or aggressive way without day-and-night exposure to such material?Although many psychologists believe that social learning theory can provide a very complete account of aggression and violence (Hill, 1989), there is still the fundamental question, if all violence is imitated then how did the jump act of violence occur? (Hewitt, 1989)In line of work to the social learning theory, Freud puts forward the suggestion that aggression and violence are innate drives. This means it is something we are born with and is thereof unavoidable. Freud also puts the dialect on the person involved and not the place where violence occurs. end-to-end our lives we face the encroach between the life instinct and the finish instinct. The death instinct is seen as the drive that pushes us towards extinction or non-existence, whilst simultaneously the life instinct strives to preserve life.The death instinct is ultimately self-destructive and if satisfied internally will result in destruction of the individual it must therefore be channelled outside the self. This may be with displacement taking out anger on a impersonal object or through sublimation channelling anger into a more socially acceptable activity for fount music or art. Another suggestion, make by Freuds daughter, is that a person may transform themselves into their victim in order to become the agent of aggression (Freud, 1946).This allows the death instinct to be satisfied transformation into and identification with the victim allows the perpetrator to struggle himself. Freud also believed that divulging in some kind of fantasy violence (for example watching a violent film or playing a violent video game) would satisfy the death instinct and th erefore echt violence will be reduced. This is known as catharsis.There is in reality very little evidence to support catharsis, however Fleshbach (1955) conducted a study in which he aggravated and insulted his participants. Half were then allowed to indulge in fantasy activities. The groups aggressive feelings were then measured victimization projective techniques. The group who engaged in fantasy play were deemed less aggressive. to a fault a study from the Bureau of justice (2006) in America found a negative correlation between the growth in violent video games and the rate of juvenile violent crime. It should, however, be noted that the first study relied heavily of symbolism whilst the second fails to show a exertion and effect relationship between the two.The majority of evidence seems to go against the model of catharsis. Green et al (1975) found that opportunities for dispersing aggression actually increased aggressive behaviour. During a learning task participants were electrocuted in order to increase aggressive tendencies. Half of the participants were allowed to retaliate in someway against their experimenters, Freud would suggest this would reduce aggressiveness. However, when the participants became the experimenter kind of than the subject those who had retaliated previously gave more intense shocks than those who had not retaliated. This is actually more supportive of the social learning theory discussed above.As well as little support evidence there are many other areas upon which Freud is criticised. Hewitt (1989) says that whilst instinctive behaviour is often seen in animals, charitables are removed more advanced creatures and so are much more aware and able to control their actions. The theory also fails to account for the different types of human aggression and violence. There is no typical form in which the behaviour takes what determines how the death instinct must be satisfied? We must also account for calculated murders or other violent crimes. Surely, if catharsis occurred the be after of the act would be enough to satisfy the death instinct and therefore prevent the event from taking place.Although Freuds theory of human aggression and violence puts forward an intelligent argument it fails to recognise and account for many things. Like many psychoanalytic theories it relies on the study of immeasurable and often unknown causes, relying heavily on symbolism and projection. There is also a habit of placing aggressive motives onto non-violent actions. It seems difficult to know precisely where the psychoanalytic definition of aggression lies. This also gives a very bleak outlook on life violence and aggression are unavoidable and therefore non preventable. peerless could even suggest Freud justifies violence and aggression it is after all a human instinct. two theories can both account for certain aspects of human aggression and violence but they cannot fully explain the phenomena. Biological theor ies such as Freuds instinct theory fail to recognise the knotty environment we live in, whilst the social learning theory neglects the role of biology. Both also fail to account for the differences that we see between humans. There is a feeling that each perspective seems to explain something that cannot be definitely defined. Whilst one school tries to explain its own defined version of aggression and violence it neglects anothers own definition. It can therefore be accepted that not one single theory can explain human aggression and violence, agreeing with the given statement.ReferencesBandura, A (1983). Psychological mechanisms of aggression, New York schoolman Press, in Baron, R, A., Richardson, D R (1994) Human aggression, second edition. New York Plenum press.Bandura, A (1961). Transmission of aggression through imitation of aggressive models journal of deviate and social psychology, 63, 575-582. online. Available from http//psychclassics.yorku.ca/Bandura/bobo.htm Accessed 17/01/2007Baron, R.A. (1977). Human Aggression. New York Plenum press.Barlow, G., Hill, A. (1985) Video violence and children, Suffolk Hodder and Stoughton.Bureau of Justice (2006). In Jan Jagodzinski, (2006). Video game cyber subjects, the ethics of violence and addiction A psychoanalytic approach, Psychoanalysis, culture and society, 11, pp 282-303.Buss, D,M. (1990), Evolutionary social psychology Prospects and pitfalls Motivation and emotion 14, 265-286. In Hogg, M, A. and Vaughan, G, M. (2005) fourth edition. Social psychology. UK Pearson prentice Hall.Cumberbatch, G (1997). Is television harmful?, in Cochrane, R and Carroll, D (1997) Psychology and social issues, London Falmer (pp. 171-181)Dollard, J., Doob, L., Miller, N., Mowrer O. and Sears, R. (1939) Frustration and Aggression. New haven, CTYale University Press, in Glassman, Hadad (2006), Approaches to psychology. 4th edition.Norfolk Open University Press.Feshbach, S. (1955) The drive reducing function of fantasy behavio ur daybook of abnormal and social psychology, 50, 3-11. In Glassman, Hadad (2006), Approaches to psychology. 4th edition.Norfolk Open University Press.Freud, A. (1946) The ego and the mechanisms of defense.New York international Univer. Press, 1946. In Transmission of aggression through imitation of aggressive models Journal of abnormal and social psychology, 63, 575-582. online. Available from http//psychclassics.yorku.ca/Bandura/bobo.htm Accessed 17/01/2007Freud, S. (1920) Beyond the pleasure principle, in Glassman, Hadad (2006), Approaches to psychology. 4th edition.Norfolk Open University Press.Hewitt, D et al (1989), Social psychology conflict and continuities, Buckingham Open University PressHill, G (2001), Psychology for AS A level. 2nd edition. Glasgow Oxford university press.Home office research study 276 (2004), Domestic violence, sexual lash out and stalking Findings from the British Crime Survey online. London Home office, Research, using and statistics directorate .Lefkowitz, M, M et al. (1978) Parental punishment A longitudal analysis of effects pull in of general psychiatry, 35, 186-191. In Glassman, Hadad (2006), Approaches to psychology. 4th edition.Norfolk Open University Press.Lorenz, K. (1966) On aggression. New York Harcourt, couple and World, in Hogg, M, A. and Vaughan, G, M. (2005) 4th edition. Social psychology. UK Pearson Prentice Hall.McCord, W et al (1961) familial correlates of aggression in non delinquent male children, Journal of abnormal and social psychology. 62, 79-93. In Glassman, Hadad (2006), Approaches to psychology. 4th edition.Norfolk Open University Press.Mccoby, E,E. (1992) The role of parents in the socialisation of children An diachronic overview, Developmental psychology, 28, 1006-1017. InZillmann, D. (1979). Hostility and aggression. Hillsdale, NJ Erlbaum, in Hogg, M, A. and Vaughan, G, M. (2005) 4th edition. Social psychology. UK Pearson Prentice Hall.

Contributing factors of airline industry globalistion

Contributing factors of skyway attention internationalistionThis report vividly covers the factors which bring forth airway intentness to globalization. Critical psychoanalysis of external and interior(a) environs using strategy tools has besides been considered. For internal environment a particular firm, i.e., British airways has been taken into consideration on which the assignment task is based. Research for the report includes a review of academician books, journals, articles and websites. It besides covers the critical account of globalization on British Airways stating its strengths and weaknesses .The model of core competencies is also explained briefly and applied on the chosen firm.airline exertion is a large and growing manufacture. It facilitates economic growth, inter subject enthronization and world trade and is therefore central to other industries as healthy for globalisation. There ar various forces which lead to globalisation in airline industry. Yip provided some major separate drivers of change. Key drivers of change atomic occur 18 forces likely to affect the structure of an industry sector or commercializeplace (Johnson, G et al 2005).Yips model provides a good example of the drivers that argon increasing the globalisation of industries.Market globalisationSimilar guest necessitatesGlobal customersTransfer suit equal to(p) securities industryingCost globalisationScale economiesSourcing efficiencies gamy Product development salutesCountry-specific courtGlobalisation of government policies employment policiesTechnical standardsHost government policiesGlobalStrategiesGlobalisation of competitionmutualnessCompetitors globalHigh exports/imports(Source Johnson, G et al 2005)Market globalisation in airline industry is a increasing trend because of various reasons of customer needs and preferences as globally they be becoming similar (Johnson et al 2005).For backup or leisure customers do move outside their origin . In gone decade, air travel has grown by 7% per year. go for both business and leisure purpose grew strongly worldwide. Scheduled airlines carried 1.5 one thousand thousand passengers last year. In the leisure market, the availability of large aircraft such as the Boeing 747 do it convenient and affordable for people to travel (adg.stanford.edu).As market globalise, those operate in such markets become global customers and may search for suppliers who operates on global basis (Johnson et al 2005).Business travel has grown as companies ar becoming increasingly global in name of their investments, their supply and fruit chains and their customers. The rapid growth of world trade in goods and run and international direct investment argon also main drivers of globalisation in airline industry (www.scribd.com). The development of global communication and scattering channel may also drive globalisation-the obvious example macrocosm the impact of internet.(Johnson et al 2005). Online booking of tickets and advertising may all be develop globally. This further generates global contend and expectations from customers. Airline industries are unfastened to similar trends. Cost globalisation gives potential for competitive advantage by means of economies of scale. There might be be advantages from the experience built finished wider scale operations. It hindquarters be achieved by central sourcing efficiencies from lowest turn to suppliers a surmount the world (Johnson et al 2005). The activities and policies of government fork over also tended to drive the globalization of industry. Changes in macro environment due to government policies are increasing global competition which in turn encourages further globalization. applied science innovations in industry like the invention of Jumbo jet in 1950 for commercial use also gave a push to globalization.Although there are various enabler of globalisation in airline industry, paradoxically the airline in dustry itself remains subject to highly restrictive national controls on cross border competition and investment. Government to government bilateral agreements often intimidate the routes that international air carriers can fly, the progeny of flights they can schedule and the fares they can charge.(Hamilton and Quinlan 2005).The global airline industry operates in an international regulatory environment that ranges from strict regulation and protectionism in some countries or region to nearly complete deregulation in others. The long-term trend would seem to be in the direction of further deregulation and liberalization, with the unified market created by the EU and the pro alivenessration of bilateral and multilateral open skies agreements marking major advances in this direction since the early 1990s.National ownership requirements, even in the economically developed regions on the world, persist an important barrier to a full globalization of the industry. There is also a str ong trend toward privatizing the more(prenominal) Government-owned national carriers that had long dominated air travel outside the boundaries. There has also been concern expressed that the airline industry is moving from a being highly regulated one to one dominated by global alliances and co-operation amongst airlines, both of which are a priori anti-competitive structures.( Belobaba et al 2009 ) get along 2In todays contemporary organisational environment, the external marketplace is dynamic and rapidly evolving. PESTLE analysis, which provides a framework from which to consider the political, economic, social, expert, legal and environmental factors which influence an organisation (Worthington and Britton, 2006) has been playn. In addition, Porters five forces model analyses the structure of the industry and the relative attractiveness of a particular industry in terms of its potential to generate skipper economic returns and its framework considers the impact of the powe r of buyers and suppliers, the threat of substitutes, barriers to creation and the point of competitive rivalry (Porter, 1980 1995 Barney and Hesterly, 2008).The airline industry has been subject to a number of changes and dynamic forces in the external environment. In recent times, the airline industry has undergone a turbulent report which has led to bankruptcies, mergers and acquisitions and an increase in costs and therefore a reduction in the profit margins (Berry and Jia, 2008). Over the past five years, the uprise cost of fuel, which saw oil prices reach some $100 a barrel is one of the major reasons why airlines are filing for bankruptcy. In 2005, Delta Airlines and North West Airlines, the third and fourth largest US carriers filed for bankruptcy (CNN, 2005). The US Airport Transport Association estimated that between 2001 and 2004, the US airline industry faced losings of over $30 billion. In addition, in 2008, the UK airline carrier, XL collapsed leaving 85,000 holid ay makers stranded (BBC News, 2008). This occurred because the rising costs make it unviable for smaller carriers to operate efficiently. As a result, industry analysts predict a period of consolidation allow occur indoors the industry (BBC News, 2008).Social factors include changes in consumer behaviour. This is largely attributable to technological changes, which includes the emergence of airline websites and multiple price comparison websites, which provides consumers with change magnitude availability of prices and therefore reduces information asymmetry. This therefore, increases the power of buyers (Porter, 1985 Barney and Hesterly, 2008). In addition, the global downturn in the economy has placed an increase financial strain on the industry. This is oddly the case amongst business travellers who are less willing to pay tribute prices for business and first class travel. This has placed a strain on the financial viability of airline operators inwardly the industry. An ad ditional change amongst consumer behaviour is the surrender in customer loyalty. This is partly due to the spread of information and the increased price sensitivity of consumers, which means that the most important factor when reservation a purchasing decision is price and has little to do with the speciality strategies implemented by any given airline (Porter, 1980 1986 Barney and Hesterly, 2008). In terms of political factors, post 9/11 a number of credentials measures and regulations has been implemented in an attempt to avert any future threats from terrorism. This has added increased the costs of airline operators in terms of prep and providing the necessary training and personnel to deal with these rules and regulations. In addition, the initial period following 9/11 saw a decrease in passenger and consumer demand which had a negative effect on the profitability of the airline industry.The arcdegree of rivalry within the airline industry is high. Since the 1980s the indu stry has undergone a period of deregulation and privatisation which has increased competition within the industry and reduced the barriers to entry. Privatisation is essentially involves changing the structure of the industry from public to private ownership. This has had a negative effect on market incumbents, such as British Airways, which has undergone periods of financial turmoil as a result of deregulation, privatisation, reduced barriers to entry and increased competition (Barney and Hesterly, 2008). ). Deregulation is the removal of government rules and regulations, which are tell to constrain an industry.In the past decade, the industry has seen the emergence of low cost airline carriers (Cho et al., 2007 Centro, 2008). These include companies such as easyJet and Ryanair, which operate low-cost flights to a wide variety of European destinations. Low cost airline carriers have had a significant impact on changing the structure of the industry, which has meant that consumers are increasingly price sensitive when it comes to airline travel (Cho et al., 2007 Centro, 2008). ). The low cost sector appears to bucking industry trends and is expanding at a rapid rate. Low cost airlines focus on short-haul flights and try and pack in as many passengers as possible to increase turnover. These companies also generate savings, which are passed on to the consumer by providing customers the ability to book their flights directly over the Internet. As a result, the degree of rivalry within the industry is high (Porter, 1980 1985 Barney and Hesterly, 2008).Despite the deregulation which has occurred and the opening up of the market, barriers to entry are still relatively high. This is because the capital, skills and expertness required to set up an airline company are relatively high (Porter, 1980 1985 Berry and Jia, 2008 Barney and Hesterly, 2008). As such, airline operators need to be able to compete both in terms of cost leadership and preeminence in order to inc entivise consumer purchasing behaviour (Cho et al., 2007 Centro, 2008). Airline operators also need to operate a delicate balance between maintaining a tight-fitting control over costs and implementing cost saving measures whilst maintaining high standards of customer service and safety (Cho et al., 2007 Berry and Jia, 2008). Overall, there exists opportunities and threats in the external market environment, which affects the overall profitability and industry attractiveness of firms operating within the airline industry. Therefore, the level of profits that firms can earn are based on these factors, nonetheless, the internal management of a firm is also critical to organisational performance, which will be discussed in further depth in the next section.Answer 3The airline which has been chosen in order to address the key themes and issues highlighted in this section is British Airways (BA). BA is the largest airline operator in the UK, flying to over 150 destinations across the gl obe. BA started out life in 1975 and was the national airline for the UK, as such, the company operated a noncompetitive structure before it was privatised in the 1980s. The purpose of the privatisation was to make the industry more competitive by exposing the company to completion and external industry forces to purify the operational efficiency of the company as nearly as modify the overall customer experience. However, since changes such as privatisation and industry deregulation, BA has had undergone periods of turbulence, which has been characterised by major successes and major weaknesses. During the 1990s, BA was hailed as one of the most admire and most profitable airlines in the world. However, by the late 1990s BA experienced a massive reduction in profits as a result of decreased demand, increased economic pressures and employee disputes and short relations. In the period between 2008 and 2008, BAs turnover was 9 billion. However, overall, the company made losses of 401 million. This is the greatest loss ever reported by the company and delineate a massive loss compared to the previous year when the company made a profit of 922 million.The airlines major hub is situated at London, Heathrow, the busiest airport in the world in terms of the number of passengers, which pass through daily. BA operates around 220 aircraft. Within the last few months, BA made a preliminary announcement that it was to merge with Spains largest airline, Iberia (Rothwell, 2009). The purpose of this merger is to mitigate weaknesses within the internal operations at BA and develop its strengths through capitalising on synergies which can be prevailed through the merger with Iberia airlines (Barney and Hesterly, 2008 Rothwell, 2009).In order to address the current issues facing BA, including the highest ever reported losses, the company has been forced to undertake significant cost cutting measures, which includes reducing the salaries of existing employees as well as red ucing the overall firm headcount. However, this has resulted in a number of problems for the company. One of the major weaknesses of BA is its history of industrial disputes and tentative history in terms of employee relations. In December, 2009 cabin crew announced a 12 day go down over the Christmas and New Year period, however, this was postponed as it was found to be an illegal strike as the ballot administration implemented by the trade union was not considered to be fair. At the time of writing, the industrial dispute is still an ongoing issue which represents a major weakness to the airline (Milmo and Webb, 2009). The cost of such a strike would run into hundreds of millions, as well as the impact on the injure on customer and employee relations. This represents a critical weakness for the company. Nonetheless, BA has a strong brand and is renowned for safety and customer service. The brand is also trusted across the globe and is a popular choice with business travellers. The heritage of the brand has a strong resonance in the wit of the British and indeed global consumer. This represents a unique strength, which is troublesome for competitors to imitate. Therefore, this represents a source of sustainable competitive advantage for the company (Barney and Hesterly, 2008). This is based on the notion of core competences and how an organisation is able to deploy its resources to develop a distinct set of core competences and strategic capabilities (Barney and Hesterly, 2008). If these resources are distinct, rare and difficult to imitate then this will lead to a source of sustainable competitive advantage (Barney and Hesterly, 2008). As a result, these core competences will ingeminate into superior economic performance when compared with rivals. In the case of BA, external market conditions, as well as internal weaknesses have contributed to recent poor financial performance. However, in the long run, the company will be able to leverage its strength s and core competences to remain competitive within the industry and obtain a source of sustainable competitive advantage.

Thursday, March 28, 2019

When Light Pierced the Darkness by Nechama Tec Essays -- Pierced Darkn

When Light Pierced the Darkness by Nechama TecAltruism bear on for the welfare of others, as opposed to egoism egotismlessness (American 99). In her script entitled When Light Pierced the Darkness, Nechama Tec asserts that people who aided Jews during the Nazi final solution may have acted altruistically however, they did so under a modified description of self-sacrifice. Furthermore, she offers her own definition of altruism within the setting of the Holocaust and designates six traits, which she found rescuers of Jews to exhibit. While many of these traits are observable in the personalities of characters in the films Shop on important Street, Cold Days, carve up We Fall, and Europa Europa, some of them are glaringly absent. Tec offers the general definition of altruism, doing things for others without antepast of external rewards (Tec 151). She indicates that this definition does non apply to people who saved Jews because it does not take into account the tremend ous amount of risk (e.g., the possibility of losing angiotensin-converting enzymes life) involved in their actions. Consequently, she offers the biological science definition of altruism, self destructive behavior performed for the benefit of others, which she perceives to be more applicable to the exploits of non-Jews who carry through Jews (151). Moreover, Tec personally defines altruism within the context of the Nazi Holocaust as, that behavior which is carried out to benefit another?with a possibility of very high, rather than inconsequential, personal costs to the giver (151). In addition, within the parameters of this broad definition she offers two sub-definitions normative altruism and autonomous altruism. Tec explains that normative altruism (e.g., a father donating a kidney... ... were outsiders may have contributed to their selfish, cowardly behavior. Thus, it is the separate who demonstrates a high degree of independence, a strong sense of obligation where ch arity is concerned, and an ability to value every human life no matter of religion or ethnicity that will be most likely to altruistically aid people in distress. Conversely, it is the individual that lacks the aforementioned traits, who will be the least effective in assisting those in need.Works CitedAmerican hereditary pattern Dictionary. Second College Edition. Boston, MA Houghton Mifflin Company.1982.Holland, Agnieszka. Europa Europa. Orion, 1991.Hrebejk, Jan. Divided We Fall. Czech Republic, 2000.Kadar, Jan, and Elmar Klos. Shop on Main Street. Czechoslovakia, 1965.Kovacs, Andras. Cold Days. Hungary, 1966.Tec, Nechama. When Light Pierced the Darkness. 1986.

Wednesday, March 27, 2019

Cultural Assimilation Essay -- United States, American society, ethnic

Many people come to the fall in States for change. Change they think will be given to them the moment they tonus foot on U.S soil, which happens to be incorrect. There is a process to abide before an individual is able to experience change. A process which occurs formerly they allow it to begin. Cultural assimilation is a process by which members of an social minority congregation lose heathen characteristics that distinguish them from the dominant cultural group or take on the cultural characteristics of an other group (medical-dictionary.thefreedictionary.com). It is challenging to begin, that is why when deciding on weather or not to assimilate, people usually weigh the benefits and costs (Konya 2). For example, pargonnts usually assimilate tied(p) if it imposes very large costs for them, because they want the best for their children (Konya 2). But, there are still ethnic groups that assimilate into American society at some(prenominal) lower rates than others because they refuse to until they finally decide to later in their lives. To be more specific, there is evidence to support that Mexicans in Los Angeles, CA are assimilating at lower rates than any other race Now, a new study lays bare what sociologists and others have hanker argued Mexican immigrants are assimilating to life in the unite States less(prenominal) successfully than other immigrants (Schulte 1). The Madonnas of Echo Park by Brando Skyhorse portrays the terrible make caused by the slow cultural assimilation of Mexicans in Los Angeles compared to other races. These effects such as poor income and daily struggles can be seen by dint of genus Felicia Esperanza and remarks made by Freddy Blas as well as Efren Mendoza. Felicia Esperanza, a U.S born citizen was raised in a very Mexican concentrated... ...0 Nov. 2013. . Lazear, Edward P. Mexican Immigration to the United States. Ed. George J. Borjas. Mexican Assimilation in the United States (2007) n. pag. National Bureau of Economi c Research. Web. 20 Nov. 2013. . Schulte, Bret. Mexican Immigrants Prove sulky to Fit In. US News and World Report. USNews.com, 15 May 2008. Web. 15 Nov. 2013. . Skyhorse, Brando. The Madonnas of Echo Park. New York Free, 2010. Print. Teske, Raymond H.C., Jr., and Bardin H. Nelson. Acculturation and Assimilation A Clarification 1.2 (1974) 351-67. Jstor.org. Jstor.org/journals, Feb. 2013. Web. 15 Nov. 2013.

Vitamin C Content of Apple Juice :: essays research papers

Vitamin C Content of Apple Juice foot Complete lack of ascorbic acid (a.k.a Vitamin C) in the diets of humans and other order Primates leads to a classic nutritional disease, scurvy. This disease was widespread in europium during the fifteenth and sixteenth centuries, but it is r ar today. Ascorbic acid is widely distributed in nature, but it occurs in extremely high concentrations in citrus and super acid plants such as green peppers and spinach. Ascorbic acid can be synthesized by all plants and animals, with the exception of humans, other primates, and guinea pigs. Therefore, vitamin C must be present in our dietary substances.The fundamental role of ascorbic acid in metabolic processes is not very well understood. There is some reason that it may be involved in metabolic hydroxylation reactions of tyrosine, proline, and some sex hormone hormones, and in the cleavage-oxidation of homogentisic acid. Its function in these metabolic processes appears to be related to the talent of vitamin C to act as a reducing agent. The adult Recommended quotidian Allowance f vitamin C is 70 mg per day. Some scientists and physicians pick out suggested doses up to 1 to 3 grams per day in order to avail resist the common cold. Deficiency of vitamin C results in swollen joint, abnormal development and maintenance of tissue structures, and eventually scurvy.Determination of vitamin C in biological fluids such as bolld and urine is difficult because only crushed amounts of the vitamin are present and many interfering reducing agents are present. Substances containing sulfhydryl groups, sulfite, and thisosufate are common in biological fluids and react with DCIP, but much more than slowly than ascorbic acid. The interference by sulfhydryl is often minimized by the summation of p-cholormercuribenzoic acid. Materials and SuppliesApple JuiceMetaphosphoric acid/ Acetic acid resoluteness 4%Unknown ascorbic acid in metaphosphoric acid/acetic acid solution, .5mg/ml2,6 dicho lorphenolindophenol solution in waterAscorbic acid oxidase, lyophilized water experimental ProcedureStandard Ascorbic Acid SolutionFill a microburet with DCIP solution. victimisation a pipet, transfer 1.0 ml of the ascorbic acid standard solution to a 50 ml Erlenmeyer flask containing 5 ml of 4% metaphosphoric acid solution. Read and record the initial reading on the buret. Titrate by rapid, dropwise addition of DCIP from the buret while mixing the contents of the flask. Add DCIP solution until a distinct rose-pink color persists for 15-20 seconds. Record the final reading on the buret. Repeat this procedure twice more, each time with a orthogonal 1.

Tuesday, March 26, 2019

Effects of the Hawthorne Studies Essay -- Business Management Human Re

The Hawthorne studies, which began in 1924 and ended in 1933, at the Western Electric Company, deliver produced controversy since its findings in 1939 were publish in the book Management And The Worker. There were so many an(prenominal) elements changed during the tests that many people disagree on the true factors that caused a prink in step to the foreput. Was the rise in output due to the rise in money, or the factor of better human relations? Instead maybe the rise in output was due to the now famous term that came out of the studies known as the Hawthorne case. Hopefully through this research, a better pinch of the factors that contributed to the rise in output can be determined, and ultimately how the Hawthorne studies squeeze the future of business management.The Hawthorne studies developed when William Durgin of the Commonwealth Edison Company started conducting tests in 1918 to put up that different amounts of illumination would alter the amount of production in a c ompany. The results of these studies showed an increase in productivity of 10-20% with increases of light intensity (Wrege, 1986, p. 24). Due to the mastery of these tests, the electric companies formed a committee with Thomas Edison as the chairman. And therefrom began the Illumination tests at Hawthorne in 1924. After three years of scrutiny for illumination, the results concluded that illumination had little or no influence on production. Instead it was concluded that supervision if anything had an influence on output.In 1927 The pass Assembly Room Tests began at Hawthorne. The study lasted nearly five years, fashioning it the longest experiment conducted at Hawthorne. Selection of this department may have been an error by the team of observers. The Relay Assembly department ... ...rizons, Feb., Vol. 21 Issue 1, p31, 6p.Greenwood, G., Ronald. Wrege, D., Charles. (1986). The Hawthorne Studies. Academy of Management Proceedings, p24, 12p.McGregor, Douglas. (1960). The Human S ide of Enterprise. New York McGraw-Hill, pp.114. Shepard, M., John. (1971) On Alex Careys Radical Criticism of the Hawthorne Studies. Academy of Management Journal, Mar., Vol. 14 Issue 1, p23, 10p.Shivers, C. Herbert. (1998) Halos, Horns and Hawthorne potence Flaws in the Evaluation Process. Professional Safety, Mar., Vol. 43, Issue 3.Stephen, R. Jones. (1992). Was there a Hawthorne effect? American Journal of Sociology, Nov., Vol.98, Issue 3.Yunker, W., Gary. (1993).An Explanation of Positive and Negative Hawthorne effect Evidence from the Relay Assembly Test Room and Bank wire Observation Room Studies. Academy of Management Proceedings, p179.