A fundamental objective of the Land Registration Act 2002 Essay

A key goal of the Land Registration Act 2002 - Essay Example The Land Registration Act 2002 targets permitting planned purchasers of land know the presence of any fair interests that might be joined to the land1. The essential suspicion of the law is that forthcoming purchasers ought not take the weight of checking the antagonistic interests appended on the land, yet ought to depend on the land register that mirrors any impartial interests joined to the land2. The Act likewise kills the vast majority of abrogating interests in land by guaranteeing the obligation of exposure and sensible investigation of premiums joined to land3. This paper will predominantly concentrate on the fundamental arrangements of the Act that has guaranteed exact and ideal impression of the status of title of land. The order of the demonstration gave another forward leap in the land title enrollment and confirmation since it changed the component of offer and acquisition of enlisted land from paper based exchanges to electronic exchanges. The Act followed the three sta ndards enunciated by Thoedore Ruoff, a previous Land enlistment center of England. The standards are ‘mirror rule, drapery rule and protection guideline. For unregistered land, the title of the land must be reviewed under the old principles and vender must demonstrate 15 years whole chain of the title from the foundation of the title. The buyer has the obligation to enroll his title to the register inside the specified time, inability to which the person will lose his legitimate bequest in the land. The Land library gives a depiction of the real estate parcel, the legitimate proprietor and whatever other interests that may influence the worth and responsibility for land. ... The electronic system capturers all exchanges identified with the land including the enlistment of the title by the gatherings. The Act has set down conventions identifying with electronic transport, for example, time and date when the electronic miens should produce results. All the electronic marks must be verified and such electronic archives must be marked by totally included gatherings. Segment 4 (1) (g) of the Act requires enlistment on the production of an ensured first lawful home loan that is secured by the store of title deeds and furthermore enrollment of leases with a term surviving from over seven years. The Act additionally concedes the land recorder forces to utilize exchange data on the system so as to screen and reveal such suitable data to different gatherings in electronic movement chain5. The Act likewise encourages electronic settlement by conceding the Land enlistment center the forces to shape or aid arrangement of an organization or put resources into an organ ization with this arrangement of electronic settlement. On account of Abbey National Building society v, Cann, the principle concern was the enrollment hole that happens when an intrigue is made at the purpose of enlistment yet before completion6. In any case, The House of Lords decided that a gathering must have real control of the land at the date of fulfillment of enlistment of any enthusiasm to land so as to accomplish an abrogating status to the land. In viable premise, the acquisition of the land isn't finished on the day the buyer makes official hunt, however following not many days has slipped by. Given the buyer holds up an enlistment inside the specified period, the individual in question isn't limited by notification or limitations that might be made inside the mediating period7. Segment 7 (1)

Managerial accounting Essay Example | Topics and Well Written Essays - 1000 words - 4

Administrative bookkeeping - Essay Example advertisement predominantly shaped key associations with significant players in the Chinese dairy, refreshment and food ventures picking up rights to significant Chinese dairy and drink brands. China was a significant market for Group Danone attributable to which the organization alongside Peregrine framed a Singapore enlisted organization to put resources into Joint Venture keeping 51% offers while Wahaha and workers had 49% of the offers. Anyway the fundamental intention of the Joint Venture is referenced beneath: Yanni Yan (2000) makes reference to that control is a multidimensional factor which assumes a significant job in the limit of a firm to accomplish its objectives which alludes to the procedure by which one individual or gathering impacts to changing degrees, the conduct of another using force and authority. Anyway the fundamental reason for control and impact in joint endeavors is to guarantee that the advantages are acknowledged and targets are accomplished. Further it is referenced by Aimin Yan and Yadong Luo (2001) that the degree of control alludes to how much each gathering in the endeavor practices its control in the administration of the joint endeavor. Schaan (Aimin Yan and Yodan Luo, 2001) during his investigation distinguished wide scope of control instruments accessible to parent firms including the endeavors top managerial staff, formal understandings, arrangements of key work force, arranging procedure, and announcing connections. It is likewise additionally expressed th at assortment of casual instruments are likewise viable for practicing guardian control through setting up integrative structures between the endeavor and the parent, running preparing programs for personnel’s and welcoming supervisors to go to the corporate conferences. It is relevant to make reference to that as per an examination, better happened when the worldwide guardians accepted an increasingly loosened up disposition toward control in any case if there should be an occurrence of tight control by outside accomplice; the endeavors execution is probably going to be enduring (Aimin Yan and Yodan Luo, 2001). Anyway if there should arise an occurrence of Wahaha and

Self reflection 03094 Essay Example | Topics and Well Written Essays - 2500 words

Self reflection 03094 - Essay Example what's more, models and built up my comprehension on how association can adapt up to the issues identified with authoritative culture and subsequently set up amicability in the hierarchical setting productively (Cameron and Quinn, 2011). In this intelligent paper, I will talk about the basic assessment of analysts with respect to authoritative culture and its alternate point of view, for example, hierarchical changes, hierarchical learning and merger-procurement. Authoritative change is the procedure through which an association presents basic changes for example changes in its business methodologies, innovative association, operational strategies and different properties of authoritative culture. My examination has likewise indicated that any association, working in the worldwide global outline, hierarchical change is inescapable for affirming its reality in the ever-changing business world and guaranteeing smooth running of its tasks (Markovic, 2012). I have examined hierarchical change in the exploration of Battilana and Casciaro (2012) as a ceaseless procedure which is significant for any association to audit the inner and outside business condition over an unmistakable timeframe and comprehend whether any progressions are required to acquire the association. My exploration on the speculations presented by Cameron and Green (2012) has uncovered that different inward and outside components existing in the earth in which the business substance is working, powers its administration to get changes the hierarchical procedure. In the event that I think about the outer factors, changes in financial and political guidelines, for example, increment in conversion scale or changes in exchange guidelines after some time profoundly impacts the business to change its short and long haul choices so as to defend the association from acknowledging colossal misfortune. Innovative headway additionally impacts an association to get changes with the goal that the strategy for creation gets swifter and monetary. At times, I

Uncommon Article Gives You the Facts on Research Essay Samples That Only a Few People Know Exist

Uncommon Article Gives You the Facts on Research Essay Samples That Only a Few People Know Exist The Honest to Goodness Truth on Research Essay Samples Persuasive writing can be hard, especially whenever you're made to face with a close-minded audience. Another thing that you should think of before writing is your primary point. Adverts with a simple story, short length and very clear information will often interest the audience and permit them to continue to keep their concentration. For example, you get to figure own the positioning of the statement in addition to how to help it become arguable. Well everyone requires some kind of assistance from time to time. Among the places where I feel I have needed to use my critical thinking skills is in the region of gauging information on the Internet. Actually, besides getting a sample or help with only the subject, you can order an original customized paper from our qualified experts. Obviously, there's a lot which goes into p roducing a superior paper, which must reflect on the eventual price of the item. There are particular steps which you will need to comply with if you are prepared to create a compelling descriptive essay. Therefore, many students and employees decide to obtain affordable essay rather than writing it themselves. A literary analysis essay is a sort of essay which comprises an argumentative analysis of a bit of literature. The first job of the essay examination is an integrated undertaking. The success of the entire essay directly depends upon how good you present the supporting facts. Sample essay outlines can be viewed on the page to give more information regarding a literary essay and the way the components are placed to keep the structure of an essay. The second region of the essay is known as the independent job. The simplest approach to compose a decent persuasive essay is to chose a topic you're confident in. Well, drafting a descriptive essay might not be a simple feat to accomplish. The very best persuasive short essays often concentrate on controversial problems. A History of Research Essay Samples Refuted Literature is a strong force with the capability to influence who and how ordinary men and women love. If you neglect to submit your work punctually, you risk getting a reduced grade or needing to retake the full course. The second goal is to guard the crucial organs of the human body, like the brain, heart, lungs, and even the kidneys. Many students have a tendency to encounter the writing issues due to the shortage of suitable understanding. Details of Research Essay Samples You need to understand how to compose an effective essay as it is a typical foundation for a student's grade. Students have to compose e ssays based on the teacher's instructions or their preferred style in writing. In most cases, they are not taught how to write good papers. Many students discover that it's quite hard to select the topic independently or understand how each kind of literature needs to be structured. Your cheap custom made college paper on Grants essay is going to be written from scratch, and therefore you do not need to fret about its originality. It is suggested to look for the one which has a fantastic reputation and offers high-quality papers at inexpensive rates. Buy customized essays from us and you can't go wrong. Essay writing help provided by such on-line firms may also spend the sort of free samples of essays which are proficiently. Feel free to request adjustments if you believe that any portion of the paper fails to fulfill your expectations. Do not neglect to be aware the source for each evidence you're likely to utilize in your paper. Actually, besides asking for help with the subject, you may also request for a personalized paper, written based on the instructions as set out in your prompt. Order your authentic assignment from and you'll be impressed at how simple it is to finish an excellent custom paper within the shortest time possible! Any type of academic writing has to be organized in a variety of sections and paragraphs. From time to time, a teacher comes across that 1 essay that's perfectly written, all of the way from this issue, to the structure and content. Students can likewise be called upon frequently to be able to continue to keep their attention in the class. Research Essay Samples - Dead or Alive? Helping the needy is among the most crucial methods serve such interest. Folks tend to decide on a variety of themes of who they are and attempt to describe all of them. Friends aren't born overnight, but they may be lost almost as fast. Students lead busy lives and frequently forget about an approaching deadline.

Infant-Mother Attachment and Eating Disorder Behavior Essay

Mary S. Ainsworth was fascinated in the association between infants and their mothers that she later coined the theory of infant-mother attachment. According to Ainsworth, there are three evident attachment patterns that will develop, secure, anxious and avoidant infants. Ainsworth felt it was substantially necessary for a child to transition out from a mother’s attachment and vulnerability to autonomy and independence as a factor in normal development in personality. One of the key points of Ainsworth security theory is that infants need to â€Å"develop a sense of direction and secure dependence on parents† before leaving the nest into a strange and unfamiliar situation (Bretherton, 1992). According to Ainsworth, â€Å"Familial security in the†¦show more content†¦In order for children to thrive, infants need to experience healthy nurturing relationships with their mother or caregiver. Nevertheless, without a mother infant attachment bond the growth and d evelopment of personality would be non-existent to the infant or child. For the explanation if attachment, family factors do play an imperative role for positive development in a mother infant attachment bond. Studies show that an individual who has a healthy relationship with parent s will have a positive or nurturing relationship with their peers (Richters Walters, 1991). Individuals who are alienated growing up are more prone to the development of eating disorders or self-harm behaviors that had negative experiences growing up in a house hold with conflicts, or the lack of socialization skills (Richters Walters, 1992). Relationship between attachment and eating disorders Many theorists believe that family dynamics of those suffering from eating disorders may have contributed to their illness. For instance, anorexic families have sought to be closely related, with perfectionistic attitudes, and higher socioeconomic status. Cole-Detke Konak (1996) described anorexic families as dependent on their child which results in the sufferer being tired to their needy parents by stopping their daughter from actually developing her own autonomy and sense of separation into the world. According to attachment theory, disordered eating behaviors and the attempt to controlShow MoreRelatedRelation: Infant Mother Attachment and Eating Disorders1510 Words   |  7 Pageslinks between infant mother attachment and eating disorder behavior. Throughout this paper the two main theorists that are looked at are Mary S. Ainsworth and John Bowlby. Mary S. Ainsworth’s framework of attachment theory began in Uganda, while studying individual difference in infant behav ior, which is known as the Strange Situation. John Bowlby coined the theory of infant mother attachment based on object relations psychoanalytical theory and the conceptualization that infants need healthy maternalRead MorePsychological Theories, Freudian, Object Relational, And The Main Components Of Attachment And Object Relations Theory1660 Words   |  7 PagesIn this paper, the author will delineate the following developmental theories, Freudian, Object Relational, and the main components found in Attachment. The main theorists that will be addressed include, Sigmund Freud, John Bowlby, Mary Ainsworth, and some work of Melanie Klein. The author will provide a detailed explanation on attachment and object relations theory and how it can be incorporated with a client who is suffering from Anorexia Nervosa and how the impact of development correlates withRead MoreEssay on Attachment Theory2562 Words   |  11 Pagesbetter insight of attachment theory Mary S. Ainsworth develop ed a concept unfolding the underlying behaviors infants display towards their mothers. Without a mother infant bond, insecure attachment can develop causing psychological and emotional stresses. However, a maternal bond is needed for a healthy development in an infant, without the necessary mother infant bond negative behaviors can arise leading to difficulties in relationships, negative behaviors, and an anxious attachment beyond infancyRead MoreAttachment Is The Emotional Bond Created By A Child With Their Primary Caregiver1568 Words   |  7 PagesAttachment is the emotional bond created by a child with their primary caregiver, which is normally the mother. An example of attachment would be if the mother left the baby, and the baby cries from her absence. The connection normally begins when the child is around six months of age. It’s key for infants to develop. Babies aren’t comfortable away from their mothers. It varies around the world, but it is still very imp ortant no matter where the infant is from. It is mainly studied. (Child AdolescentRead More Eating Disorders and Pregnancy Essay2138 Words   |  9 PagesEating Disorders and Pregnancy Pregnancy has often been viewed as a period of great developmental change for women. This is also a period in which previously dormant psychological issues rise to the surface and when current issues have the potential to worsen. Because anorexia nervosa and bulimia nervosa occur primarily in young women, many of whom are of childbearing age, it is important to evaluate the potential medical and psychological consequences when an eating disorderedRead MoreAddiction And It s Affects On The Family System Essay819 Words   |  4 PagesAddiction and it’s Affects on the Family System When a family has a member with addiction with addiction each family and member is uniquely affected by an individual using drugs or alcohol. Affects can cause unmet developmental needs, impaired attachment, economic hardship, legal problems, emotional distress, and sometimes violence being perpetrated against him or her Lander, L, et al. (2013) A family with unmet developmental needs may include children of parents with learning disabilities, poorRead MoreFreud s Trust Vs. Miss Trust Theory907 Words   |  4 Pagesâ€Å"Half of the infants in the United States today have employed mothers, twice the proportion that there were in 1970.† Studies on the affect of mothers going back to work have been varied and have thus for lead to interpretations of the results. The mothers and infants relationship has a central part in a lot of theories on an infants trust development. Freud’s trust vs. miss-trust theory is an example of this. â€Å"Infants must learn to trust their caregivers to meet their needs. Responsive parentingRead MoreEmotional Abuse : Cause And Effects1344 Words   |  6 Pagesaffective quality of the caregiver-infant relationships helps foster the development of empathy (Sorsoli, 2004). The concept of a negative affective relationship or the external influences are currently developing a new type of a society devoid of empathy (Sorsoli, 2004). The lack of emotional connection to the provider in the infant stages creates a lack of attachment to the caregiver in younger adolescent stages (Sorsoli, 2004). The unhealthy attachment between infant and young adolescent has vast impactsRead MoreThe Source Of Referral Was Referred By An Outpatient Mental Health Provider1724 Words   |  7 Pageslife-style transition which has stirred up emotions of abandonment. Alyssa reports she has lived with her biological mother for all of her life, and now is faced with being left alone to live in their home because of biological mother’s choice to move-in with her long-time boyfriend. Alyssa’s moods can be extreme when discussing her current living situation or relationship with her biological mother. It is apparent she is unable to control her anger or self soothe when in a state of feeling despair. AlyssaRead MoreBorderline Personality Disorder And Insecure Attachment2065 Word s   |  9 Pages Borderline Personality Disorder and Insecure Attachment Melanie Countee Marymount University â€Æ' Abstract Borderline Personality Disorder is marked by maladaptive personality traits including chaotic interpersonal relationships, poor impulse control, and emotional instability. Theorists and clinicians have suggested that attachment based theories provide a framework to understanding and assessing BPD etiology. Links between insecure attachment along with abuse and neglect are relevant casual

Classical Greek Conceptions Of Knowledge Essay - 1044 Words

Classical Greek Conceptions of Knowledge All philosophically related through one another, these three philosophers share similar views on human knowledge. Socrates established the Socratic Method of Examination as a way of teaching the ignorant. In the Analogy of the Sun and the Good, Plato uses Socrates’ perspective on knowledge to discuss the intelligible and sensible worlds to relay an underlying message about knowledge and its universal importance. Continuing to follow this Socratic philosophy, Plato introduces his Allegory of the Cave to depict the problem of ignorance using the metaphorical darkness of the cave and the symbolic chains preventing humanity from attaining uncorrupted knowledge. Aristotle forges his own path as he describes the five intellectual virtues and four causes that provide a gateway to untapped knowledge. Through their own examples and theories, the three philosophers outline the necessary means to attaining knowledge and ridding one’s s elf of common ignorance. Plato uses analogies and metaphors to convey his theory on knowledge and eradicating ignorance. In his Analogy of the Sun and the Good, he uses Socrates and his theories to introduce the Sun as a metaphor for the author of all visibility, growth and generation and the Good as the intelligibility of all being, but it itself is beyond being. The Good is the author of all knowing and promotes the necessity of truth in knowledge. Through the Good, Socrates makes apparent that evilShow MoreRelatedAttributes Of God Within Classical Christian Theism978 Words   |  4 PagesAttributes of God in Classical Christian Theism We continue our study of the history of God by looking at His attributes from a number of different viewpoints. We will first examine the view of Classical Theism, then the view of Freewill Theism, and finally that of Open Theism. We begin by defining Classical Theism, also called traditional theism or Augustinian theism. In a section entitled, â€Å"The Classical Christian Concept of God,† Francis Beckwith gives a short definition of Classical Theism in See theRead MorePlato s Allegory Of The Cave Essay1630 Words   |  7 Pagesanother Greek, Glaucon, the image of a cave in which inhabitants are shackled, forced to view nothing but a wall and shadows upon it projected from other light sources. A caveat exists in the prisoners inability to even turn their heads to become aware of sources of light, let alone the real objects for which they have confused shadows their entire lives. Truth becomes a value in the work through the light metaphor. Socrates first details a fire. This moment and its situation within Greek lore becomeRead MoreBiography of Socrates, An Annotated Bibliography1581 Words   |  6 Pagesinterpretation of human wisdom can be given in terms of â€Å"philosophia†.He confirms his analysis by its resolution of some enduring difficulties in the interpretation of Apology and also by providing the answer as to why Socrates continued to search for knowledge which he thought was impossible to attain. He tries to explain the concept of human wisdom with the help of Socrates sayings. Overall, Dylan provides a clear analysis with the proper tone and style. Kenneth C. Blanchard, Jr. â€Å"The Enemies of Socrates:Read MoreThe Utility Of Myth : Plato s Metaphysics1624 Words   |  7 Pagesscratch at the surface of our faculties. To do this, Plato believes we must let our ability to reason override our baser, desires, so as to reach our maximum potential to the benefit of ourselves and the those who come after. Plato s conception of psychology—â€Å"from Greek psyche meaning soul or mind and logos, meaning word, discourse, or reason† is directly tied to his notions of death and the afterlife. In this paper I wish to argue, as with his teacher Socrates, Plato’s views are layered and highlyRead MoreNatural Law : The Human Conception Of Justice Or Moral Right1181 Words   |  5 PagesNatural law can be defined broadly as a philosophical belief that the human conception of justice or moral right is common to all humans and derived from nature. However it’s definition has been highly debated across history and therefore different definitions must be used as to not misinterpret the ideas and principles of different strains of thought within natural law (Boucher, 2009, P.19). It is also very important to distinguish how rights are understood in natural law, which is another contestedRead MoreItalian Renaissance Italy Essay1160 Words   |  5 PagesIn Renaissance Italy, new attitudes and a â€Å"new conception of life itself† emerged, deeply contrasting the attitudes and ideals of the previous Middle Ages. The Italian Renaissance, which occurred during the fourteenth and fifteenth century, was a complete â€Å"rebirth† of Greco-Roman culture and values. Subsequently, it marked an era of great erudition and broad-mindedness, wherein Italians discovered a profound admiration for artistry and philosophical reasoning, leading to a monumental political, scientificRead MoreThe Rebirth Of Ancient Cultures1462 Words   |  6 Pagesrebirth of man and the rebirth of two important ancie nt cultures, Greek and Roman, which had been lost with the beginning of the Middle Ages in Western history. Florence was very prosperous during the late Middle Ages, next to Venice and Milan. It was the birthplace of many important thinkers, artists, architects, and political figures who led the Renaissance. Along with the birth of the philosophy of humanism, the rebirth of ancient Greek and Roman cultures were driven by a revived interest in ancientRead MoreBlending of Renaissance and Reformation in Paradise Lost2288 Words   |  10 Pageshe advances his writing in a classical manner. The theme of Paradise Lost is Biblical as it shows the wrongdoing of Adam and Eve by the influence of Satan and the justice of God for sinners. Milton writes Paradise Lost in such a style which holds classical flavor. So, Milton shows Biblical theme in classical mood. We can also say that Milton’s mind is shaped and moulded by the influence of the Renaissance and the Reformation. On the one ha nd, he drank deep of classical poetry and philosophy and isRead MoreThe Quest: An Archetype in Various Cultural Myths Essay2253 Words   |  10 Pageskeeps repeating—the image of the quest. This archetype functions with various different mythologies as a method of learning about the world, both its external features and what is inside the self. The quest comes from ancient origins and is found in Classical Western culture, but has been fine tuned through the generations. In its most modern interpretations, there are continuing elements of the age old myth, where extenuating circumstances or hubris, place the hero in turmoil and needing to find an answerRead More Differentiating the Renaissance Period and Middle Ages Era in Europe1013 Words   |  5 Pagesprosperity. The decision was made depending on the difference of two eras. Unlike the Renaissance, the Middle Ages were a thousand years of ignorance and superstition. The Renaissance men were leaders in an era of rebirth and learning looked to the Ancient Greeks and Romans for models of advance. Many historians felt that the Middle Ages and the Renaissance were one era. The debate centers around whether the Renaissance was a unique age or a continuation of the Middle Ages. â€Å"Was the Renaissance a period

Critical Analysis of Alien Hand Syndrome-Free-Samples for Students

Question: Discuss about the Critical Thinking and Research Methodology. Answer: Critical Analysis of Alien Hand Syndrome Hassan and Josephs (2016, pg1) define Alien hand syndrome as one of the rare disorders associated with loss of limb ownership or involuntary limb movement. From the name alien hand, it is clear that the condition affects the hand. However, Alien Hand Syndrome is also able to affect the leg. Several literature sources that study this condition claim that it has three variants. The variants are posterior, callosal, and frontal. The frontal variant mostly affects the right hand (because it is most dominant). The condition is characterized by the right hand that is groping, impulsive, compulsive object manipulation, and difficulty in releasing grasped objects. In contrast, the callosal variant mostly affects the left hand (for the right-handed patients). The syndrome is, therefore, characterized by the unavailability of frontal features and limb weakness. The callosal variant has other clinical features. The features are tactile anomia, apraxia, agraphia, visual anomia, Alexia, and negle ct. Lastly, the posterior variant mostly affects the left hand (non-dominant). The variant causes strong estrangement feelings on the affected limb and motor activity that is less complex like non-conflicting or non-purposeful movements (Hassan and Josephs, 2016, pg1). As mentioned before, the Alien Hand Syndrome mostly affects the left hand (non-dominant). However, the findings of this condition are not confined to the limbs alone because it also affects the legs. The etiology of the syndrome can be used to explain its location, temporal progression, onset, and its clinical features. In as much as the infection is unilateral, it can also be bilateral with bilateral strokes or neurodegenerative disorders. On the same note, Bryant (2017), argues that neurodegenerative disorders are often seen together with AHS in subacute forms. If the onset is sudden, the condition is accompanied by a stroke. Those are the common presenting signs after which classical findings follow. In other words, the syndrome progresses in neurodegenerative disorders in which it spreads to contralateral or ipsilateral limbs in months to years (Bryant, 2017). The condition will improve with time following a stroke. However, Panikkath., et al (2017), suggests that AHS may be inte rmittent or short-lived in multiple sclerosis, metabolic causes, or stroke. Alien hand syndrome affects old and middle-aged adults. However, there is a pediatric case reported to be associated with Parry-Romberg syndrome. In the case, the patient has an emotional response to AHS. The responses are frustration, self-criticism, and annoyance with the infected limb. The subject personifies or admonishes the limb as Bmischievous and not part of his own body. The limb then becomes a true alien (Moawad, 2017). In summary, several factors affect the presentation of Alien Hand Syndrome. The factors are lesion location, hand dominance, temporal onset, natural history, and etiology. However, few study activities have established answers regarding AHSs etiopathology. Most of the studies on this illness are limited to inadequate interpretation towards the study criteria, inadequate longitudinal data, and inadequate pathology variety (Panikkath., et al, 2017). References Bryant, C. (2017). How Alien Hand Syndrome Works. [online] HowStuffWorks. Available at: https://science.howstuffworks.com/life/inside-the-mind/human-brain/alien-hand.htm [Accessed 14 Dec. 2017]. Hassan, A. and Josephs, K. (2016). Alien Hand Syndrome. Current Neurology and Neuroscience Reports, 16(8). Moawad, H. (2017). Alien Hand Syndrome | Neurology Times. [online] Neurologytimes.com. Available at: https://www.neurologytimes.com/blog/alien-hand-syndrome [Accessed 14 Dec. 2017]. Panikkath, R., Panikkath, D., Mojumder, D. and Nugent, K. (2017). The alien hand syndrome. [online] Available at: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4059570/ [Accessed 14 Dec. 2017].

Concepts of Minimum Drinking Age

Table of Contents Position statement Appeals and Evidence Refutation Conclusion Work Cited Fixing a minimum drinking age for Americans has always brought out popular debates among American citizens. Since 1984, when an â€Å"act,† established came into law, here in the United States limiting the consumption of alcohol to persons aged 21 and older, there arose defender and attackers of the act. The National Minimum Drinking Age Act of 1984 required all states to raise their minimum purchase and public possession of alcohol age to 21. States that did not comply faced a reduction in highway funds under the Federal Highway Aid Act.Advertising We will write a custom essay sample on Concepts of Minimum Drinking Age specifically for you for only $16.05 $11/page Learn More Some of the supporters of the act acknowledge it as the best legislation ever made in American history. For one, it prohibits alcohol consumption under the age of 21, including the purchase of it. With the â€Å"legal† drinking age set at age 21, both the government and parents perceive this individual as mature and capable of making rational decisions as compared to an 18 year old person. Ironically, as people turn 18, the government allows them to have an identification card. With an identity card, an individual can join military, marry, fly airplanes, participate in pornography, and even work in private or public institutions. However, with all these legal rights allowing them to participate in all of the above activities, the law still bars them from consuming alcohol until they are at least age 21. This is where the debate entangles. The attackers of the Act wonder how, somebody who performs all these functions furthermore under law, cannot drink. Consider the supporter’s point of view: excessive alcohol consumption affects the health of consumers while subjecting them to diseases and accidents. Everyday accidents occur on roads due to drive rs being under the influence of alcohol. In hospitals, many are suffering from irreversible diseases that result from excessive consumption of alcoholic beverages, such as liver disease, and sadly, in dramatically increasing numbers, the misunderstandings between partners who happen to be consumers of this commodity are only increasing. On the other hand, doctors advise against alcohol consumption as it kills brain cells. Perhaps this is the major reason why there is a minimum drinking age. If young people become drunken masters, their educational intellect will be questionable courtesy of alcohol. (Lund Para. 2-11).Advertising Looking for essay on administrative law? Let's see if we can help you! Get your first paper with 15% OFF Learn More During Vietnamese war, minimum drinking age limit was 18 years of age. Young sent to war consumed alcohol at will. As a result, those who remained back utilized this opportunity drinking even when driving. However, traffic accident s increased tremendously. This forced Congress to sanction American states in raising the minimum drinking age from 18 to 21 to control death cases. Since then, road accidents became minimal making road transport comfortable. The paper examines why Americans should never reduce the minimum drinking age from 21 to 18. Position statement The reason why Americans changed the minimum drinking age from 21 to 18 is that, young people caused harm and risks to not only to their lives, but also to other persons. At 18 years of age, most young persons are still undergoing physiological and psychological body changes associated with adolescence. Therefore, parents and governments should control the psychological behavior of young persons especially in colleges, rest they affect themselves physiologically. The issue of minimum drinking age came into limelight when highway accidents increased all over the states of America. This called on the government to exercise its powers so that these cases diminish. From the statistical report compiled by The National Traffic Safety Administration (NHSTA), road accidents committed by drivers under the age of 21 were more, as compared to those under 21 years between 1987 and 1996. This is because; the ‘act’ did not allow purchasing or possession of alcohol to persons less than 21 years of age. On the other hand, between 1882 and 1986, when the minimum drinking age was as from 18, stood at high percent only to drop by around 13 percent when the act became a law. (McCardell Para. 3-8). Appeals and Evidence All over the world, different countries have different minimum drinking age limits. Like in America, these countries have their own debates on this ‘act’. All Americans whether opposing it or supporting the act generally accept that, drinking among young people is sometimes harmful. For example, drinking at the age of between 18 and 20, reduce the sensitivity of these people making then vulnerable to excessiv e alcohol consumption. (McCardell Para. 10-17). Excessive alcohol consumption affects the physiological fitness of these people as they are still developing. Alcohol develops neural pathways in the brain and in a situation where the consumer is young, it leads to memory retardation and other physiological impairment associated with the brain. Therefore, increasing the minimum age from 18 to 21, means preserving young people from memory loss, excessive drinking and social and physical destructions.Advertising We will write a custom essay sample on Concepts of Minimum Drinking Age specifically for you for only $16.05 $11/page Learn More Young people at the age of 18 and 21 can engage in uncontrollable drinking behaviors than those above 21. Consequently, these people can participate in unruly and aggressive behaviors, which lead to highway accidents and other social and physical calamities. Most young people in United States colleges engage in binge drink ing; and guess the result is risky and abnormal activities like sexual behaviors, which make them vulnerable to sexually transmitted disease. The fixation of a minimum drinking age in United States is about cultural attitude where injuries, defiant behaviors and accidents become minimal. (Faler Para. 2-4). Refutation Some researchers argue that, the occurrence of road accidents is blame on the police and therefore, the minimum drinking age is subjective. On the contrary, these researchers must understand that, controlling road accidents start with psychological behaviors. Young people possessing vehicles and therefore, driving at a tender age, adding alcohol influence on their part, sum up to road accidents. Police cannot be under blame for mistakes committed under legal grounds. The law should be abiding and discourage those under 21 never to drink. The problem with uncontrolled young people is that, they utilize cultural and religious norms, government laws, media adverts, peer pr essure and family background to do malicious things. The debate should rather focus on the harmfulness of introducing alcohol to young persons and its impact in adulthood. Young people even less than 25 years of age are prone to a myriad of risks if they excessively consume alcohol. The best way however can be, to provide sound education to young persons. This cans help them realize the dangers or alcohol at a tender age and its impact on the brain, education, workplaces and in adulthood. Alcohol among the youth is responsible for unruly behavior in colleges and unnecessary demonstrations in public universities. In other occasions, transnational crimes and terrorism attacks receive propulsion from drug and alcohol abuse. With all these cultural and social effects, the minimum drinking age should be at 21. (Schlesinger and Jefferson Para 6-7).Advertising Looking for essay on administrative law? Let's see if we can help you! Get your first paper with 15% OFF Learn More Conclusion The law on minimum drinking age came into limelight when road and highway accidents increased. Most accidents occurred because drivers were under influence of alcohol. Although the government changed the minimum age from 21 to 18 during Vietnamese war, it later changed it back to 21 years. Since then, there has been minimal number of road accidents as compared to the former. This was success on the part of government and Americans at large. However, parents and tutors should be at the fore front counseling youths on the dangers of alcohol. If their attitude changes, they will start viewing themselves as not prisoners to law. On the other hand, driving schools should instruct their trainees not to drive while drunk. They can withdraw driving licenses of drivers who commit accidents if found to be under the influence of alcohol. Highway accidents do happen due to reckless driving. Reckless driving associates itself with poor concentrations, one of it being alcohol consumpti on. Lastly, law-enforcing agencies should ensure no young adult under the age of 18 and 20 involve in binge drinking. Alcohol consumption not only causes depression and stomach problems, but loss of life and property as well. Work Cited Faler, Mary. The Legal Drinking Age Debate: Should It Be Lowered? 2009. Web. Lund, Adrian. Protecting Teens from the Dangers of Alcohol Use and Abuse: Wishful Thinking versus Science. 2007. Web. McCardell, John. Commentary: Drinking Age of 21 Doesn’t Work.  2009. Web. Schlesinger, Robert, Jefferson, Thomas. The Drinking Age Debate: Time to Go From 21 to 18, But It’s Not an Easy Call. 2009. Web. This essay on Concepts of Minimum Drinking Age was written and submitted by user Abb1ga1l to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.

The Law of All Land essays

The Law of All Land essays A Study of Diplomatic Immunities and Privileges I. Introduction A Brief History of Diplomacy B. Foreign Sovereign Immunities Act of 1976 and Diplomatic Relations Act of 1978 IV. U.S. Policy on Diplomatic Immunity V. Abuses of Diplomatic Immunities and Privileges I. INTRODUCTION A Brief History of Diplomacy Sadaam Hussein emerged as public enemy number one because of his blatant disregard to international law and relations, in his continued hostage hold of U.S. diplomats. As a result, foreign and national security policies had to be enacted to handle the hostile foreign affair. Diplomacy became one of the chief instruments of foreign and national security employed in the Iranian hostage crisis and other international conflicts preceding and succeeding. The history of diplomacy can be traced to the intense diplomatic intercourse between ancient Egypt and its neighbors long before 1000 BC. Not until the twelfth and thirteenth centuries, however, did diplomacy begin to assume its modern form. Rules were developed by the Italian city-states to govern the appointment and conduct of ambassadors, and in 1455, Milan established the first permanent embassy in Genoa. In the sixteenth century, other European states followed the Italian example and appointed permanent ambassadors. Under the inf luence of sixteenth and seventeenth century writers, such as Hugo Grotius and Alberico Gentili, the privileges of diplomats were more precisely defined and incorporated in international law. The Congress of Vienna in 1815 and the Vienna Convention on Diplomatic and Consular Relations in 1961 and 1963 defined and redefined, respectively, classes of diplomatic representatives. In the twentieth century, consular and diplomatic services, formerly separate, have been merged in many countries, including the United States (1924). Diplomacy is the activity of preventing and solving conflicts by representatives, namely diplo...

Demonstrates your understanding of communication theories by applying Essay

Demonstrates your understanding of communication theories by applying the theories we have studied - Essay Example According to Vygotsky, this zone refers to an area of exploration for which the learner is cognitively prepared but need assistance and social interaction to fully develop. Vygotsky therefore believes that a teacher or a more experienced peer has the ability to provide t he student with what is termed as scaffolding, which helps the student to develop complex skills. This paper provides an insightful analysis of Vygotsky’s sociocultural theory and its relevance in young children is thinking and talking, as well as sociocultural influence in youths’ participation in gambling behavior. According to Vygotsky’s sociocultural theory, the most appropriate strategies for supporting the intellectual knowledge and skills of learners as well as enhancing intentional learning include collaborative leaning, modeling, discourse, and scaffolding. As mentioned earlier, his most prominent contribution is the concept of Zone of Proximal Development. In his own words, the Zone of Proximal Development refers to the distance between a child’s actual developmental level as dictated by independent problem solving, and the higher level of potential development as determined by problem solving under adult guidance or with support from more capable peers. In his journal article, Young Children Thinking and Talking: Using sociocultrual theory for multilayered analysis, Robbins (2012) applies the ideas and concepts of Vygotsky’s sociocultural theory in describing the thinking and communication of young children. According to Robbins(2012), Vygotsky’s sociocultural theory provides an rich information base upon which we can understand how the biological line of development and cultural line contribute towards the overall development of children’s thinking. He believes that the lower order mental processes with which children are born with are transformed into higher mental process through interaction with others as well as the mediation of various

Historical english paper Research Example | Topics and Well Written Essays - 1250 words

Historical english - Research Paper Example Thou, as used in the play, has a meaning of the second person pronoun in the singular form. It is in its archaic form as it has been currently replaced by ‘you’. It is in the normative form. Its oblique or objective form is ‘thee,’ whereas the possessive form is ‘thine.’ The word following it in the sentence is ‘done,’ which begins with a consonant letter. ‘Thou’ was originally a singular counterpart of ‘ye’, a pronoun, which traces its origin in the Ancient Indo-Europe. Due to the language progress in the Indo-Europe, the word was later adapted and used in the expression of intimacy, disrespect, as well as familiarity. The word has been used in the inquisitive sentence by Horner to Quack. As stated, the word has been used in asking a question. It is preceded by the word, ‘hast’, which is also an archaic word. This is one of the common features of archaic words. In this case, Horner is using a commanding tone in asking the question to his colleague. This is a proof that the word is mainly used or applied in making interrogations, or in interrogating sentences. Using it in a sentence, especially in a play, implies direct approach of a particular character on the other. In general, the author of the play has used the word to succeed in the achievement of commanding tone in this section of the play. The tone is necessary for the smooth continuation or enhancement of the play’s plot. It is also a depiction of the relationship existing between the speaker, Horner and the addressee, Quack. Considering the general flow of the play and the character roles in the play, Horner is portrayed as a leader, a charismatic individual and a more aggressive person compared to many other characters in the play. Another instance where the word has been used is by Horner talking to Har. â€Å"But why shouldst thou be afraid†¦Ã¢â‚¬  (Wycherley 26). The second word in the

How Christians put there believe of helping others into practise Essay Example for Free

How Christians put there believe of helping others into practise Essay Helping others is a big part of being a Christian. One of the commandments is Love thy neighbour; so many Christians do what they can to help. Charities are a popular way of helping the poor. Both Christian and non-Christian charities provide a wide range of help for the poor and needy. Christian Aid was set up in Britain and Ireland at the end of the Second World War. Its main aims were to improve the quality of peoples lives, particularly those of refugees who were struggling to cope with the aftermath of World War Two. It also funded Churches to help repair damage caused by the war. Eventually Christian Aids work started to involve other countries. It now has an income of approximately à ¯Ã‚ ¿Ã‚ ½40 million a year, and there are forty churches in the United Kingdom and Ireland who are part of Christian Aid. Most of the money, which they make through door-to-door collections and donations from members of the public and various churches, is put towards development work to help people in the long term. There are many other Christian charities that help in different ways. The Church of England Childrens society helps children in need. The Hospice Movement helps terminally ill people live out there life in a relaxed, caring environment making the experience less stressful for the patient and the patients family. Another famous Christian organisation is the Samaritans which was set up by Chad Varah, a priest. Chad Varah set up this organisation because horrified to find out that 3 suicides took place every day in London. He believed that the best way to help someone who was contemplating committing suicide was to talk to them. He set up a phone in his church and advertised locally for advice for people who were feeling suicidal. Now The Samaritans deal with 2 250 000 calls a year Sir John Templeton is a famous charitable Christian. He grew up in a poor family on a farm in Tennessee. He was educated at both Yale and Oxford University and he became a financial consultant in New York. Throughout his life he gave 10% of his earnings (a process called tithing) to help the poor. Eventually he became very wealthy running a multimillion dollar investment company, where he successfully managed funds for over two million people world wide. In 1972 he started the Templeton prize to be awarded for progress in religion. The Templeton prize is now worth more than the Noble Peace Prize. Fifteen years later he was knighted for services in philanthropy. In 1992, he sold his investment company for $400 million. He still gives money to support projects around the world. George Macleod is another famous charitable Christian. In 1938 he set up a Christian community on Iona, an island off of Scotland. He found volunteers to learn building, stone masonry and carpentry skills and together they rebuilt Ionas ruined abbey. After that he opened a centre to provide shelter for young people from across the world to live in a community. The people of this community cook, clean, garden and work away. When they are not working they pray. The people who live there feel it is better for everyone to share and live in a close community than be rich and not. Oscar Romero was born in 1917. He became Archbishop of El Salvador in 1977. When he took his post his meekness encouraged the corrupt authorities to take advantage and step up there reign of terror against the church; priests were murdered and tortured. When he witnessed the murder of a particular priest Romero began to think differently. He began to speak out against the government in his sermons. In March 1980 he was shot while speaking out against the government in a hospital chapel. He is seen as a great martyr, who took the greatest sacrifice for what he believed in.

Prisons Dont Work Essay examples -- Critical Thinking Essays

Right now in the United States of America murderers, rapists, and child molesters are being set free. Prisoners are watching T.V., eating a meal, and using exercise equipment while law abiding citizens are starving and living in the gutters. Prisoners even have their own periodical. Dangerous criminals are walking the streets and crime is a way of life to many Americans. In America, crime does pay because our nations prison system is not working. The nations prison system must be changed because of major problems with the system such as overcrowding and the fact that early release programs do not work. Building more jails is expensive and does not solve anything. These problems can be solved by giving prisoners no chance for parole and imprisoning only violent offenders. The non-violent offenders should enter a work program for the duration of their sentence. Since 1980, jail and prison populations have grown by 172 percent(United States 11 Sept. 1994). Overcrowding is both inhumane to the prisoner and dangerous to the prison staff. When you put a lot of people, especially criminals, in close quarters tensions rise and the chance of a riot increases. If a riot occurs both prisoners and guards are put in danger. In Texas the jails are full. There is an estimated backlog of 29,000 state prisoners who are incarcerated in county jails awaiting new cells.(Brida 24 Nov. 1994) Texas is not the only state with overcrowding problems. For example, Ohios prison system is operating at 180 percent of capacity.(Varnam 16) Also, the federal prison system is 37 percent over-capacity(Clark 4 Feb. 1994). Statistics like this are found across the country. Prisons should have two objectives; 1) keep dangerous criminals off the streets ... ...ng more prisons cut the crime rate? The CQ Researcher 4 Feb. 1994URL:gopher://gopher.cqalert.com/0F1:25674:05CQR_FEBRUARY1994%20gopher. Cunniff, Mark A. and Patrick A. Langan. Recidivism of Felons on Probation, 1986-89. 24 Nov. 1994(found) URL:gopher://justice2. usdoj.gov/00/ojp/bjs/13. Prison Inmates To Work In Wildlife Management Areas.Associated Press 24 Nov. 1994(found) URL:gopher://gopher.cic.net/00/nircomm/ gopher/e-serials/general/education/univ-newspapers/daily- texan/today/94041507.s03_Prison.gz. Sanchez , Edward J. Look Beyond Capital Punishment. 26 Nov. 1994 (found) URL:?. United States. Department of Justice. Bureau of Justice Statistics. Probation And Parole Populations Reach New Highs. 11 Sept. 1994. URL:gopher://justice2.usdoj.gov/00/ojp/bjs/probpar.txt. Voters Get Tough On Criminals. The Associated Press 9 Nov. 1994. URL:?. Prisons Don't Work Essay examples -- Critical Thinking Essays Right now in the United States of America murderers, rapists, and child molesters are being set free. Prisoners are watching T.V., eating a meal, and using exercise equipment while law abiding citizens are starving and living in the gutters. Prisoners even have their own periodical. Dangerous criminals are walking the streets and crime is a way of life to many Americans. In America, crime does pay because our nations prison system is not working. The nations prison system must be changed because of major problems with the system such as overcrowding and the fact that early release programs do not work. Building more jails is expensive and does not solve anything. These problems can be solved by giving prisoners no chance for parole and imprisoning only violent offenders. The non-violent offenders should enter a work program for the duration of their sentence. Since 1980, jail and prison populations have grown by 172 percent(United States 11 Sept. 1994). Overcrowding is both inhumane to the prisoner and dangerous to the prison staff. When you put a lot of people, especially criminals, in close quarters tensions rise and the chance of a riot increases. If a riot occurs both prisoners and guards are put in danger. In Texas the jails are full. There is an estimated backlog of 29,000 state prisoners who are incarcerated in county jails awaiting new cells.(Brida 24 Nov. 1994) Texas is not the only state with overcrowding problems. For example, Ohios prison system is operating at 180 percent of capacity.(Varnam 16) Also, the federal prison system is 37 percent over-capacity(Clark 4 Feb. 1994). Statistics like this are found across the country. Prisons should have two objectives; 1) keep dangerous criminals off the streets ... ...ng more prisons cut the crime rate? The CQ Researcher 4 Feb. 1994URL:gopher://gopher.cqalert.com/0F1:25674:05CQR_FEBRUARY1994%20gopher. Cunniff, Mark A. and Patrick A. Langan. Recidivism of Felons on Probation, 1986-89. 24 Nov. 1994(found) URL:gopher://justice2. usdoj.gov/00/ojp/bjs/13. Prison Inmates To Work In Wildlife Management Areas.Associated Press 24 Nov. 1994(found) URL:gopher://gopher.cic.net/00/nircomm/ gopher/e-serials/general/education/univ-newspapers/daily- texan/today/94041507.s03_Prison.gz. Sanchez , Edward J. Look Beyond Capital Punishment. 26 Nov. 1994 (found) URL:?. United States. Department of Justice. Bureau of Justice Statistics. Probation And Parole Populations Reach New Highs. 11 Sept. 1994. URL:gopher://justice2.usdoj.gov/00/ojp/bjs/probpar.txt. Voters Get Tough On Criminals. The Associated Press 9 Nov. 1994. URL:?.

Though the book “A Man without a Country”

Though the book â€Å"A Man without a Country† is written in funny way, it has a serious message for those who are concerned about humanity in general and America in particular. It intimately expresses the author’s deep anguish at the prevailing situation in the United States despising the Bush administration and its policies. Kurt Vonnegut in his own kidding and humorous style strongly condemns the Americans’ lust for oil. He laments at the inhuman administration that has dehumanized millions of people in the name of race and religion. He criticizes the unthinking and uncaring attitude of people in damaging the environment. He is not quite hopeful of a great future for the coming generations given the indifferent and reckless attitude of the present people. He says, â€Å"I know of very few people who are dreaming of a world for their grandchildren†. Using humor as a physiological response to the fear, he expresses his deep concern for the future generations and his total disregard for the people who are in the positions of power causing loss to people and to the green earth. He strongly advocates that everyone should save his own and others’ lives and be honorable. The title of the Book A Man without a Country, with the sub-title â€Å"A Memoir of Life in George W Bush's America† is a collection of small essays, speeches and interviews despising the Bush administration. Fitting the definition of a memoir, the book comments on the incidents happened during administration of famous personality President Bush. The author calls himself a man without a country except for the librarians as he is quite disgusted with the present day Americans who present themselves as proud and pitiless war lovers. It is clear that he does not like to be associated with people who have dehumanized millions and millions of human beings in the name of religion and race. The book consists of intimate and informal conversations of an eighty year old man about the affairs of the day urging the people to save themselves and the earth and to be honorable.

Deadlines for implementation - Free Essay Example

Sample details Pages: 9 Words: 2808 Downloads: 10 Date added: 2017/06/26 Category Law Essay Type Argumentative essay Did you like this example? Question 1 (a) This question concerns the UKà ¢Ã¢â€š ¬Ã¢â€ž ¢s failure to implement Directive 2006/2001 by the deadline for implementation, which was 31 July 2008. The Directive would have limited the amount of chemical ABC in local groundwater. (i) Local residents have complained of a bad small and seek redress. Don’t waste time! Our writers will create an original "Deadlines for implementation" essay for you Create order (ii) Local gardeners have become ill due to high levels of chemical ABC and also seek redress. This question raises the issue of whether a Member State can be held liable for failure to implement a Directive on time. The case of Ven Gend en Loos[1] established that Community law takes supremacy over national law. This was repeated in Costa v ENEL.[2] Therefore, the terms of the Directive cannot à ¢Ã¢â€š ¬Ã…“be overridden by domestic legislation, however framed.à ¢Ã¢â€š ¬Ã‚ [3] Article 249 EC states that Directives are, à ¢Ã¢â€š ¬Ã…“binding as to the result to be achieved, upon each Member State.à ¢Ã¢â€š ¬Ã‚  Therefore, in Van Duyn, the ECJ held that Directives could have direct effect and could be relied upon directly by individuals in litigation.[4] In Ratti the ECJ held that à ¢Ã¢â€š ¬Ã…“a Member State which has not adopted the implementing measures required by the directive in the prescribed periods may not rely, as against individuals, on its own failure to per form the obligations which the Directive entails.à ¢Ã¢â€š ¬Ã‚ [5] The reasoning here is quite simple. The ECJ first found that Directives took precedence over national law. It then held that they were binding on Member States and could have Direct Effect. The effect of this is that the residents will be able to hold the terms of the Directive against the Government, who failed to implement it on time.[6] However, they will not be able to hold the terms of the Directive against Fattenem. This is because Fattenem has simply been operating as best it could under the UK law of the time. This is because of the reasoning applied by the ECJ in Marshall, where it stated à ¢Ã¢â€š ¬Ã…“the binding nature of a Directive exists onlyà ¢Ã¢â€š ¬Ã‚  against Member States. The Directive was addressed to the UK Government, not to Fattenem, and therefore creates no legal obligations on Fattenem. However, according to Von Colson[7] UK courts would look at the case, and at national law, in l ight of the Directive. This is known as the indirect effect of Directives.[8] If national law could be interpreted in a manner that would cause it to comply with the Directives, using the accepted methods of statutory interpretation available to UK courts, then the courts are under an obligation to give the national legislation such an interpretation. However, it is suggested here that the residents and gardeners are far more likely to be successful using the Directive directly against the Government rather than seeking to use it indirectly against Fattenem. Relying on the Directive against the Government, the residents and gardeners will be able to seek financial compensation from the Government. In Francovich[9] the ECJ held that à ¢Ã¢â€š ¬Ã…“the full effectiveness of Community rulesà ¢Ã¢â€š ¬Ã‚  requires that litigants be able to seek compensation from a Member State in situations where they have suffered a loss as a result of a failure to implement a Directive.[10] Wh en seeking compensation from the Government however, it may well be the case that the gardeners and the other residents are not in exactly the same boat. As we have seen, the gardeners have suffered illness due to the Governmentà ¢Ã¢â€š ¬Ã¢â€ž ¢s failure to implement the Directive, whereas the other residents have only been subjected to a bad smell. As the ECJ stated in Francovich, à ¢Ã¢â€š ¬Ã…“the result prescribed by the directive should entail the grant of rights to individualsà ¢Ã¢â€š ¬Ã‚ ¦[and] it should be possible to identify the content of those rights.à ¢Ã¢â€š ¬Ã‚  After such rights have been identified, à ¢Ã¢â€š ¬Ã…“the existence of a causal link between the breach of the Stateà ¢Ã¢â€š ¬Ã¢â€ž ¢s obligations and the harm suffered by the injured partiesà ¢Ã¢â€š ¬Ã‚  must be established. The harm suffered by the gardeners is clear and quantifiable. It would also be fairly easy to establish that the Directive was intended to grant a right to the protection of heal th from the chemicals concerned. However, a right not to smell the chemicals might be more difficult to establish. It also is not certain that compliance with the Directive would have removed the smell of the chemicals, or merely removed their ability to endanger health. Therefore, in conclusion, I would advise that the gardeners stand a good chance of seeking compensation from the UK Government for its failure to implement the relevant Directive, based on the direct effect of the Directive. I would not advise them to seek compensation from Fattenem based on the indirect effect of the Directive. Furthermore, I would warn the wider residents, who did not become ill from the chemical, that they would find it difficult to establish a right not to smell chemicals, in the Directive, and furthermore, they might find it difficult to establish a causal link between the smell and the Governmentà ¢Ã¢â€š ¬Ã¢â€ž ¢s failure to implement the Directive. Question 1 (b) The second part of the question relates to a Directive that the UK Government has implemented but has implemented inadequately. This is because, while the Directive calls for compulsory controls on chemical XYZ, the Government has established voluntary controls. The residents and gardeners are now saying that this voluntary regime has caused them to suffer from poisoning from XYZ. The situation here is very similar to that described above. As Article 249 EC states, Directives are binding à ¢Ã¢â€š ¬Ã…“as to the result to be achieved.à ¢Ã¢â€š ¬Ã‚  Directives do not prescribe actions or methods of regulation to Member States, they only prescribe results. Article 249 goes on to state that Directives à ¢Ã¢â€š ¬Ã…“leave to the national authorities the choice of form and methods.à ¢Ã¢â€š ¬Ã‚  It is not therefore by taking measures that a Member State complies with a Directive, it is by achieving results. We have seen in this case study however, that Directive 2002/2006 does specify that a com pulsory testing regime must be put into place by each Member State by the deadline for implementation. The UK has not done this. Therefore, just as in the scenario above, it has failed to properly implement the Directive. The residents and gardeners will be able to bring an action against the UK Government for its failure to implement the Directive completely. In this case it will be even more important that the issue of causation is looked at properly. It will be necessary to show that Fattenem is in fact abusing the voluntary regime and that it would have acted differently had the Government adopted the compulsory testing regime. This type of investigation would for example, take into account the effectiveness of a compulsory testing regime and it might well be the case that under the compulsory testing, it would still take time for Fattenem and similar operators to reduce their output of XYZ. It will also be necessary for the residents and gardeners to show that the ill effects t hey are suffering are in fact due to chemical XYZ and are not due to chemical ABC or some other cause. The other area where it will be difficult to hold the Government to account is the statement from the Francovich case[11] in which the Court held that à ¢Ã¢â€š ¬Ã…“the result prescribed by the directive should entail the grant of rights to individuals,à ¢Ã¢â€š ¬Ã‚  and furthermore, that à ¢Ã¢â€š ¬Ã…“it should be possible to identify the content of those rights.à ¢Ã¢â€š ¬Ã‚  The question is sure to arise of whether or not a the establishment of a compulsory testing regime for chemicals is designed to grant rights on individuals. It appears as if individuals have nothing to do with such an arrangement and are merely an indirect beneficiary of the result of such compulsory testing. It is questionable in this case therefore, whether Directive 2002/2006 creates legally enforceable rights which the residents and gardeners of the town will be able to enforce. However, thei r position is still quite strong since they are clearly being affected by the failure of the company to monitor its output of XYZ. Arguments similar to those put forward below in relation to standing and individual concern would be put forward and the discussion below will be of use in this respect. Question 2 This question relates to the ability of the UK Government to challenge a Community act under Article 230 EC. It also concerns the ability of the Sheep Farmerà ¢Ã¢â€š ¬Ã¢â€ž ¢s Association (SFA) to challenge a Community act on the ground that they are individually effected by the act. Article 230 allows the ECJ to rule on the à ¢Ã¢â€š ¬Ã…“legality of acts adoptedà ¢Ã¢â€š ¬Ã‚  by the European Community which are à ¢Ã¢â€š ¬Ã…“intended to have legal effectà ¢Ã¢â€š ¬Ã‚ . The Court can strike down any law that it believes does not comply with the requirements of the Treaties. Under Article 230(2) EC, the UK is a privileged applicant and can therefore challenge any act of the EU Institutions. Decisions are specifically permitted to be challenged. The grounds on which the Court might annul the decision above, as set out in Article 230 are that the Community lacked competence to legislate, that the Community breached an essential procedural requirement when making the decision, or that the decision breached the fundamental principles of community law or was an abuse of power. The ground on which the UK Government will be challenging this Decision is on procedural grounds. The Community adopted a procedure that required Qualified Majority Voting (QMV). However, the UK is of the belief that the correct procedure would have required unanimity. The Court would look at this claim from the UK and decide if the Community made the Decision based on the correct Treaty provisions and used the correct legislative procedure. The SFA is not a privileged applicant under Article 230(2). However, it may still bring an action under Article 230(4) if it c an show that the Decision à ¢Ã¢â€š ¬Ã…“is of direct and individual concernà ¢Ã¢â€š ¬Ã‚  to them. The cases of Plaumann[12] and Cordorniu[13] set a very difficult test for individual applicants, such as SFA, to show that they have been directly and individually concerned by a Decision. Plaumann was similar to the present situation in that the Decision was addressed to Germany, but a sole operator tried to challenge it. The Court held that to show individual concern the operator had to show that the Decision, à ¢Ã¢â€š ¬Ã…“affects them by reason of certain attributes which are peculiar to them or by reason of circumstances in which they are differentiated from all other persons and by virtue of these factors distinguishes them individuallyà ¢Ã¢â€š ¬Ã‚ ¦Ãƒ ¢Ã¢â€š ¬Ã‚ .[14] This is notoriously difficult to show because the applicant will be blocked from making a challenge if others are put in the same position as they are. In Plaumann, the court ruled that anyone could start ex porting clementines from Germany and would be affected in the same way as the applicant. This was the case whether or not there actually were other clementine exporters. The cases which have successfully shown individual concern are very specific to their facts and do not create general situations in which applicants will be successful. For example, in Toepfer[15] the applicant was successful because the decision related only to operators who applied for licenses on a particular day and Toepfer was the only one. No one could join this group as the day had passed. Similarly, in Bock[16] the Court ruled that, à ¢Ã¢â€š ¬Ã…“A decision is of individual concern to a person when the factual situation created by the decision differentiates him from all other persons and distinguishes him individually just as in the case of the person addressed.à ¢Ã¢â€š ¬Ã‚  The full difficulty is shown by Spijker Kwasten,[17] where it was shown that à ¢Ã¢â€š ¬Ã…“a decision addressed to certain Me mber Statesà ¢Ã¢â€š ¬Ã‚ ¦ is not of individual concern to the only importer of the products in question established in the member states to which the decision is addressed since it concerns the importer merely by virtue of his objective status as an importer in the same manner as any other trader who is, or might be in the future, in the same situation.à ¢Ã¢â€š ¬Ã‚  The applicant in Codorniu was successful in his challenge because even though many operators in the relevant field could be caught be the provision, he was set out from the crowd because he had a registered trade mark that was affected. However, while this case was hoped to mark a new approach by the ECJ in the field of individual concern, subsequent case law has shown that the Plaumann test is still being used to block challenges to decisions which might potentially have more than one person affected.[18] There has been a lot of scholarly criticism of this state of affairs and many have even argued that the Cou rtà ¢Ã¢â€š ¬Ã¢â€ž ¢s approach to individual concern is arbitrary and unjust.[19] However, in the absence of legislative action to change the law, it appears as if the Court is unwilling to step in here and make it simpler for applicants who have not been addressed by a decision to challenge that decision. This was concerned in the case of Greenpeace,[20] which came after Codorniu and showed that there had been no significant change in the Courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s position. One problem that has been identified with the strictness of Article 230(4) is that the Treaties supposedly establish à ¢Ã¢â€š ¬Ã…“a complete system of legal remedies and procedures designed to permit the Court of Justice to review the legality of measures adopted by the institutions,à ¢Ã¢â€š ¬Ã‚  and the Courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s approach to Article 230(4) goes against this goal.[21] To conclude therefore, the UK Government will be able to challenge the Decision on the ground that, firstly, they are the addressee of the Decision, and secondly, that they are a privileged applicant under Article 230. However, the SFA will find it very difficult to challenge the decision on the basis of the test for individual concern. The Decision has not been addressed to them. While they represent a few thousand sheep farmers, there are over 250,000 in the UK and the vast majority are not members of SFA. Also, not only sheep farmers but all livestock farmers will be equally affected by the Decision. Therefore, there is no way for the SFA to differentiate their position from that of all the other livestock farmers in the UK and therefore, they will not be able to show that they have been individually concerned by the Decision and will accordingly not be granted locus standi before the ECJ. Bibliography Biernat, E., The Locus Standi of Private Applicants under article 230(4) EC and the Principle of Judicial Protection in the European Community, Jean Monnet Working Paper 12/03, New York, 2003 Chalmers, P., Hadjiemmanuil, C., Monti, G., Tomkins, A., European Union Law, Text and Materials, (2006) Cambridge: Cambridge University Press Craig, P. De Burca, G., EU Law, Text, Cases and Materials, 3rd ed., (2002) Oxford: Oxford University Press Liisberg, J., Does the EU Charter of Fundamental Rights Threaten the Supremacy of Community Law? (2001) 38 CMLRev. 1171 Mancini Keeling, Democracy and the European Court of Justice, 57 (1994) MLR 175 Rasmussen, H., Why is article 173 interpreted against private plaintiffs? (1980) 5 ELRev 462 Usher, J., Direct and Individual Concern à ¢Ã¢â€š ¬Ã¢â‚¬Å" an effective remedy o a conventional solution, (2003) 23 ELRev 342 Case 26/62, N.V. Algemene Transporten Expeditie Onderneming van Gend en Loos v. Nederlandse Administratie der Belastingen [1965] ECR 1 Case 41/74, Van Duyn v. Home Office [1974] ECR 1337 Case 148/78, Pubblico Ministero v. Tullio Ratti [1979] ECR 1629 Case 14/83, Von Colson and Kamann v. Land Nor drhein-Westfalen [1984] ECR 1891 Case 25/62 Plaumann v. Commission [1963] ECR 95 Case C-309/89 Codorniu SA v. Commission, [1994] ECR I-1853 Cases 106-107/63 Toepfer v. Commission [1965] ECR 405 Case 62/70 Bock v. Commission [1971] ECR 897 Case 231/82 Spijker Kwasten v. Commission [1983] ECR 2559 Case T-585/93 Stichting Greenpeace Council (Greenpeace International) v. Commission, [1995] ECR II-220537 Case 6/64, Flaminio Costa v. ENEL [1964] ECR 585 Case C-6 9/90, Francovich and Bonifaci v Italy [1991] ECR I-5357 Footnotes [1] Case 26/62, N.V. Algemene Transporten Expeditie Onderneming van Gend en Loos v. Nederlandse Administratie der Belastingen [1965] ECR 1 [2] Case 6/64, Flaminio Costa v. ENEL [1964] ECR 585 [3] ibid. p. 593 [4] Case 41/74, Van Duyn v. Home Office [1974] ECR 1337 [5] Case 148/78, Pubblico Ministero v. Tullio Ratti [1979] ECR 1629 [6] Craig, P. De Burca, G., EU Law, Text, Cases and Materials, 3rd ed., (2002) Oxford: Oxford University Press [7] Case 14/83, Von Colson and Kamann v. Land Nordrhein-Westfalen [1984] ECR 1891 [8] Liisberg, J., Does the EU Charter of Fundamental Rights Threaten the Supremacy of Community Law? (2001) 38 CMLRev. 1171 [9] Case C-6 9/90, Francovich and Bonifaci v Italy [1991] ECR I-5357 [10] Chalmers, P., Hadjiemmanuil, C., Monti, G., Tomkins, A., European Union Law, Text and Materials, (2006) Cambridge: Cambridge University Press [11] supra. note 9 [12] Case 25/62 Plaumann v. Commission [1963] ECR 95 [13] Case C-309/89 Codorniu SA v. Commission, [1994] ECR I-1853 [14] supra. note 12, para. 107 [15] Cases 106-107/63 Toepfer v. Commission [1965] ECR 405 [16] Case 62/70 Bock v. Commission [1971] ECR 897 [17] Case 231/82 Spijker Kwasten v. Commission [1983] ECR 2559 [18] Mancini Keeling, Democracy and the European Court of Justice, 57 (1994) MLR 175 [19] Usher, J., Direct and Individual Concern à ¢Ã¢â€š ¬Ã¢â‚¬Å" an effective remedy o a conventional solution, (2003) 23 ELRev 342; Rasmussen, H., Why is article 173 interpreted against private plaintiffs? (1980) 5 ELRev 462 [20] Case T-585/93 Stichting Greenpeace Council (Greenpeace International) v. Commission, [1995] ECR II-220537 [21] Biernat, E., The Locus Standi of Private Applicants under article 230(4) EC and the Principle of Judicial Protection in the European Community, Jean Monnet Working Paper 12/03, New York, 2003