European Business Ideas - Institutions and Trade

Question: Examine about the Report on European Business for Ideas, Institutions and Trade? Answer: The ramifications of the global exchange and the parity of spendings to open economies, for example, the UK Essentialness of the worldwide exchange to one open monetary framework; UK Countries are commonly needy, which alludes they rely upon one another for supporting their riches. They require different countries to buy their transhipment to have assets to buy assets which are not framed in their country. Moreover it is all together that nations can pack in making a help or great and perceive that the provisions, which they dont have, may be presented from different countries that concentration in that gracefully. Countries have a lot of charges (military, compensation, wellbeing administrations and so forth) in addition to charges once in a while conceal all, so they expect acquiring to offset the shortage. Worldwide exchange essentially is one of the significant highlights of UK money related framework; it is key for UK so as to keep up its budgetary advancement and qualities and in the logically increasingly serious universal economy (Gandolfo, 2013).There are a few reasons that why global exchanges are so huge to UK business. Widens Markets and Horizons: In the event that one enterprise situated in United Kingdom, was to just exchange and sell their products locally, never pushing and advertising their made merchandise to clients in different countries, the state would totally restrict its imminent. They may consistently grow a steady exchange from the UK clients, anyway they couldn't be skilled to develop so far as, if the company exchanged through eight further nations (for e.g.).Thus this exchange is so noteworthy for ventures and the money related framework - it intensifies client figures, deals and traffic. Expenses of Product: Through exchanging further countries, the organization likewise discharge up itself to substandard expenses for creation. For e.g., the TV maker in US may discover that its product could be created for impressively less in the modern unit in Greece. That isn't simply sets aside the enterprises cash, anyway it helps the client as that TV may be sold in lesser cost. Furthermore, Greece's budgetary framework is helped, credits goes to that TV Company for paying their industrial facility to create its item. Materials: At the point when it wasn't planned for different countries, UK couldn't be skilled to get their hands on a few of the assets they have to make items which they use day by day - for the most part inside the food fabricating. Colder nations, like UK, depend on the more sultry countries for the natural products like mangoes or bananas, in addition to those more blazing countries dependent on the countries like UK for certain items like potatoes. Without the financial combination and global exchange of food ventures, all countries could have some insufficient decision. Significance of supreme bit of leeway, near favorable position, trade rates and the arrangements of exchange Supreme Advantage: A country has the supreme favorable position on it exchanging partners gave it is proficient to produce advantageous of a help or great with the comparable measure of capitals or the comparative measure of administrations and merchandise with lesser assets. The Absolute preferred position assesses the proficiency of different economies or makers. The producer which includes a lesser amount endeavors to fabricate stock should have the supreme preferred position while making that great. On worldwide exchange facing, it is really natural for one nation to include the total bit of leeway inside production over the further countries. The hypothetical United Provinces, Csonda, for e.g., has specialized strength in the production of gadgets, instruction, sundials, pocket watches, turnips, plumbing supplies and sodas to describe only a bit. Csonda can make strengthening of those products utilizing lesser assets than various different nations in this world, especially assessed to one progress ively speculative country, Republic of the Northwest Queoldiola. Relative Advantage: David Ricardo inside his speculation of the near expenses suggested that countries will moves and exchange administrations and product where they have the similar points of interest. It is easy to see that while countries have the total preferred position, there is some reward to exchange. By the by, what happens in the event that one country has the total preferred position on its exchanging partners the production of a no. of product? Exchange and specialization can in any case impact in their government assistance increases arranged from the exchange. The circumstance of the near bit of leeway had gigantic significance while coordinating worldwide business and exchange. The clogged economies that produce fake blockades to the business and exchange scarcely advantage by following such temporary strategies. It is one of the set up realities that by versatile trade and exchange this isn't feasible to grow the extent of the business in any human progress farther than what its advantag es can maintain. It can guide a few pieces of it into the ways where they would not have, or probably gone, best case scenario. Be that as it may, the capability of the utilization of constrained assets can't be unequivocal in this bogus way. In the budgetary framework which is basically determined by the ideological twists, thought isn't comfortable and political purposes abrogate financial practicality. The money related development is yielded for some further political purposes. In its energy to extend the confident money related framework, it diverts indispensable, inventive assets into organizations where it neither has the right expertise nor the efficient exertion to ensure efficient arrangement. It would have easily subcontracted the product made by such organizations from various nations that hold the similar points of interest Conversion scale: Trade rates take part in a significant job in the nation's phase of business, which is huge to basically each free market monetary framework in this world. For this, conversion scale is among the major watched inspected and authoritatively controlled money related measures. Notwithstanding, trade rates subject on the lesser degree also so they impact the genuine return of the financial specialist's arrangement. Here, a few of significant administrations are there behind the swapping scale exercises. An unrivaled cash creates a country's fares all the more exorbitant and imports cheap in the outside commercial centers; a substandard money delivers a country's fares in costly in addition to the imports all the more expensive in the remote commercial centers. A better conversion scale expected than subordinate the country's harmony of exchange, though a substandard swapping scale could expand it. Terms of exchanges: The proportion of assessing import esteems to send out qualities, terms of exchange essentially is associated with existing money related records and harmony of outgoings. While the expense of the countries sends out increments by the bigger rate than its imports, at that point its terms of exchange valuably have upgraded. Developing terms of exchange affirms unrivaled specify for the country's fares. This outcomes in expanding livelihoods from the fares, which gives intensified interest for country's money. On the off chance that the charges of fares increment by a lesser rate than the imports, the legitimate delicate's worth will reduce in comparative with the managing accomplices. Depict the development of equalization of the installments: Equalization of the Payments is fundamentally the proof of the countries managing rest of this world. This equalization of the installments contains: Current Account (exchange administrations, products + reserve funds wages + transmits) Capital Account (budgetary and capital streams, all out speculation, arrangement venture) Oversights and Errors: It is hard to assemble all data so a few are ignored. In theory there must be a bantering between current/budgetary and capital record. Just if there is one current record lack, there must be an overabundance on that money related/capital record. UK Current Account UK present record deficiencies were 20.7 billion inside Q3 2013, energetic from the change inconsistency of 6.2 billion inside Q2 2013. The deficiency inside Q3 2013 related to 5.1% of the GDP at present market costs, playful from 1.5% inside Q2 2013 In 2012, the UKs present record deficiencies were 59.8 billion. (Source: Willett and Laney, 2014 p-127). Instrument of the Current Account Arrangement in stock Arrangement in administrations Whole salary (venture pay) Entire current transmits UK present record from the Jan 2013: UK Deficit in Current Account Since 1980s, the UK for the most part had an insistent shortfall in current record. Basically, UK had been presenting a greater number of administrations and products than selling abroad. (source: Dustmann and Frattini, 2014, p-640) Purposes behind the Deficit in Current Account Exaggerated paces of trade. Countries in Euro zone that became non-serious (Spain, Greece and Portugal) rehearsed enormous current record deficiencies. It is a direct result of the exaggerated pace of trade that implies selling abroad are all the more exorbitant, anyway imports are economical. This convinces residential clients to buy imports. This likewise makes this intense for the exporters since they are nearly non-serious. High Customer Spending. While there is fast development in client spending, there inclines to be the enlarge in imports sourcing compounding in current record Lopsided Economy. The economy decided on client using as opposed to hypothesis and fares will incline toward having a more prominent shortfall in current record. Competitiveness.Associated with the pace of current record is all inclusive seriousness of the organizations. While there is any dismissal in near seriousness, for example raising pay costs, modern disturbance, poor prevalence products then this is harder over sell abroad causing debilitating in current record. Parts of UK shortage in current record Shortfall in stock: As the technique of de-motorization

Aspects of Sustainability Samples for Students †MyAssignmenthelp.com

Question: Talk about theAspects Principle of Sustainability. Answer: Lodging Truth be told, lodging speaks to a few ideas, for instance, character, security, and comfort and above all, it has noteworthy significance to everybodys nature of wellbeing existence with considerable individual, social, social and financial importance (Maller et al., 2012). Moreover, it is additionally a basic part in the monetary and social texture of the whole countries. Staggeringly, no country is yet placated that adequate haven has been given to the distinctive monetary gatherings that comprise its populace. Shockingly, harsh evaluations depict that there is more than 100 million vagrants and that around one billion people are inadequately housed all inclusive (Seyfang, 2010). In spite of the fact that they contain a fourth of the whole mankind, just a little bit dwells in the industrialized world. Obviously, creating countries are the greatest survivors of serious lodging issues. 33% of their whole people is destitute (Seyfang, 2010). The nature and purposes for those issues contrast from one nation to the next relying upon nearby political, monetary, and social structures. Actually, low-pay countries lodging issues are generally not quite the same as those felt in created nations, and further urban and rustic lodging additionally show their own odd incongruities. Truth be told, house building, making the basic unit of human settlement inside the developed biology is also a crucial part of social turn of events. For this situation, it serves the basic job of achieving reasonable turn of events (Legrand, 2012). Money related moderateness and ability to an individual have a quick effect of changing this prerequisite or need into a sensible reality. Significantly, innovation fills in as an impetus to help with accomplishing this by offering reasonable choices fitting individual needs and dynamic conditions, along with finishing present necessities, the desires and needs of people in the future being borne at the top of the priority list (Bolay et al., 2014).). Along these lines, the basic of lodgings manageability comes in this milieu. Measured all inclusive, lodging is associated with around 25% of the ozone depleting substance discharges spoke to in family purchases and 26% of the land utilization of families (Seyfang, 2010). Truth be told, manageable homes are developed using economical materials, techniques, and empower green works on, encouraging a progressively environmental way of life. Their support and development have unbiased consequences for the planet. Habitually, if fitting, they are constructed near imperative administrations, for instance, open travel, work, supermarkets, day cares, and schools allowing them to commit to viable vehicle alternatives (Dempsey et al., 2009). Infrequently, they are off-the-matrix houses that never request any open sewer administration, water or vitality. When not off-the-framework, viable homes may be associated with a network gave by a force plant which is using manageable force sources, buying power similar to a standard goals (Maller et al., 2012). Besides, reasonable homes may be connected to a system, yet may deliver their own capacity through sustainable techniques and deal any leftover portion to an organization. Twofold metering and net metering are the commonest techniques for moving toward that alternative. Indeed, net metering uses the ordinary meter which is fixed in numerous homes, running forward when current is used from the framework, going in reverse when the voltage is placed in the network (Shaeffer, McKibben, 2015). That empowers them to use their all out vitality use, placing remaining vitality in the network when not required, and expending power from the matrix during times of heavy traffic, when it may be difficult to create adequate vitality right away. Then again, twofold metering involves interfacing two meters: one evaluating utilized power while the other one estimates power created (Shaeffer, McKibben, 2015). Furthermore, as opposed to retailing their sustainable power source, proprietors of supportable homes may select to bank their excess power by using it to reload batteries. This offers the decision of utilizing that vitality a while later during horrible force delivering minutes, for instance, evening, when the breeze is inaccessible, and in this way become alto gether independent of the electrical system. On the opposite side, supportable houses are assembled utilizing tolerable structure materials (Dempsey et al., 2009). Truth be told, some structure materials may be respected viable by certain clarifications and under certain circumstances. For example, wood may be viewed as viable when it gets developed using biological backwoods the executives, handled using viable vitality, and moved utilizing economical vehicle. Obviously, protecting a viable home is basic as the vitality get saved all through the homes lifetime (Bolay et al., 2014). Very much secluded lofts and dividers utilizing green materials are an unquestionable requirement since it diminishes or, in amalgamation with a house which is all around structured, kills the interest for cooling and warming through and through. Protection establishment differs as per the sort of protection under use. Typically, lofts are sequestered by slivers of protecting material laid between supports. Another significant component in protection is introducing vitality effective windows (Sheuya et al., 2010). Basically, guaranteeing that entryways and windows are pleasantly fixed amazingly reduces the loss of vitality in a house. The other inclination for window protection is utilizing low-E glass or low-emissivity windows. It is a covering on window sheets of a slight, translucent covering of metal oxide, and perform by reflecting warmth back to its beginning, keeping up warmness inside during winter, and coolness during summer. Vitality Truth be told, vitality is firmly associated with the three sizes of feasible turn of events: social, natural and monetary (Sustainable Service, 2013). Clearly, vitality sources are fundamental to social and monetary turn of events. To add voice to this proceeding with improvement, the significant issue inside the vitality part is controlling the usage of common vitality assets (Sustainable Service, 2013). Unquestionably, a framework must be built up for improved similarity with contemporary ways of life with conservation of vitality assets for tomorrow's ages. Vitality remains the main thrust of present-day human progress. Truth be told, vitality administrations are critical to human government assistance and removes a portion of fortifying social soundness on account of the nonstop increment in expectations for everyday comforts (The World Conservation Union, 2013). The conclusive factor to flourishing and improvement among the financial players is vitality. In spite of the vitality level requests of todays economies being gradually declining, tremendous measures of energies would be requested to improve states of living in third world economies (Sustainable Service, 2013). Truth be told, the vitality division itself occupies a fundamental spot in the worldwide economy in exchange, salary, and business terms. Every country on earth seems to see the USs expectation for everyday comforts toward the start of 21st century as the best target. The strategy for achieving that goal is determined by a simple condition. The condition offers an interesting delineation: the United States (including 5% of the earths masses) utilizes 25% of the planets oil creation (The World Conservation Union (Iucn), Unep, Wwf. 2013). For this situation, a lion's share of masters agree that, at the current utilization rates, inside the following 50 years, oil stores will be exhausted (The World Conservation Union (Iucn), Unep, Wwf. 2013). Along these lines, clearly the USs advancement model, whereupon the European model is fabricated, can't be utilized on a worldwide scale. Consequently, vitality squandering rehearses should be subbed by a viable advancement model. The power request control entangles a lot of strategies and advances that focus to advance the buyers vitality use (Ahmed, 2013). This ought to be accomplished while confining open foundation consumption and the outcomes on the environs. This control involves a few decisions and activities. Hardware ought to have the best practical exhibition (proficient apparatuses, and low-vitality lights among others) (Shaeffer, McKibben, 2015). Critically, it is attractive to choose gadgets which can control the bought in vitality request on the matrix (software engineers, power controllers). We ought to likewise endeavor to substitute mains power used for warm applications (high temp water, warming) with vitality gotten from inexhaustible sources. Indeed, practical advancement is upgraded by expanding sustainable power sources (Maller et al, 2012). Supportable vitality is significantly offered by the tides, the plant's development, the breeze, the sun, the warmth of the earth, and cascades, and it creates pretty much nothing or zero waste or dirtying releases. By using those viable assets, we protect the non-renewable energy sources of the planet, for instance, oil and petroleum gas, the provisions of which are normally deficient and would unavoidably run out. Be that as it may, the specialized and logical advancement has fuelled the creation and utilization of sustainable power sources, consequently satisfying a major bit of the present vitality needs of the populace, outside the vehicle segment (Shaeffer, McKibben, 2015). To control more vitality use during lighting, LED lights have been given as probably the best alternative (Legrand, 2012). The lights are end up being sound neighborly, efficient, biological and obviously are expanding getting moderate. End Living reasonably is tied in with living inside the methods for our characteristic frameworks or condition and guaranteeing that our way of life doesn't hurt our general public and culture. Thusly, this paper has talked about two parts of reasonable living in particular; lodging and vitality and it have additionally investigated applicable developments for guaranteeing supportability. No country is yet mollified that adequate haven has been given to the differe

Essay on College Admission Requirements

Essay on College Admission Requirements College Admission Requirements Dec 19, 2019 in Education Introduction Many high school students apply to colleges every year. It is a complex, multilevel, and, at times, controversial process. College admissions involve multiple steps, and take a considerable amount of time. The major elements of the process are making choices, writing an essay, paying fees, visiting college, and passing interviews. Students prepare separate applications to every college. Though, the Common Application may sometimes expedite the process. Overall, the main controversy is that there are many requirements that may differ from college to college. Thus, a high school student should carefully study all standards and requirements of colleges he wants to apply to. In any case, it should be admitted that the complexity of the process and its elements is justified, as it works and preserves the general order of admission for all high school students. Body In recent years, students have started to apply to colleges earlier than the common deadline on the 1st of January, while the regular admission remains a widespread phenomenon. It is easier for institutions to process all data, if they have more time. Foreigners and minor applicants are usually the ones who choose this route. Some people think that the main controversy is that students are unable to compare competing aid packages from various colleges. Yet, students and parents may ask about the expected costs before applying. Thus, the aforementioned downside can be mitigated to some extent. At the same time, I agree that early admission is beneficial to wealthy families, as they do not have to compare financial aid offers. Additionally, early decision benefits colleges, as it almost guarantees that an applicant will attend. Thus, it helps college to improve its ratings. The other tool a student should use is an early action. It is similar to early decision, but it is not binding. T hus, a student can apply to multiple colleges. Moreover, there is a belief that early action is perfect for the students who have already decided where they want to apply to. Talking about regular admission, it is considered that it would be the best choice for the students who are not sure where they want to apply to. The main advantage of this way is that students are able to improve their grades during the fall of the senior year. Additionally, they have more time to make the decision about the college they want to enter. Yet, the best advantage is that regular admission results in higher offers of financial aid. It is a good subsidiary mechanism that simplifies the financial side of the process for many American families. Order now Live Chat One of the main college admission requirements is obviously the passing of a certain test. Most of the colleges accept either the ACT or SAT test. They have formulas that help to convert scores into admissions criteria. The main controversy about passing tests is that there have been examples of people passing the tests instead of the real students (Dominus). The phenomenon is illegal, but it remains a common practice. The other downside is that many students decide to take the test for the second time in order to improve their scores. Thus, they may become score obsessed. This is why many specialists advice passing tests only once, or maximum two times. The other issue is that the tests are often criticized for being ineffective in predicting life success. People tend to pay too much attention to the score, as if the result of the test determines who the person will be in his or her future. On the positive side, both SAT and ACT tests are equivalent and seem to bring similar results . Moreover, each test is equally accepted by colleges. The only point that should be mentioned is the slight difference in the structure of the tests that may benefit one of the test-takers. For instance, there is no penalty for wrong answer in ACT test, so a student can guess the answer while the time remains. At the same time, incorrect guessing is penalized on the SAT test. It makes SAT test more important in evaluating applicants. Some admissions officers consider the test to be a better indicator of academic ability. In any case, it should not be considered that the previously mentioned difference to have a great impact on the test results. A student cannot guess all the answers. This is why the issue should not be viewed as a major one. College admissions essays provoke different opinions. They are considered to be less important than high school grades and test scores. Yet, I believe that an essay can make a difference in certain circumstances. The essays may be a primary index of a students character. The student should be guided not by the quantity, but by the quality. The standard length of the college admissions essay is considered to be 500 words. A bigger essay may be irritating, and show that a student cannot qualitatively shape his or her thought. There is an opinion that the essay should be honest, concise, accurate, and cohering, while revealing a smart and likeable individual. A student may use humor and touch controversial topics in a balanced way. The main goal is to show social conscience, maturity, inclusiveness, and tolerance. Writing college admissions essay may be a controversial element in the admissions process, as it does not regard the precise knowledge that a student should show in SAT or ACT tests. Yet, everything can be blamed as prejudiced. In any case, it should be mentioned that the college admissions essay shows the students ability to think and analyze better than all the other college requirements Another major requirement in admissions process is passing an interview. Overall, interviews are considered to be less important than college admissions essays, but they should be done, if that is a requirement of the college. If a student decides not to go to such an interview, it may be detrimental to his or her chances for admission. I believe that it is the most important requirement that colleges have. The grades are not the only indicators of the students prospects. The interview allows a person to show the positive sides of his or her character and its strengths. Such qualities cannot always be seen in the admissions tests. Additionally, the interview helps to show the students desire to enter a precise college. An applicant may say something specific about the college, or a subject, or a professor who teaches there. Thus, it will show the students sincere interest and may improve his or her rating. Conclusion In conclusion, college admission is a complex, multilevel, and, at times, controversial process. It involves multiple steps, and takes a considerable amount of time. Thus, there are several college admission requirements that a high school student should accomplish. One of the first requirements is the process of applying. A student may choose an early admission, early decision, or regular admission. The other requirement is passing the ACT or SAT test. Having passed the test, the student may be asked to come for an interview, or write a college admissions essay. All previously mentioned requirements may provoke some controversy, but they mainly depend on the students punctuality and awareness. It depends on the high school student, whether he or she decides to carefully study all the standards and requirements of colleges, or decides to put it to chance. Eventually, it should be said that the complexity of the process and its elements is justified. The versatility of the requirement s preserves the general order of admissions for all high school students.

The Marxist Theory Is The Political And Economic Theories...

The Marxist theory is the political and economic theories originated by German theorists: Karl Marx and Friedrich Engels. Marx was born in Germany in 1818 and studied philosophy and law. He was among many the most important authors of sociology and was best known as the â€Å"father of Marxism† (McIntyre, 21). Along with Friedrich Engels, he wrote and published The Communist Manifesto. This document helped shape the revolutions that reconstructed much of the world with over the course of the next century. According to Marx the most important thing about society is the way a society is organized to produce goods and services, also known as mode of production. The relationships among people and people’s relationships to the forces of production are how decisions were made about what to do with the outcomes. The Marxist theory recognizes several typical modes of production and characteristics of different periods in our past history (McIntyre, pg28) These modes of produc tion includes: â€Å"Primitive communism† which had no categorized social class structures or capital growth, â€Å"Asiatic mode† which is allegedly the original form of society where small groups removes social additions through violence directed at settled or unsettled band groups within a domain. â€Å"Ancient mode† is when property is the control of the individual, the forces of production connected with this mode is the widespread use of animals in agriculture, and advanced trade networks.† Feudalism† the property is theShow MoreRelatedRevisionist Socialism1088 Words   |  5 Pagesjustice in the sense of narrowing the economic and social inequalities (to varying degrees) within capitalism through welfare and redistribution. Social democracy is the most obvious example of revisionist socialism. 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The Sirens Episode in The Odyssey - Free Essay Example

Sample details Pages: 3 Words: 864 Downloads: 8 Date added: 2019/04/01 Category Literature Essay Level High school Tags: Odyssey Essay Did you like this example? The Sirens Episode in The Odyssey Itis hard to imagine what it would feel like when one is unexpectedly enchanted and persuaded to commit suicide. This is what would exactly happen when one met the Sirens, Greek fairy-tale beings believed to have the power to hypnotize and fascinate those who listened to their songs. The Sirens greatly influenced the life of Odysseus in Homers The Odyssey. Don’t waste time! Our writers will create an original "The Sirens Episode in The Odyssey" essay for you Create order On his return to Circes island, Odysseus is cautioned of these beings and advised to avoid them since they are dangerous (Odyssey 12.53-58). The main lesson learnt from the recount is the importance of heeding to advice so as to avoid temptations in life. Odysseus learns of the impending danger posed by the Sirens and listens to the instructions given by Circe by explaining to his men (12.170-79). The goddess tells Odysseus that he alone should listen to the voices of the Sirens, despite the fact that this could result to him losing his life. This presents a dilemma in that he either disobeys the goddess to avoid risking his life or follow Circes instructions and be lured to his death with the Sirens beautiful voices. Another obstacle evident from the recount is how Odysseus will handle the weight of responsibility bestowed unto him to ensure that his men reach their destination safely. He handles this by putting beeswax in each mans ears to block out the charming songs of the Greek mythical beings (12.189-93). Because Odysseus is the only one meant to listen to the Sirens beautiful voices, he faces the danger of being enticed to his death. However, he and his men overcome this by adhering to the advice issued by the goddess. Odysseus men tie him up along a mast to prevent him from going towards the Sirens voices. When he listens to their voices, desire creeps in him and he asks to be untied. He faces the obstacle to give in to his desires and temptations. However, his men remember the instructions given to them and Perimedes and Eurylochus tighten the lines that tied Odysseus to the mast (12.216). Their loyalty and obedience prove vital as they play an integral role in preventing their friend from succumbing to the enchanting but dangerous voices. The episode on Odysseus encounter with the Sirens shows the valiant characteristics in this episode. Obedience is the first virtue that proved important in this encounter. Odysseus obeys the instructions given to him by Circe. He puts his trust in those instructions and doesnt question them. His men are also obedient because they adhere to those guidelines by ignoring the Sirens attractive singings and tying Odysseus up to a mast. Courage is another virtue appreciated in this episode. Odysseus is courageous enough to put his life on the line by agreeing to listen to the Sirens voices despite being aware of the risk posed by doing so. The Sirens voices entrance him but his friends tighten the roles so that he doesnt get loose. Loyalty is another heroic characteristic evident from this episode. Odysseus companions show their devotion and trust by following his instructions. They also trust that Odysseus tactic of covering their ears with wax will block out the Sirens singings. Most importantly, they ignore Odysseus plea to be united so as to follow the charming voices but instead tighten and pass more lines so as to keep him safe. Springing up at once to bind me faster with rope on chafing rope. (12.215-216)There are various important lessons learnt from the Sirens episode. The first one is the significance of having loyal and caring friends in life. This is evident from the episode as Odysseus friends make sure that he doesnt give in to the charm in the Sirens beautiful voices. Furthermore, being courageous is also significant since Odysseus agrees to listen to the singings in spite of being aware of the consequence of paying attention to them. Linguistic styles have been employed in this episode. Firstly, Homers use of the idiomatic phrase sore at heart illustrates the feeling of despair Odysseus experiences when sharing the given directives with his men. Furthermore, Homer metaphorically refers to the Sirens voices to being honeyed. This shows that their voices are lovely and appealing to listen to that no one can resist them. The phrase the heart inside me throbbed me to listen longer depicts the desire Odysseus had to continue listening to the Sirens voices since they were praising him and this pleased him for he was being recognized and acknowledged. The episode on the Sirens heighten the importance of the other Odyssey episodes since it illustrates mans desires that cannot be gotten. The Sirens are a sign of mans enlightenment. They are the desires that man should avoid so as to stay safe during their endeavors. From the episode, it is right to conclude that Odysseus was courageous enough to protect his men from the Sirens by putting himself at risk. Furthermore, the loyalty showed by his companions was crucial in keeping him away from the Sirens enchanting voices. The episode gives an example of the many challenges that Odysseus and his men must overcome in order to reach home safely.

British Literature Paper Free Essays

Michael Sharp British Literature I 09/26/07 Angelina Jolie has a place in Hell According to Dante, Hell is broken down into nine circles. Each circle would represent a punishment according to their sin and would be more evil as you draw near towards the last circle. If Dante were to travel in Hell again, he would most likely encounter Angelina Jolie. We will write a custom essay sample on British Literature Paper or any similar topic only for you Order Now Although she is looked upon as a celebrity with a humanitarian heart, the sins that she have committed would not be acceptable in God’s eyes. Despite her humanitarian heart, she is likely to go to hell. Despite Angelina Jolie’s humanitarian heart, she is a non-Christian. Non-Christians are automatically condemned to hell. It is stated in the bible, â€Å"†For God so loved the world that he gave his one and only Son, that whoever believes in him shall not perish but have eternal life† (John 3:16). The bible strictly states that if you do not believe in Jesus Christ, you will not go to heaven. It is through God’s grace that we are entitled to enter heaven. When Dante traveled through the first circle of hell, he noted that it housed all the pagans. Great writers and poets were condemned in the first circle because they had died not knowing Christ. You don’t ask,† my good Teacher said to me, â€Å"who are these souls you look upon? Before you go on in your journey, you must know they did not sin. If they had bad merits, these were not enough- baptism they did not have, the one gate to the faith which you believe† (35). Although those people did not commit a serious sin, they did not believe in Christ. Therefore th ey were condemned to the first circle of hell. This is one of the few circles in Hell, where should would be condemned. Lust is one of the many sins people struggle with and it often leads to committing adultery. Angelina Jolie is one of the many who had committed adultery. She seduced Brad Pitt away from his wife Jennifer Aniston and later marries him. In the bible it quotes, â€Å"Whosoever shall put away his wife, saving for the cause of fornication, causeth her to commit adultery. And whosoever marry her that is divorced, committeth adultery† (Matthew 5:32). The bible also states clearly that this sin is not looked upon lightly. In fact in Ephesians 5:5 reads, â€Å"For of this you can be sure: No immoral, impure or greedy person such a man is an idolater has any inheritance in the kingdom of Christ and of God. Marriage is highly regarded in the Christian faith; it is a sacred covenant that is established between the man and his wife. Committing adultery would be a violation of that sacred covenant that was established between husband and wife. In Dante Inferno, Dante describes how he and Virgil pass into the second circle. It was illustrated as a dark area where the rain would co ntinuously fall and the wind would blow constantly. The condemned would helplessly swirl in the wind and be swept through the storm. One of the characters that Dante pointed out was Semiramis. She was allegedly an Assyrian queen who created incest a legal practice. Angelina Jolie did not only commit adultery but she also had an incestuous relationship with her brother. According to the bible it states, â€Å"Do not have sexual relations with your sister, either your father’s daughter or your mother’s daughter, whether she was born in the same home or elsewhere† (Leviticus 18:9). The bible strictly forbids any family members to have a sexual relationship with one another. According to the laws from the Old Testament they would execute those who were guilty from committing this sin. In the New Testament, the local church would be given the authority to outcast the guilty for the offence. In the Second Zone of the Seventh Circle’s Third Ring, Dante encounters Bruetto Latini. This is where the Sodomites must walk continuously under the rain of fire. Bruetto Latini was noted for providing Dante with kindness and counsel, yet he accuses him for being a homosexual. During this time period, homosexuality was evident but not acceptable to the society. However in today’s society homosexuality is acceptable. Angelina Jolie publicly admitted that she had feelings for woman and would consider dating some of either gender. Her guilty pleasure in the same sex would earn her a spot in the third ring. Although Angelina Jolie has committed more than one serious sin, she would be condemned into the second circle of Hell. Lust has overwhelmingly affected her life and to God’s eyes it looked down upon with disgrace. She has violated the sacred commitment between husband and wife by sleeping with another wife’s husband. She has been divorced and became pregnant before marriage. All of these factors are more than enough reasons as to why she should be condemned to Hell. Bibliography Alighieri, Dante. Dante Inferno. New York: Esolen, 2003. Angelina Jolie. Ed. Mai Dinh, Janet Murphy. 25 September 2007. http://www. people. om/people/angelina_jolie/biography/0,,20004347_0,00. html Adultery. www. biblegateway. com. Ed. Nick Hengeveld. 25 September 2007. http://www. biblegateway. com/quicksearch/? quicksearch=adulteryx=0y=0 John 3:16. www. biblegateway. com. Ed. Nick Hengeveld. 25 September 2007. http://www. biblegateway. com/passage/? search=john%203:16version=31 Incest. www. biblegateway. com. Ed. Nick Hengeveld. 25 September 2007. http://www. biblegateway. com/quicksearch/? quicksearch=incestx=0y=0 homosexual. www. biblegateway. com. Ed. Nick Hengeveld. 25 September 2007. http://www. biblegateway. com/quicksearch/? quicksearch=homosexualx=0y=0 How to cite British Literature Paper, Essays

Marketing Practice for Mediums and Innovative - myassignmenthelp

Question: Discuss about theMarketing Practice for Mediums and Innovative Technology. Answer: Introduction The occurrence of new and innovative media has posed a severe challenge for the conventional media. There has been imposed a negative impact upon the various conventional medias such as print newspaper, etc. But it is seen that the impact of the new and digitalized media upon the conventional media is still somehow manageable. The advertising agencies are still investing and taking use of the conventional media as a source for attracting the customers. The advertising agencies are facing huge struggle in moving away from these conventional and old media to electronic media so that there can be acquired strong access to the people of Generation Y (Asur, et al., 2011). The paper will present the various probable reasons because of which the advertising agencies have remained unsuccessful in fetching more number of customers with these new mediums and innovative technology. Positive and negative aspects of new technology and ineffective outcomes gained by advertising agencies with the use of the new media channels In the present time, the potential customers are primarily the Generation Y people who have an easy access to all the new and innovative media, electronic media and advanced media channels. These individuals have a tendency to buy products and services which have high visibility at various electronic and digital media channels rather than just having a visibility on old media channels. Thus, to have an easy access to such customers, the companies are required to have a strong and vibrant presence on all such media channels (Zhao and Jiang, 2011). To attain the objective of increased sales and higher customer base, the advertising agencies have taken use these new technologies and electronic as well as digital media channels. But from the overall perspectives and analysis, there has been analyzed that these media channels have not turned put be effective and successful for the companies and their products and services in comparison with the conventional media channels (Granka, 2010). There has been identified both positive as well as negative aspects of the new technologies and digital media channels which impacts the potential number of customers. Firstly highlighting and evaluating the positive considerations of these media channels, it can be realized as the advertising agencies can have an extended and global reach to the customers in various other nations with these new technological Medias (Salman, et al., 2011). There is probability that if the customers develop reliability with the brand than there are chances that the products and services can be globally recognized. In respect with the capital investments and expenditure, the new ad techno savvy media channels are much affordable and are pocket friendly for all types of business ventures whether small, medium or large scale. Thus, there has been an equal platform to all the companies in respect with social presence and fetching the attention of the potential buyers (Howard and Hussain, 2011). But analyzing from the negative perspectives, there are comparatively several weaknesses and loop holes because of which the advertising agencies have not gained much success and effective customer network with the use of these new mediums with updated technology. The key negative aspect is that the social media platforms are not a proper source for having higher number of customers because of the fact that those social networking sites such as Twitter, Facebook, etc. have both the negative as well as the positive review about the products and services which directly impact the future growth of the business. By taking glimpse from negative reviews and comments, the buyers change their decision of making a purchase as they try to judge the products with these reviews. But on the other hand, if the products or services are good but still if there are negative reviews then there is a very high probability that the individual will not buy those goods or services (Meraz, 2011). The big difference among both these medias are that the traditional or the conventional media still have a strong presence and are more powerful in fetching the attention of the customers and masses. These media channels are positive in respect with the advertising agencies as only the advertisements and promotional campaigns are displayed rather than the negative elements in terms of reviews and comments by the consumers. Thus, in a broader sense only a good picture of the products and services are displayed to the potential users and this leads to increase number of sales and revenues (Shah, 2011). The new technology and electronic and digital media are successful for new ventures where there is a need to have higher presence in terms of visibility and have less capital investments. But in respect with giant players and with higher capital investments the conventional media channels are much effective and dominating for influencing the various customer segments. The media channels such as newspapers, radio and posters are those conventional media channels that have been negatively impacted by the rise of the digital and electronic Medias as they electronic and digital media has offered the online platforms to the companies for advertising their products and services. Thus, such media channels are much impacted by the rise of digital media but not all conventional media channels (Kaplan and Haenlein, 2010). With number of positive aspects of the electronic and online media channels, it is still believed that the advertisers still have a faith and association with the traditional media sources such as television. There are several modifications and changes that have occurred in television media such as over the past few years, there are innovative dimensions for instance the highly interactive televisions which are one of the key advertising mediums for the advertising agencies (Stephen and Galak, 2012). The conventional association among the broadcasters and the advertisers have been completely changed because of the interactive television, since there has been paid a particular amount by the advertisers for the particular length of the advertisements in-between the various programs but, the occurrence of the interactive television, it is the choice of the consumers what they are liked to view at a particular point of time and this has given rise to a new paradigm (O'Connor, 2012). The authors and researchers have argued and analyzed that rather than advertising dependency on only one of the media i.e. conventional or electronic, it is advisable that there must be taken use of an integration approach by the advertisers by taking use of both the conventional media channels such as television with have a decent consideration to the other digital channels too such as social networking sites, emails, etc. The integration of the both the media channels will result in a better combination for the advertising agencies to have an increased global presence, extended customer base and effective use of both the media channels. As well as the integration process will help the advertisers to have a touch with both the people of generation X as well as Generation Y so that they do not loss the connection from either of the two customer groups as well as have an upsurge customer base. Thus, the new trend of integration of the traditional media with new media has presented sev eral new opportunities for the advertising agencies as well as for the consumers as a whole (Peng and Zhu, 2011). Conclusion The new and electronic media offers vast opportunities to the advertising agencies and the companies to have a vast customer base and strong global presence. These media channels are affordable, innovative, inexpensive and extended reach. Thus, the advertisers prefer advertising their products and services on these electronic media channels. But from the overall analysis, it has been concluded that the success offered by the traditional media is much more than these electronic and digital media channels. The social networking sites are effective in offering little success only in comparison with the conventional media as they have both negative as well as positive reviews and comments by the users which can impact the future sales of these products and services. Thus, it can be concluded that rather taking use of either conventional or electronic media alone, the advertisers must have their emphasis on their integration and combine use of these platforms for effective advertising and gathering attention of increased number of masses. References Asur, S., Huberman, B.A., Szabo, G. and Wang, C., 2011, July. Trends in social media: Persistence and decay. InICWSM. Granka, L.A., 2010. Measuring agenda setting with online search traffic: Influences of online and traditional media. Howard, P.N. and Hussain, M.M., 2011. The role of digital media.Journal of democracy,22(3), pp.35-48. Kaplan, A.M. and Haenlein, M., 2010. Users of the world, unite! The challenges and opportunities of Social Media.Business horizons,53(1), pp.59-68. Meraz, S., 2011. The fight for how to think: Traditional media, social networks, and issue interpretation.Journalism,12(1), pp.107-127. O'Connor, R., 2012.Friends, followers and the future: How social media are changing politics, threatening big brands, and killing traditional media. City Lights Books. Peng, T.Q. and Zhu, J.J., 2011. A game of win-win or win-lose? Revisiting the internets influence on sociability and use of traditional media.new media society,13(4), pp.568-586. Salman, A., Ibrahim, F., Abdullah, M.Y.H., Mustaffa, N. and Mahbob, M.H., 2011. The impact of new media on traditional mainstream mass media.The Innovation Journal: The Public Sector Innovation Journal,16(3), pp.1-11. Shah, H., 2011.The production of modernization: Daniel Lerner, mass media, and the passing of traditional society. Temple University Press. Stephen, A.T. and Galak, J., 2012. The effects of traditional and social earned media on sales: A study of a microlending marketplace.Journal of Marketing Research,49(5), pp.624-639. Zhao, X. and Jiang, J., 2011. An empirical comparison of topics in twitter and traditional media.Singapore Management University School of Information Systems Technical paper series. Retrieved November,10, p.2011.

Health Policy and Law

In public health and health care sectors, law and health policies play critical roles in controlling illnesses and reducing deaths. Therefore, it is important to include them in study of health care and public health. It is important for future healthcare and public health practitioners to understand the scope and influence of law in their field of practice (Andre, 2002). Public health law focuses on role of government in improvement of health at various levels of society.Advertising We will write a custom essay sample on Health Policy and Law specifically for you for only $16.05 $11/page Learn More In addition, it deals with legal issues experienced in public health practice, as well as effects on health of people (Andre, 2002). Policies and laws that aim to reduce diseases and injuries, as well as promote provision of quality health care services to people govern the health care and public health sectors. Therefore, they aid future practitioners in und erstanding how law and policy affects their work, as well as their role in implementing their requirements (Andre, 2002). Bioethics refers to study of ethics initiated by advancements in medicine and biology (Andre, 2002). In addition, it refers to process of making decisions in relation to health care policy and practice. It deals with ethical questions that arise from implementation of health care policies. Bioethics is an important component that shapes and determines establishment of health policies. Many issues arise from developments in the medical field and health care sector. The issues have varying bioethical implications on health policy, as they affect the well-being of communities (Andre, 2002). In addition, development of health policy generates ethical issues that affect delivery of health care services. On the other hand, bioethics deals with ethical implications of public policy as it relates to delivery of health care services (Andre, 2002). The health care sector h as many controversies mainly caused and resolved using health policies. Such controversies include abortion, euthanasia, physician-assisted suicide, patient self-determination, and role of practitioners in safeguarding patients’ privacy of medical information. Bioethics covers controversial issues related to establishment and implementation of health policy (Andre, 2002). Decisions related to health law and policy affect interests of many stakeholders. Stakeholders such as employers, the public, healthcare providers, pharmaceutical companies, and researchers have different interests in health law and policy (Teitelbaum Wilensky, 2013). Therefore, changes in health law and policy affect their interests significantly. Choices regarding certain policies and passage or interpretation of certain laws affect interests of stakeholders immensely. For example, a court of law could make a ruling regarding requirements of physician licensing and associated duties of physicians to patie nts (Teitelbaum Wilensky, 2013).Advertising Looking for essay on health law? Let's see if we can help you! Get your first paper with 15% OFF Learn More The court could rule that a medical practitioner is at will to either treat patient or decline to treat a patient despite the fact that he/she was acting as the doctor of the patient’s family. This ruling would affect many stakeholders. It would affect the patient, the family of the patient, and other medical practitioners (Teitelbaum Wilensky, 2013). It would also affect legislation of the state because the law on licensing could have been ambiguous and therefore in need of amendment. Another stakeholder that would be affected is the public. If such law were passed, it would affect all decisions related to health care and public health. Policy choices or passage and interpretation of law affect the interests of many stakeholders. In the foregoing example, affected stakeholders include the public, health care p roviders, patients, and the government (Teitelbaum Wilensky, 2013). References Andre, J. (2002). Bioethics as Practice. New York: University of North Carolina Press. Teitelbaum, J., Wilensky, S. (2013). Essentials of Health Policy and Law. New York: Jones Bartlett Publishers. This essay on Health Policy and Law was written and submitted by user GorillaMan 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.

Addendum on Used To vs. Use To

Addendum on Used To vs. Use To Addendum on Used To vs. Use To Addendum on Used To vs. Use To By Maeve Maddox It sometimes happens that I write a post that I think is beautifully focused on one point of usage, and then I receive a slew of emails faulting me for misrepresenting the topic. That’s what happened with a post on the modal use of used and use to express habitual action in the past. When an article receives this kind of response, I have to assume that my intended explanation wasn’t as clear as I thought it was. The post was based on the following question from a reader: Which is correct    He USED to go to the game on Friday. He USE to go to the game on Friday. All I intended to point out in my answer was that used is the correct choice for the examples given, but that use is correct when it follows the negative didn’t. What I said was, When the statement is positive, as in the reader’s example, the expression is used to. In negative statements, the expression is use to. For example, â€Å"He didn’t use to go to the game on Friday.† One reader correctly commented, â€Å"The distinction is not really about positivity/negativity,† and offered the following sentences as evidence: He did use to go to the game on Friday. He never used to go to the game on Friday. The first example is correct as a contradictory statement. For example: Person A: He didn’t use to go to the game on Friday. Person B: He did use to go to the game on Friday. The second example contains the negative adverb never, but used is still the correct form. Any adverb, negative or otherwise, may modify the modal used: never used to go always used to go rarely used to go I apologize for my sweeping statements about positive and negative. Another reader asks, Can we say â€Å"usednt to† instead of  Ã¢â‚¬Å"didn’t  use to†? It depends. If you live in the UK or some other place where this expression is common, go ahead and use it. If you say it to an American speaker, you’re likely to get a puzzled look. For British speakers, here’s what it says about the different forms in The Penguin Writer’s Manual: The strictly correct negative form of used to is used not to, which can be shortened to usedn’t to: â€Å"You used not to (or usedn’t to) mind if we came in a little late.† This often sounds rather formal, so that did not use to or didn’t use to (but not didn’t used to) are generally acceptable in informal speech or writing. Likewise, the traditionally correct negative question form used you not to..? or usedn’t you to..? is often replaced, more informally, by didn’t you use to..? If neither of these options seems acceptable, you used to, didn’t you? can be used. Another reader demands, What is your authority for this? My usual authorities are the OED, Merriam-Webster Unabridged Dictionary, and The Chicago Manual of Style. This time, however, I relied for the most part on British and American grammar sites that target English learners. BBC: When talking about things that we did in the past but dont do now we can use the expression  used to. The negative form, to talk about things which we didnt do in the past but do now, is  didnt use to.   Oxford Learner’s Dictionaries: Except in negatives and questions, the correct form is used to: â€Å"I used to go there every Saturday.† To form questions, use did: Did she use to have long hair? The negative form is usually didn’t use to, but in British English this is quite informal and is not usually used in writing. English Stack Exchange: Except in negatives and questions, the correct form is used to: â€Å"we used to go to the movies all the time† (not we use to go to the movies). However, in negatives and questions using the auxiliary verb do, the correct form is use to: â€Å"I didn’t use to like mushrooms† (not I didn’t used to like mushrooms). Finally, several readers wondered about the pronunciation of used to and use to. You’ll find a thorough treatment of British and American pronunciation of these forms at the Oxford Learner’s Dictionaries site. Thanks to all of you for your comments. Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Misused Words category, check our popular posts, or choose a related post below:50 Redundant Phrases to Avoid55 Boxing IdiomsUlterior and Alterior

Discussion Questions #1 and #2 Personal Statement

Discussion Questions #1 and #2 - Personal Statement Example Scientific methods are often lengthy, time consuming and very cumbersome. For the analysis to come to completion, therefore, a lot of time, efforts and costs must be expended. The constraints of time and costs are very fundamental and may significantly limit this method a great deal. Furthermore, they must be conducted by well informed individuals who have adequate scientific skills. Where these are lacking, the method’s applicability is hindered. The human population is constantly increasing. Calculating this increase in population is very difficult for a number of reasons. First and foremost, some births are not registered and, therefore, it becomes difficult to know exactly how many children are born especially in developing countries. In addition to this, growth in human population is never uniform world over (Linkov & Ramadan, 2004, p. 67). In some countries or regions, there is unprecedented growth in this population while, in others, it is a bit low. Therefore, most methods used to calculate the population is bound to experience a great degree of

Fired for Creativity Essay Example | Topics and Well Written Essays - 750 words

Fired for Creativity - Essay Example In order to complete a case analysis on his story, initially, before answering six essay questions, this paper will first provide a summary of Lasseter’s experience from a management perspective. According to the Power and Politics in the Fall and Rise of John Lasseter, the creative man’s employment background, the early attraction to animation began in his freshman year of high school and only intensified when he began his formal education in the field. Upon being hired at Disney, Lasseter worked emphatically to progress the animation department to the ways of the future by introducing the idea of films based solely off computer-generated imaging. While his intentions were honorable, Lasseter acknowledges that his drive may have created instances where he seemed like a loose cannon. After a particular meeting where Lasseter was allowed to create a test film to demonstrate the viability of using both hand drawn animation and computer generated imaging, he was immediatel y fired by a supervisor who did not care for him. This instance is where the case analysis can determine a clear problem with management style. The problem with what happened to Lasseter is that his employment termination was obviously personal in nature. It seems ridiculous that an employee of a creative company could be terminated for simply being creative. Furthermore, Lasseter had no outstanding work infractions. For whatever personal reason that this studio head did not care for Lasseter, the employee was fired unjustly. Personal feelings must be worked out in a professional manner versus being dealt with professionally which can often go the wrong way, as we see in this example. Fortunately for Lasseter, this unjust retribution did not last as the young animator was hired by Steve Jobs and helped him in the creation and success of Disney’s Pixar and the outstanding films the company produced. The analysis of this scenario demonstrates that while younger employees can fi nd themselves at a disadvantage when it comes to dealing with their more tenured and older counterparts, there is always hope in the fact that someone else will see them and value their creativity. Questions 1-6 1. What forms of interpersonal power are evident in the case? Within the case of Lasseter and the studio head who did not care for him as a person, the types of interpersonal power being used are those of status and age. As the older, more experienced employee, the studio head knew he had the upper hand in the situation as he had the more advanced job title to effectively be able to have Lasseter fired without due cause. 2. In what ways do the two faces of power appear in this case? The two faces of power in this case are first, the studio head who chose to have Lasseter unjustly fired. By simply using his power to make this happen, the studio head used the power of his position and office politics to have the young artist fired. The second face of power in this case is that of Steve Jobs himself. The actions of Jobs allow him to act as the hero in this story as he is able to see the value in this employee and hire him back on for Pixar. 3. Does the firing of John Lasseter from Disney Studios and the events leading up to his firing demonstrate the ethical use of power? Explain

Alexander the Great Essay

Alexander the Great Essay With the courage of a tiger and the ferocity of a Lion, Alexander III swept through Eastern Europe and Asia. Alexander the Great as he would be called was believed to be a descendant of the Gods! He was a military genius because his battles throughout Asia Minor, against Darius, the King of the Empire of Persia, would bring him fame, fortune, and eternal glorification as the greatest king to have ruled in all of history. The Macedonian kings level of intelligence, the amount of land that he acquired, and the fact that he was a military genius, is some of the most important aspects to the life of Alexander the Great. The intelligence quota of Alexander the Great was incredible and was recognized at a very young age. By following the teachings of Aristotle, Alexander would expand his horizon of knowledge to an incredible extent. The reason for this great expansion of knowledge was because of the deep rooted respect that Alexander had for Aristotle. We can see this obvious respect because He placed the copy of Homer into a casket, adorned with jewels, and it followed him wherever he went. (Abbott) Alexander loved books. He loved expanding knowledge, not only for himself, but for his people. His famed city of Alexandria was built after him. It housed the greatest library of the ancient world. It had thousands of books and scrolls and all kinds of literature. By using his vast amount of literary resources surrounding him, he was able to sharpen the tip of his spear that was his knowledge of military tactics. By studying ancient generals and kings, whether they were great in what they accomplished or terrible for how they failed, he learned to use their feats in a way to better himself as a king and especially as general. He would go on to use his knowledge to command and conquer the once thought invincible Asiatic empires. Alexander the Great was one of the most amazing leaders in the history of ancient Greece. The expansions of his boundaries of the kingdom were phenomenal. In five years, he expanded his empire east by 2500 miles (Leadership). He was one of the most successful military commanders of all time and is presumed undefeated in battle. By the time of his death, he had conquered most of the world known to the ancient Greeks (Snow). He controlled the vast majority of the eastern European continent and he also controlled much of the Asiatic continent as well. Alexander the Great was one of the best-known rulers in ancient history. By the time of his death at thirty-two, he ruled the largest Western empire of the ancient world (Alexander the Great Biography). By controlling this vast empire, the economy of the Macedonian empire would have flourished dramatically. This would be because of trade. The trade routes that were mapped out by Alexander and his army were extremely important. They allowed trade caravans to be able to traverse through these, previously, unchartered areas. This would allow for the exotic merchandise from foreign lands to stream into the cultures of the Macedonian people, thus causing cultural diversity. He expanded Macedonia, thus, creating an empire that covered over two million square miles. He founded 70 cities and many were on trade routes thus increasing east-west trade. He also saw the need to create a new coinage system so that his whole empire would be connected during exchanges. (Leadership) A major accomplishment of Alexander was that he saw that he needed to make his new subjects happy. To make them happy he granted them freedoms and in return he asked for loyalty. He also tried to integrate families into the Macedonian families and so he would have his soldiers marry some of the women and, thus, creating a more diverse and multi-cultural Macedonia. When Alexander ascended the throne of Macedon following the death of his father in 336, the city states of Greece and the huge empire of Persia had already been in conflict for hundreds of years (Sheppard 9). Alexanders motivation for success was driven by glory. He wanted to be remembered and be seen as a God by all who knew of his name. Alexanders favorite tutor was Lysimachus. This tutor devised a game in which Alexander impersonated the hero Achilles. Achilles was a heroic Greek warrior from a famous ancient poem called theÂÂ  Iliad.ÂÂ  Achilles became the model of the noble warrior for Alexander, and he modeled himself after this hero. This game delighted Olympias because her family claimed the hero as an ancestor (Alexander the Great Biography). He also wanted to exact his revenge on the Persians who had invaded 150 years prior to his ruling. He was a great military leader because he knew about strategy. Alexander inherited a well-trained army from his father and trained them even further. Perhaps surprisingly, the size of his army never went over 40,000. What Alexander did value and perhaps what kept his army smaller, was the mobility and speed gave military advantage (Military Commanders). He realized that through speed and mobility he would be able to quickly alter his positions and to out maneuver and eventually outflank his enemies, resulting in an almost immediate victory. He would never ask anyone to do something if he himself would not do. This means he would never have his soldiers do something dastardly during battle unless if he was there doing it with them. We can see the accuracy of this statement because he would always lead his men from the front. This made him an easy target, but also a huge motivation towards his troops. This may have been the reason that he wounded so many times. On an interesting note, he would never drink water until he knew that all of his soldiers had water to drink. Alexander is given credit for creating the phalanx style of battle. This was a battle tactic that consisted of hoplites in columns. The columns would be ten men across and ten men deep. Men in the phalanx carried a round shield called a hoplon, from which the infantry took their name, hoplites. The hoplites wore metal armor on their chests, forearms, and shins at least, plus a metal helmet that covered the head down to the neck. The addition of armor classified the hoplites as heavy infantry, as opposed to light infantry that wore little or no armor. (The Great Phalanx) With the addition of more phalanx groups Alexander would have created an extremely large and mobile fighting force. Being mobile meant that enemy cavalry could not easily strike a decisive blow against Alexander. The Grecians are known for their ability to organize and form gaps in their lines to prevent effective cavalry attacks. When a man has the ability to have historians put a Great after their names then they have to do something simply remarkable. When they have a city named after them, Alexandria, then they have had to of done something remarkable. If they are in the Bible, a book that has not been edited for thousands of years, as one of the greatest kings in all of history then they had to of done something remarkable. Alexander of Macedon, or Alexander the Great, shaped the history of mankind. In Daniel 11:2-4, we see that he is mentioned as the he-goat that destroys the ram, which a reference to Darius. This is an incredible feat for anyone. A man of his stature, a man who was extremely intelligent, acquired huge amounts of land, and was simply the most inspirational and fearless military leader of his time, deserves to have the title of Great. Alexander the Great would go down in history as the most influential and important ruler of the Ancient Grecian world.

Electric utility Essay

Doctor’s office – job shop or project. All patients do not require the same procedures, namely the service offered are custom in nature. Automatic car wash – assembly line flow. There is a linear sequence of operations common to all cars. College curriculum – can be any: Assembly line flow: if same curriculum is required of all students, batch: if curriculum is tailored to some degree, or project: if curriculum is tailored to individual students. Studying for an exam – project. The studying process is unique to each student for different, unique exams. Registration for classes – assembly line. All students must largely complete the same sequence of steps which vary little regardless of the program of study. Electric utility – continuous process as the product is highly standardized and can be automated to a great degree in order to better achieve a low unit cost. Q2. Why are assembly-line processes usually so much more efficient but le ss flexible than batch processes? Give three reasons. Reasons for efficiency, but less flexibility of the line than the batch process: a. Standardization of tasks b. Standard products c. Highly automated d. Specialized equipment e. Unskilled or semi-skilled labor Q3. The rate of productivity improvement in the service industries has been much lower than in manufacturing. Can this be attributed to process selection decisions? What problems would be involved in using more efficient processes in service industries? Yes, the rate of productivity improvement in the service industries can be partly attributed to process selection  decisions. Service industries typically select a batch or project process to provide customized service. This is usually less efficient than the assembly line or continuous process approach. The problems in using more efficient processes in the service industries are: Possible customer dissatisfaction with standardized product Need for extensive capital investment Need for high and stable volume, particularly without inventory Difficult to specify exact process sequence The customer can be involved in the process during production of the service and create unique demands or inefficiencies. Q6. Compare the expensive restaurant, fast-food restaurant, and cafeteria in terms of process characteristics such as capital, product type, labor, planning, and control systems. The project process, typically used for skyscraper construction, probably does lead to higher costs because the volume of skyscraper construction is low. To make a batch process preferred would require construction of some number of identical skyscrapers. This seems both unlikely and aesthetically undesirable. Perhaps, however, sections of skyscrapers could be standardized and produced by batch processes while still maintaining the appearance of unique buildings. This would be a modular approach to the problem. Q7. An entrepreneur is planning to go into the food business. How would he or she decide whether to open a cafeteria, fast-food restaurant, or fine restaurant? What factors should be considered in this decision? He would have to consider marketing operations, and financial aspects of the problem. The factors to be considered are: Cafeteria Fast Food Fine Restaurant Capital Requirements Heavy initial investment to set up cafeteria line. Low inventory. Medium initial investment, but higher inventory needs. Lower initial investment medium inventory. Market Conditions Need for large body of steady customers; mobile market. Inexpensive market. Competition very intense. Need for large and inexpensive market. Competition fairly intense. Need for expensive Less danger from competition. Labor Low skilled labor at low cost. Low skilled labor at low cost. Highly skilled cooks and waiters required. Technology Most risky. Less risky. Little risk. Q10. What are the strategies of the following organizations? Is the strategy defined in terms of product or process or both? McDonald’s. AT&T Telephone Co. General Motors. Harvard Business School. Distinctive Competence Product/Process McDonald’s Restaurant Fast, inexpensive, quality food, pleasant atmosphere . Product & Process AT&T Telephone Company Highest volume of calls Best technology Process Ge neral Motors Its reputation, number of dealers Product & Process Harvard Business School Case method Process Q12. A new business is considering starting up a new plant to produce low-volume, standard products. They are hoping that the business will grow and the products eventually will become successful and sell in high volumes. a. The business should consider using a batch process that is flexible enough to be modified into a line process when the products become successful and sell in high volume. b. The business should expect the need to invest more when it eventually uses a line process. It may be necessary to purchase special purpose equipment when the products sell in high volume for a long period of time. Lower skills, lower pay and more repetitive tasks may characterize the future labor force. Q1. Classify the following services by their degree of customer contact (high, medium, or low). Also, determine how much uncertainty the customer introduces into the system by the ability to make customized service demands (high, medium, or low). Check clearing in a bank. Bank teller. Bank loan officer. Customer contact customized service demands Check clearing in a bank Low Medium Bank teller High Low Bank loan officer Medium High Q5. Describe the service-product bundle for each of the following services: Hospital. Lawyer. Trucking firm. Trucking firm is tangible service – explicit service what the provider does for customer Hospital is psychological benefits – implicit service how customer feels after service Lawyer is physical goods – facilitating goods used during service or received by customer Q10. Why is the service-profit chain important to operations management? The service-profit chain model tries to link all the components required to make an organization successful. According to this model, a company that performs well in one aspect and poorly in another will eventually develop problems that affect the entire organization. This working model highlights the importance of the links between quality management, a good work force and exceptional service to the customer. Q14. How can we use the service matrix to improve service operations? The Service Process Matrix is a classification matrix of service  industry firms based on the characteristics of the individual firm’s service pr ocesses. The Service Process Matrix can be useful when investigating the strategic changes in service operations. In addition, there are unique managerial challenges associated with each quadrant of the matrix. By paying close attention to the challenges associated with their related classification, service firms may improve their performance. Also, the Service-System Design Matrix is a useful tool for understanding the different elements Service Design Matrix of a service system. Q16. What key factors are most firms seeking when they offshore services? Transaction-intensive services becoming commoditized. Professional services more commonly offshored High-end niche providers are globally dispersed Firms moving fast to scoop up global talent Collaboration and maintaining quality challenging with globally dispersed providers

Law of Tort

4. 0 INTRODUCTION Occupiers' liability generally refers to the duty owed by land owners to those who come onto their land. However, the duty imposed on land owners can  extend beyond simple land ownership and in some instances the landowners may transfer the duty to others, hence the term occupier rather than owner. The term occupier itself is misleading since physical occupation is not necessary for liability  to arise. Occupiers' liability is perhaps a distinct form of negligence in that there must be a duty of care and breach of duty, causing damage.The rules of remoteness apply to occupiers liability in the exact same way that they apply to negligence claims. Liability can arise on occupiers for omissions since their relationship  gives rise to  duty to take action to ensure the reasonable safety of visitors. The law relating to occupiers' liability originated in common law but is now contained in two major pieces of legislation: Occupiers Liability Act 1957   – which imposes an obligation on occupiers with regard to ‘lawful visitors' Occupiers Liability Act 1984 – which imposes liability on occupiers with regard to persons other than ‘his visitors'.Different levels of protection are expected under the two pieces of legislation with a higher level of protection afforded to lawful visitors. NB: Lawful visitors are owed the duty set out in the 1957 Act; non-lawful visitors are owed the duty set out in the 1984 Act. It is for the claimant to prove that he is a lawful visitor and therefore entitled to the more favorable duties in the earlier Act 4. 1 Occupiers( who is an occupier) At common law (and under the statute occupation is based on control and not necessarily on any title to or property interest in the land.Both the Occupiers Liability Acts of 1957 and 1984  impose an obligation on occupiers rather than land owners. The question of whether a particular person is an occupier is a question of fact and depends on the d egree of control exercised. The test applied is one of ‘occupational control' and there may be more than one occupier of the same premises: In Wheat v E Lacon & Co Ltd [1966] AC 522- House of Lords The claimant and her family stayed at a public house, The Golfer’s Arms in Great Yarmouth, for a holiday. Unfortunately her husband died when he fell down the stairs and hit his head.The stairs were steep and narrow. The handrail stopped two steps from the bottom of the stairs and there was no bulb in the light. The claimant brought an action under the Occupiers Liability Act 1957 against the Brewery company, Lacon, which owned the freehold of The Golfer’s Arms and against the Managers of the Pub, Mr. & Mrs. Richardson, who occupied the pub as a licensee. Held: Both the Richardson’s and Lacon were occupiers for the purposes of the Occupiers Liability Act 1957 and therefore both owed the common duty of care. It is possible to have more than one occupier.The quest ion of whether a particular person is an occupier under the Act is whether they have occupational control. Lacon had only granted a license to the Richardson’s and had retained the right to repair which gave them a sufficient degree of control. There is no requirement of physical occupation. However, it was found that Lacon was not in breach of duty since the provision of light bulbs would have been part of the day to day management duties of the Richardson’s. Since the Richardson’s were not party to the appeal the claimant’s action failed.Lord Denning: â€Å"wherever a person has a sufficient degree of control over premises that he ought to realize that any failure on his part to use care may result in injury to a person coming lawfully there, then he is an † occupier † and the person coming lawfully there is his † visitor â€Å": and the † occupier † is under a duty to his † visitor † to use reasonable care. I n order to be an â€Å"occupier â€Å"it is not necessary for a person to have entire control over the premises. He need not have exclusive occupation. Suffice it that he has some degree of control. He may share the control with others. Two or more may be â€Å"occupiers â€Å".And whenever this happens, each is under a duty to use care towards persons coming lawfully on to the premises, dependent on his degree of control. If each fails in his duty, each is liable to a visitor who is injured in consequence of his failure, but each may have a claim to contribution from the other. † Physical occupation is not a requirement: Harris v Birkenhead Corp [1976] 1 WLR 279 The claimant Julie Harris was 4 years old when she wandered off from a children’s play park with her friend. They entered a derelict house which was due for demolition. The house had not been secured and the door was open.They went upstairs and Julie sustained serious injury when she fell from a window. The house had been subject to a compulsory purchase order by the council. The house had been owned by a private landlord and the tenant was offered alternative accommodation by the council. The tenant informed the council that she did not want to take up the offer of accommodation and made her own arrangements and left the property. The council served 14 days notice on the owner of their intention to take possession of the property, but never actually took physical possession at the expiry of the 14 days.Held: The Council had the legal right to take possession to secure the property, actual physical occupation was not required to incur liability as an occupier. The council were therefore liable. 4. 1. 1 Occupiers Liability Act 1957 The Occupiers Liability Act 1957 imposes a common duty of care on occupiers to lawful visitors. By virtue of s. 1 (3) (a), the Act applies not only to land and buildings but also extends  to fixed and movable structures, including any vessel, vehicle or ai rcraft. The protected damage under the Occupiers Liability Act 1957 includes death, personal injury and damage to property. . 1. 1. 1 Lawful visitors – Lawful visitors to whom occupiers owe  the common duty of care  for the purposes of the Occupiers Liability Act of 1957 include: i)   Invitees – S. 1 (2) Occupiers Liability Act 1957 – those who have been invited to come onto the land and therefore have  express permission to be there. ii) Licensees – S. 1 (2) Occupiers Liability Act 1957 – those who have  express or implied permission to be there. According to S. 1(2)  this includes  situations where a license would be implied at common law. (See below) iii) Those who enter pursuant to a contract – s. (1) Occupiers Liability Act 1957 – For example paying guests at a hotel or paying visitors to a theatre performance or to see a film at a cinema. iv) Those entering in exercising a right conferred by law – s. 2(6) Oc cupiers Liability Act 1957 – For example  a person entering to read the gas or electricity meters, a police executing warrants of arrest or search) 4. 1. 1. 2 Implied license at common law In the absence of express permission to be on the land, a license may be implied at common law where there exists repeated trespass and no action taken by the occupier to prevent people coming on to the land.This requires an awareness of the trespass and the danger: Lowery v Walker [1911] AC 10  House of Lords The Claimant was injured by a horse when using a short cut across the defendant’s field. The land had been habitually used as a short cut by members of the public for many years and the defendant had taken no steps to prevent people coming on to the land. The defendant was aware that the horse was dangerous. Held: The defendant was liable. Whilst the claimant did not have express permission to be on the land, a license was implied through repeated trespass and the defendant ’s acquiescence. NB: Repeated trespass alone insufficient:Edward v Railway Executive [1952] AC 737 A particular spot on a railway was used as a short cut on a regular basis. The fence was repaired on several occasions and whenever it was reported to have been interfered with. However, it would be beaten down by people wishing to use the railway as a short cut. Witness testimony was to the effect that the fence was in good repair the morning of the incident. Held: No license was implied. The Defendant had taken reasonable steps to prevent people coming onto the railway. Lord Goddard: â€Å"Repeated trespass of itself confers no license† 4. 1. 1. 3 Allurement principleThe courts are more likely to imply a license if there is something on the land which is particularly attractive and acts as an allurement to draw people on to the land. Taylor v Glasgow Corporation [1922] 1 AC 448 House of Lords The defendants owned the Botanic Gardens of Glasgow, a park which was open to the public. On the park various botanic plants and shrubs grew. A boy of seven years ate some berries from one of the shrubs. The berries were poisonous and the boy died. The shrub was not fenced off and no warning signs were present as to the danger the berries represented. Held: Glasgow Corporation was liable.Children were entitled to go onto the land. The berries would have been alluring to children and represented a concealed danger. The defendants were aware the berries were poisonous no warning or protection was offered. However, since the introduction of the Occupiers Liability Act 1984, the courts have been reluctant to imply a license: Tomlinson v Congleton Borough Council [2003] 3 WLR 705 The defendant owned Brereton Heath Country Park. It had previously been a sand quarry and they transformed it in to a country park and opened it up for public use. The defendants had created a lake on the park which was surrounded by sandy banks.In the hot weather many visitors came to th e park. Swimming was not permitted in the lake and notices were posted at the entrance saying â€Å"Dangerous water. No swimming†. However despite this, many people did use the lake for swimming. Rangers were employed and on occasions sought to prevent swimming but some of the visitors would be rude to the rangers’ attempts to prevent them and many continued to swim. The claimant was injured when he dived into shallow water and broke his neck. At the Court of Appeal it was held that he was a trespasser despite the repeated trespass and inadequate steps to prevent him swimming.They also stated that the warning signs may have acted as an allurement to macho young men. The Court of Appeal was of the opinion that since the introduction of the Occupiers Liability Act 1984, the courts should not strain to imply a license. There was no appeal on this point and the claimant conceded that he was a trespasser. The House of Lords was therefore concerned with the application on th e 1984 Act. The Court of Appeal had held that the council were liable but reduced the damages by 2/3 under the Law Reform (Contributory Negligence) Act 1945.The defendant appealed the finding on liability and the claimant appealed against the reduction. House of Lords held: The Council was not liable. No risk arose from the state of the premises as required under s. 1 (1) (a) Occupiers Liability Act 1984. The risk arose from the claimant’s own action. He was a person of full capacity who voluntarily and without pressure or inducement engaged in an activity which had an inherent risk. Even if there was a risk form the state of the premises, the risk was not one against which the council would reasonably be expected to offer the claimant some protection under s. (3) (C). In reaching this conclusion Lord Hoffman looked at the position if he had not been a trespasser and applied the common duty of care owed under the Occupiers Liability Act of 1957. He was of the opinion that the re was no duty to warn or take steps to prevent the claimant from diving as the dangers were perfectly obvious. This was based on the principle of free will and that to hold otherwise would deny the social benefit to the majority of the users of the park from using the park and lakes in a safe and responsible manner.To impose liability in this situation would mean closing of many such venues up and down the country for fear of litigation. He noted that 25-30 such fractures occurred each year nationwide, despite increased safety measures the numbers had remained constant. 4. 1. 1. 4 Non lawful visitors The 1957 Act does not extend protection to: ? trespassers ? Invitees who exceed their permission ? Persons on the land exercising a public right of way:   Ã‚  McGeown v Northern Ireland Housing Executive [1994] 3 All ER 53 House of Lords The claimant was injured when she tripped in a hole on land owned by the defendant.The land was a public right of way. It was held that the defendan t was not liable as  the claimant  was not a lawful visitor under the Occupiers Liability Act 1957 because she was exercising a public right of way. †¢ Persons on the land exercising a private right of way:   Ã‚  Ã‚  Holden v White [1982] 2 All ER 328 Court of Appeal The claimant, a milkman, was injured on the defendant’s land by a manhole cover which broke when he stepped on it. At the time he was delivering milk to the house of a third party who had a right of way across the defendant’s land.It was held that he was not entitled to claim against the defendant since he was exercising a right of way and was not therefore a lawful visitor of the defendant. 4. 1. 1. 5 The common duty of care The common duty of care is set out in s. 2 (2) Occupiers Liability Act 1957: S. 2(2)   – ‘The common duty of  care is to take such care as in all the circumstances of the case is reasonable to see that the  visitor will be reasonably safe in using the pre mises for the purposes for which he  is invited or permitted  by the occupier to be there. ‘   Thus the standard of care varies according to the circumstances.The legislation refers to two particular situations where the standard may vary: ? S. 2(3)(a) – an occupier must be prepared for children to be less careful than adults ? S. 2(3)(b) – an occupier may expect that a person  in the exercise of his calling will appreciate and guard against any special risks ordinarily incident to it i)   S. 2(3) (a) Child visitors The courts will take into account the age of the child and level of understanding a child of that age may be expected to have. They may be more adventurous and may not understand the nature of certain risks.The occupier does not however have to guarantee that the house will be safe, but only has to take reasonable care. If the child’s parents are present, they must share some responsibility, and, even if they are not present, it may b e relevant to the occupier’s duty that they thought it prudent to allow their child to be where he was. Titchener v British Railways Board [1983] 1 WLR 1427 House of Lords The Claimant, a 15 year old girl, was out walking with her boyfriend who was 16. They took a short cut across a railway line and they were both hit by a train. He was killed and she was seriously injured.There was a gap in the fence at the place where they crossed and there was a pathway leading to this gap which suggested that there was repeated trespass. Also it was accepted that either the Defendant was aware of the gap or would have been aware upon reasonable inspection. The Defendant raised the defense of volenti under s. 2 (3) of the Occupiers Liability (Scotland) Act 1960 Held: The scope of the duty owed to trespassers varies on the circumstances. On the facts of this case the Defendants did not owe a duty to a 15 year old trespasser who was fully aware of the risks.Even if the Defendant did owe a du ty of care the defense of volenti under s. 2 (3) would succeed. Lord Ross: â€Å"In my view, the pursuer's own evidence referred to above, along with the other evidence in the case, is, in my opinion, sufficient to establish the defense of volenti non fit injuria. Such defense is open to the defenders under section 2 (3) of the Occupiers' Liability (Scotland) Act 1960, and no duty under section 2 (1) of the Act is imposed upon an occupier to a person entering on the premises in respect of risks which that person has willingly accepted as his.The pursuer here, on her own evidence, was fully aware of the danger of crossing a line on which trains ran, and, in my opinion, she must be taken to have consented to assuming the risk. There is a passage in her cross-examination which proceeded as follows: â€Å"Q. And you knew that it would be dangerous to cross the line because of the presence of these trains? A. Yes. Q. Well why did you do it if you knew it would be dangerous? A. Because it was shorter to get to the brickworks. Q. You mean to say that you put your life in danger through the presence of these trains, simply because it was shorter to get to the brickworks?A. Well, before my accident I never ever thought that it would happen to me, that I would never get hit by a train, it was just a chance that I took. † â€Å"A person who takes a chance necessarily consents to take what come†   Ã‚  Jolley v Sutton [2000] 1 WLR 1082 Two 14 year old boys found an abandoned boat on land owned by the council and decided to do it up. The boat was in a thoroughly rotten condition and represented a danger. The council had stuck a notice on the boat warning not to touch the boat and that if the owner did not claim the boat within 7 days it would be taken away. The council never took it away.The boys had been working on the boat for 6-7 weeks when one of them suffered severe spinal injuries, resulting in paraplegia, when the boat fell on top of him. The boys ha d jacked the boat up to work on the underside and the jack went through the rotten wood. The claimant brought an action under the Occupiers Liability Act 1984. The trial judge found for the claimant. The Court of Appeal reversed the decision, holding that whilst it was foreseeable that younger children may play on the boat and suffer an injury by falling through the rotten wood, it was not foreseeable that older boys would try to do the boat up.The claimant appealed. House of Lords held: The claimant's appeal was allowed. The risk was that children would â€Å"meddle with the boat at the risk of some physical injury† The actual injury fell within that description. Lord Steyn: â€Å"The scope of the two modifiers – the precise manner in which the injury came about and its extent – is not definitively answered by either The Wagon Mound ( No. 1) or Hughes v. Lord Advocate. It requires determination in the context of an intense focus on the circumstances of each ca se. † Taylor v Glasgow Corporation [1922] 1 AC 448 House of LordsThe defendants owned the Botanic Gardens of Glasgow, a park which was open to the public. On the park various botanic plants and shrubs grew. A boy of seven years ate some berries from one of the shrubs. The berries were poisonous and the boy died. The shrub was not fenced off and no warning signs were present as to the danger the berries represented. Held: Glasgow Corporation was liable. Children were entitled to go onto the land. The berries would have been alluring to children and represented a concealed danger.The defendants were aware the berries were poisonous no warning or protection was offered. Phipps v Rochester Corporation [1955] 1 QB 450 A 5 year old boy was walking across some open ground with his 7 year old sister. He was not accompanied by an adult. He was injured when he fell into a trench. The Corporation were not held liable as an occupier is entitled to assume that prudent parents would not all ow their children to go unaccompanied to places where it is unsafe. Devlin J on duty owed to children â€Å"The law recognizes a sharp difference between children and adults.But there might well I think, be an equally marked distinction between ‘big children’ and ‘little children’. †¦The occupier is not entitled to assume that all children will, unless they are allured, behave like adults; but he is entitled to assume that normally little children will be accompanied by a responsible person. †¦The responsibility for the safety of little children must rest primarily upon the parents; it is their duty to see that such children are not allowed to wander about by themselves, or at least to satisfy themselves that the places to which they do allow their children to go unaccompanied are safe.It would not be socially desirable if parents were, as a matter of course, able to shift the burden of looking after their children from their own shoulders to tho se persons who happen to have accessible pieces of land. † ii) S. 2(3)(b) Common calling ( Trade Visitors) This provision applies where an occupier employs an expert to come on to the premises to undertake work. The expert can be taken to know and safeguard themselves against  any dangers that arise from the premises in relation to the calling of the expert. For example if an occupier engages an lectrician, the electrician  would be expected to know the dangers inherent in the work they are employed to do. Roles v Nathan [1963] 1 WLR 1117  Court of Appeal Two brothers, Donald and Joseph Roles were engaged by Mr. Nathan as chimney sweeps to clean the flues in a central heating system at Manchester Assembly Rooms. The flues had become dangerous due to carbon monoxide emissions. A heating engineer had warned them of the danger, however, the brothers told him they knew of the dangers and had been flue inspectors for many years.The engineer monitored the situation throughout the day and at one point ordered everybody out of the building due to the levels of carbon monoxide. The brothers ignored this advice and continued with their work. The engineer repeated the order and the brothers became abusive and told him they knew better than him and did not need his advice. The engineer forcibly removed them from the building. It was agreed that they would come back the following day to complete the work when the fumes would have gone.They were also told they should not do the work whilst the fires were lighted. However, the next day the brothers were found dead in the basement having returned the previous evening to complete the work when the fires were lit. Their widows brought an action under the Occupiers Liability Act 1957. Held: The defendant was not liable. The dangers were special risks ordinarily incident to their calling. The warnings issued were clear and the brothers would have been safe had they heeded the warnings. Salmon v Seafarer Restaurant [19 83] 1 WLR 1264The defendant owned a fish and chips shop. One night he left the chip fryer on and closed the shop for the night. This caused a fire and the fire services were called to put out the fire. The claimant was a fire man injured in an explosion whilst fighting the fire. He had been thrown to the ground whilst footing a ladder on a flat roof. The defendant sought to escape liability by invoking s. 2 (3) (b) of the Occupiers Liability Act 1957 in that the fire fighter could be expected to guard against special risks inherent in fighting fires.Held: The defendant was liable. Where it can be foreseen that the fire which is negligently started is of the type which could require firemen to attend to extinguish that fire, and where, because of the very nature of the fire, when they attend they will be at risk even if they exercise all the skill of their calling, there is no reason why a fireman should be at any disadvantage in claiming compensation. The duty owed to a fireman was not limited to the exceptional risks associated with fighting fire but extended to ordinary risks.Ogwo v Taylor [1987] 3 WLR 1145 House of Lords The Defendant attempted to burn off paint from the fascia boards beneath the eaves of his house with a blow lamp and in so doing set fire to the premises. The fire brigade were called and the Claimant, an acting leading fireman, and a colleague entered the house wearing breathing apparatus and the usual fireman's protective clothing and armed with a hose. The two firemen were able, with the aid of a step- ladder, to squeeze through a small hatch to get into the roof space. The heat within the roof space was intense.The Claimant suffered serious burn injuries to his upper body and face from scalding steam which must have penetrated his protective clothing. Held: A duty of care was owed to a professional fireman. There was no requirement that the risk be exceptional. The defense of volenti had no application. Lord Bridge: â€Å"The duty of p rofessional firemen is to use their best endeavors to extinguish fires and it is obvious that, even making full use of all their skills, training and specialist equipment, they will sometimes be exposed to unavoidable risks of injury, whether the fire is described as â€Å"ordinary† or â€Å"exceptional. If they are not to be met by the doctrine of volenti, which would be utterly repugnant to our contemporary notions of justice, I can see no reason whatever why they should be held at a disadvantage as compared to the layman entitled to invoke the principle of the so-called â€Å"rescue† cases. † iii)   Warnings and warning  signs It may be possible for an occupier to discharge their duty by giving a warning some danger on the premises(‘Loose carpet’; ‘slippery floor’) – See   Roles v Nathan [1963] 1 WLR 1117 above)   However, S. (4)(a) Occupiers Liability Act 1957 provides that a warning given to the visitor  will not b e treated as absolving the occupier of liability unless in all the circumstances it was enough to enable the visitor to be reasonably safe. The occupier i. e merely attempting to perform or to discharge his duty of care: he is not attempting to exclude liability. Is something slippery has been spilt on the floor of a shop, the occupier can (a) close the shop, (b) clean up the spillage or (c) give a warning so that the visitor can avoid the spot or step gingerly.The warning must  cover the danger that in fact arises: White v Blackmore [1972] 3 WLR 296 Mr. White was killed at a Jalopy car race due negligence in the way the safety ropes were set up. A car crashed into the ropes about 1/3 of a mile from the place where Mr. White was standing. Consequently he was catapulted 20 foot in the air and died from the injuries received. Mr. White was a driver in the race but at the time of the incident he was between races and standing close to his family. He had signed a competitors list whic h contained an exclusion clause.There was also a warning sign at the entrance to the grounds which stated that Jalopy racing is dangerous and the organizers accept no liability for any injury including death howsoever caused. The programme also contained a similar clause. His widow brought an action against the organizer of the event who defended on the grounds of  volenti  and that they had effectively excluded liability. Held: The defence of  volenti  was unsuccessful. Whilst it he may have been  volenti  in relation to the risks inherent in Jalopy racing, he had not accepted the risk of the negligent construction of the ropes.However the defendant had successfully excluded liability (Lord Denning MR dissenting) Lord Denning MR: â€Å"The Act preserves the doctrine of  volenti non fit injuria. It says in Section 2(5) that: â€Å"the common duty of care does not impose on an occupier any obligation to a visitor in respect of risks willingly accepted as his by the vi sitor†. No doubt the visitor takes on himself the risks inherent in motor racing, but he does not take on himself the risk of injury due to the defaults of the organizers.People go to race meetings to enjoy the sport. They like to see the competitors taking risks, but they do not like to take risks on themselves, even though it is a dangerous sport, they expect, and rightly expect, the organizers to erect proper barriers, to provide proper enclosures, and to do all that is reasonable to ensure their safety. If the organizers do everything that is reasonable, they are not liable if a racing car leaps the barriers and crashes into the crowd – see Hall v. Brooklands (1933) 1 K. B. 206.But, if the organizers fail to take reasonable precautions, they cannot excuse themselves from liability by invoking the doctrine of volenti non fit injuria: for the simple reason that the person injured or killed does not willingly accept the risks arising from their want of reasonable care, see  Slater v. Clay Cross Co. (1956) 2 Q. B. 20B; Wooldridge v. Summers (1963) 2 Q. B. at page 69; Nettleship v. Weston    (1971) 2 Q. B. at page 201. † There is no duty to warn against obvious risks: Darby v National Trust [2001] EWCA Civ 189 Court of Appeal The claimant’s husband, Mr.Darby, drowned in a pond owned by the National Trust (NT). The pond was one of five ponds in Hardwick Hall near Chesterfield. Two of the ponds were used for fishing and NT had taken steps to prevent the use of those ponds for swimming or paddling. However, with regards to the pond in which the fatality occurred, NT had done nothing to prevent visitors using the pond and it was common for visitors to use the pond for paddling and swimming during the warm summer months. On the day in question Mr. Darby had been paddling with his children around the edge of the pond.He then swam to the middle to play a game he had often played whereby he would go under water and then bob up to the surfa ce. However, he got into difficulty and drowned. The claimant argued that because  of NT’s inactivity in preventing swimmers using the pond, both she and her husband had assumed the pond was safe for swimming. Held: NT was not liable. The risk to swimmers in the pond was perfectly obvious. There was no duty to warn of an obvious risk Cotton v Derbyshire Dales District Council [1994] EWCA Civ 17 Court of AppealThe claimant, a 26 year old man, had gone out for the day with a group of friends and his fiance over the Easter bank holiday. They had visited 3 pubs where the claimant had drunk about 4 pints. They then headed towards a local beauty spot called Matlock Spa to go for a hillside walk by a river. The parties were in high spirits and became separated. The claimant and his fiance drifted from the pathway and he was seriously injured when he fell off a cliff. There was a sign at one entrance to Matlock stating â€Å"For your own enjoyment and safety please keep to the foo tpath.The cliffs can be very dangerous, and children must be kept under close supervision. † However, there was no such sign at the entrance used by the claimant. The claimant brought an action based on the Occupiers Liability Act 1957 for the failure to adequately warn him of the risk. Held: There was no obligation to warn of an obvious risk. The claimant would have been aware of the existence of the cliff so such a warning would not have affected events. Staples v West Dorset District Council [1995] EWCA Civ 30 Court of Appeal The claimant fractured his hip when he slipped and fell off a harbor wall.The harbor wall was known as The Cobb and was a well-known tourist attraction commonly used as a promenade. The edge of The Cobb was covered with algae and extremely slippery when wet. The claimant had crouched in the area affected by the algae to take a photo of his friends, when he slipped and fell off a 20 foot drop landing on rocks below. He brought an action based on the Occ upiers Liability Act 1957 arguing that no warning signs were present as to the dangers of slipping. Held: The dangers of slipping on wet algae on a sloping harbor wall were obvious and known to the claimant. Therefore there was no duty to warn. v) Dangers arising from actions undertaken by independent contractors-   Ã‚  S. 2(4)(b) Occupiers Liability Act 1957   An occupier is not liable for dangers created by independent contractors if  the occupier acted  reasonably in all the circumstances in entrusting the work to the independent contractor and took reasonable steps to satisfy himself that the  work carried out was  properly done and the contractor was competent. Ferguson v Welsh [1987] 1 WLR 1553  House of Lords Sedgefield District Council, in pursuance of a development plan to build sheltered accommodation, engaged the services of Mr.Spence to demolish a building. It was a term of the contract that the work was not to be sub-contracted out. In breach of this term, Mr. Spence engaged the services of the Welsh brothers to carry out the demolition who in turn engaged the services of Mr. Ferguson to assist. Mr. Ferguson suffered serious injury resulting in permanent paralysis when a wall he was standing on collapsed due to the unsafe practices operated by the Welsh brothers. He brought an action against the Council, Mr. Spence and the Welsh brothers. The trial judge held that the Welsh Brothers were liable but that Mr.Spence and the Council were not liable. Mr. Ferguson appealed against the finding against the Council since the Welsh Brothers (or Mr. Spence) had the funds or insurance to meet liability. Held: The appeal was dismissed. Mr. Ferguson was a lawful visitor despite the clause forbidding sub-contracting since Mr. Spence would have apparent or ostensible authority to invite him on to the land. However, the danger arose from the unsafe system of work adopted by the Welsh Brothers not the state of the premises. Whilst there was evidence t hat Mr.Spence had sub-contracted demolition work to those executing unsafe practices on  previous occasions, there was no evidence that the Council were aware of this. Gwilliam v West Hertfordshire Hospital NHS Trust [2002] EWCA Civ 1041  Court of Appeal The claimant, a 63 year old woman, was injured at a summer fair hosted by West Hertfordshire Hospital. She was injured whilst using a ‘splat wall’ whereby participants would bounce off a trampette against a wall and become attached to the wall by means of Velcro material. The injury occurred as a result of negligent set up of the equipment.The equipment was provided by  a business called ‘Club Entertainments’ who were an independent contractor engaged by the Hospital. Club Entertainment’s public liability insurance had expired four days before the incidence and thus they had no cover for the injury. They agreed to settle her claim for ? 5,000. Mrs. Gwilliam brought an action against the hospita l based on their failure to ensure that the entertainment arranged was covered by public liability insurance. She claimed the difference between the ? 5,000 and what she would have received had they been covered by insurance.Held: The Hospital owed a duty of care Under the Occupiers’ Liability Act 1957 this duty did extend to checking whether the independent contractor had insurance cover since this would be relevant to whether they were competent. However, there was no breach of duty since the Hospital had enquired and had been told by Club Entertainment that they had insurance cover. There was no duty to inspect the insurance documents to ensure that cover was adequate. 4. 1. 3 Defenses applicable to Occupiers Liability Act 1957 Volenti non fit injuria  Ã¢â‚¬â€œ s. (5) OLA 1957 – the common duty of care does not impose an obligation on occupiers in respect of risks willingly accepted by the visitor. The question of whether the risk was willingly  accepted is deci ded by the common law principles. Contributory negligence – Damages may be reduced under the Law Reform (Contributory Negligence) Act 1945 where the visitor fails to take reasonable care for their own safety. Exclusion of Liability   Ã‚  Ã‚  Ã¢â‚¬â€œ s. 2(1) OLA 1957 allows an occupier to extend, restrict, exclude or modify his duty to visitors in so far as he is free to do so.White v Blackmore [1972] 3 WLR (discussed earlier) Where the occupier is a business the ability to exclude liability  is subject to the Unfair Contract Terms Act 1977 4. 1. 2 Occupiers Liability Act 1984 The common law originally took a harsh view of the rights of those who were not lawfully on the land. (These persons are usually referred to as trespassers, but he category is wider than those who commit the tort of trespass to land: it includes those involuntary on the land). The Occupiers Liability Act 1984 imposes a duty on occupiers in relation to persons ‘other than his visitors' (S. 1 (1 ) (a) OLA 1984).This  includes trespassers and those who exceed their permission. Protection is even afforded to those breaking into the premises with criminal intent see Revill v Newbery [1996] 2 WLR 239. Whilst it may at first appear harsh to impose a duty on occupiers for those that have come on to their land uninvited and without permission, liability was originally recognized at common law for child trespassers where the occupier was aware of the danger and aware that trespassers, including children would encounter the danger. British Railway Board v Herrington [1972] AC 877   overruling Addie v. Dumbreck [1929] AC 358.Addie v Dumbreck  [1929] AC 358  House of Lords the defendant owned View Park Colliery which was situated in a field adjacent to a road. There was a fence around the perimeter of the field although there were large gaps in the fence. The field was frequently used as a short cut to a railway station and children would use it as a playground. The defendant would often warn people off the land but the attempts were not effective and no real attempt was made to ensure that people did not come onto the land. A child came on to the land and was killed when he climbed onto a piece of haulage apparatus.Held: No duty of care was owed to trespassers to ensure that they were safe when coming onto the land. The only duty was not to inflict harm willfully. Viscount Dunedin: â€Å"In the present case, had the child been a licensee, I would have held the defenders liable; secus if the complainer had been an adult. But, if the person is a trespasser, then the only duty the proprietor has towards him is not maliciously to injure him; he may not shoot him; he may not set a spring gun, for that is just to arrange to shoot him without personally firing the shot.Other illustrations of what he may not do might be found, but they all come under the same head—injury either directly malicious or an acting so reckless as to be tantamount to malicious acting. † ‘Occupier' is given the same meaning as under the 1957 Act (S. 1 (2) OLA 1984). Since the Occupiers Liability Act 1984 applies to trespassers, a lower level of protection is offered. Hence the fact that  death and personal injury are the  only protected forms of damage and occupiers have no duty in relation to the property of trespassers. (S. 1 (8) OLA 1984). Also the duty only arises when certain risk factors are present. . 1. 2. 1 The circumstances giving rise to a duty of care S. 1 (3)  Occupiers Liability Act 1984 an occupier owes a duty to another (not being his visitor) if:   (a) He is aware of a the danger or has reasonable grounds to believe that it exists   (b) He knows or has reasonable grounds to believe the other is in the vicinity of the danger or may come into the vicinity of the danger   (c) The risk is one in which in all the  circumstances of the case, he may reasonably be expected to offer the other some protection If all three of these are present the occupier owes a duty of care to the non-lawful visitor.The criteria in s. 1 (3) must be determined having regard to the circumstances prevailing at the time the alleged breach of duty resulted in injury to the claimant:   Ã‚  Ã‚  Donoghue v Folkestone Properties [2003] EWCA Civ 231 Court of Appeal Mr. Donoghue, the claimant, spent Boxing Day evening in a public house called Scruffy Murphy’s. It was his intention, with some of his friends, to go for a midnight swim in the sea. Unfortunately in his haste to get into the water he dived from a slipway in Folkestone harbor owned by the defendant and struck his head on an underwater obstruction, breaking his neck.At his trial evidence was adduced to the affect that the slipway had often been used by others during the summer months to dive from. Security guards employed by the defendant had stopped people from diving although there were no warning signs put out. The obstruction that had injured the claiman t was a permanent feature of a grid-pile which was submerged under the water. In high tide this would not have posed a risk but when the tide went out it was a danger. The claimant’s action was based on the Occupiers Liability Act 1984. Mr. Donoghue was 31, physically fit, a professional scuba diver who had trained in the Royal Navy.It was part of his basic knowledge as a diver that he should check water levels and obstructions before diving. The trial judge found for the claimant but reduced the damages by 75% to reflect the extent to which he had failed to take care of his own safety under the Law Reform (Contributory Negligence) Act 1945. The defendant appealed contending that in assessing whether a duty of care arises under s. 1(3) each of the criteria must be assessed by reference to the individual characteristics and attributes of the particular claimant and on the particular occasion when the incident in fact occurred i. . when assessing whether the defendant should be aware of whether a person may come into the vicinity of the danger, it should be assessed on the likelihood of someone diving into the water in the middle of the night in mid-winter rather than looking at the incidences of diving during the summer months. Held: Appeal allowed. The test of whether a duty of care exists under s. 1(3) Occupiers Liability Act 1984 must be determined having regard to the circumstances prevailing at the time of the alleged breach resulted in injury to the claimant. At the time Mr.Donoghue sustained his injury, Folkestone Properties had no reason to believe that he or anyone else would be swimming from the slipway. Consequently, the criteria set out in s. 1 (3) (b) was not satisfied and no duty of care arose. 4. 1. 2. 2 Standard of care S. 1 (4) OLA 1984 – the duty is to take such care as is reasonable in all the circumstances of the case to see that the other does not suffer injury on the premises by reason of the danger concerned. Revill v Newber y [1996] 2 WLR 239 Court of Appeal Mr. Newbery was a 76 year old man. He owned an allotment which had a shed in which he kept various valuable items.The shed was subject to frequent breaking and vandalism. Mr. Newbery had taken to sleeping in his shed armed with a 12 bore shot gun. Mr. Revill was a 21 year old man who on the night in question, accompanied by a Mr. Grainger, and went to the shed at 2. 00 am in order to break in. Mr. Newbery awoke, picked up the shot gun and fired it through a small hole in the door to the shed. The shot hit Mr. Revill in the arm. It passed right through the arm and entered his chest. Both parties were prosecuted for the criminal offences committed. Mr. Revill pleaded guilty and was sentenced. Mr. Newbery was acquitted of wounding. Mr.Revill brought a civil action against Mr. Newbery for the injuries he suffered. Mr. Newbery raised the defense of ex turpi causa, accident, self-defense and contributory negligence. Held: The Claimants action was success ful but his damages were reduced by 2/3 under the Law Reform (Contributory Negligence) Act 1945 to reflect his responsibility for his own injuries. On the application of ex turpi causa Neill LJ: â€Å"For the purposes of the present judgment I do not find it necessary to consider further the joint criminal enterprise cases or the application of the doctrine of ex turpi causa in other areas of the law of tort.It is sufficient for me to confine my attention to the liability of someone in the position of Mr. Newbery towards an intruding burglar. It seems to me to be clear that, by enacting section 1 of the 1984 Act, Parliament has decided that an occupier cannot treat a burglar as an outlaw and has defined the scope of the duty owed to him. As I have already indicated, a person other than an occupier owes a similar duty to an intruder such as Mr. Revill. In paragraph 32 of their 1976 Report the Law Commission rejected the suggestion that there should be no duty at all owed to a trespa sser who was engaged in a serious criminal enterprise. Ratcliff v McConnell and Harper Adams College [1997] EWCA Civ 2679  Ã‚   Court of Appeal The claimant was a student at Harper Adams College. One night he had been out drinking with friends on campus and they decided they would go for a swim in the college pool which was 100 yards from the student bar. They climbed over a locked gate into the open air swimming pool. The pool had a notice at the entrance which stated the pool would be locked and its use prohibited between the hours of 10pm -6. 30am.There was a notice at the shallow end in red on a White background stating ‘Shallow end’ and a notice at the deep end stating ‘Deep end, shallow dive’. However, the boys did not see the signs because there was no light. The three boys undressed. The claimant put his toe in the water to test the temperature and then the three of them lined up along the side of the pool and dived in. Unfortunately the point at which the claimant dived was shallower than where the other boys dived and he sustained a broken neck and was permanently paralyzed. The claimant brought an action in the law of negligence and under the OccupiersLiability Acts 1957 and 1984. The trial judge held that the claimant was a trespasser since he was not permitted to go into the pool and that the College owed a duty of care under the 1984 Act since the pool had often been used by students in the prohibited hours so the College should have been aware that the claimant was within a class of persons who may come into the danger. The breach was in not taking more preventative action to prevent use of the pool. The claimant’s damages were, however, reduced by 60% under the Law Reform (Contributory Negligence) Act 1945.The defendants appealed contending the evidence relied on by the claimant in terms of repeated trespass all took place before 1990 before they started locking the gates. Held: The appeal was allowed. The cla imant was not entitled to compensation. The defendant had taken greater steps to reduce trespass by students since 1990. The only incidence of trespass to the pool in the four years prior to the claimant’s injury, related to students from a visiting college and therefore there was no reason for the college to suspect the students had come into the danger so no duty of care arose under s. (3) (b) Occupiers Liability Act 1984. Also the trial judge had incorrectly identified the danger. The pool itself was not dangerous it was the activity of diving into it which was unsafe. This was an obvious danger to which there was no duty to warn. By surrounding the pool with a 7 foot high fence, a locked gate and a prohibition on use of the pool in the stated hours the College had offered a reasonable level of protection. The duty may be discharged by giving a warning or discouraging others from taking the risk S. (5) Occupiers Liability Act 1984 – note there is no obligation in re lation to the warning to enable the visitor to be reasonably safe – contrast the provision under the 1957 Act. Tomlinson v. Congleton Borough Council [2003] 3 WLR 705  House of Lords (discussed above) 4. 1. 2. 3  Defenses Volenti non fit Injuria – s. 1 (6) OLA 1984 – no duty of care is owed in respect of risks willingly accepted by the visitor. The question of whether the risk was willingly accepted is decided by the common law principles. Contributory negligence – Damages may be reduced under the Law Reform Contributory Negligence) Act 1945 where the visitor fails to take reasonable care for their own safety. Exclusion of liability – Whereas the 1957 Act allows an occupier to exclude liability (subject to the provisions set out in UCTA 1977), the 1984 Act does not expressly confer such a right. This may be an oversight by the legislature and it may be possible to exclude liability since it is not expressly forbidden or it may be that the legis lature  was of the opinion  that it should not be possible to exclude liability for the basic level of protection afforded to trespassers. . 2 Liability for Manufacturers The narrow rule in Donoghue v Stevenson [1932] AC 562 recognizes that manufacturers owed a duty of care to ultimate consumers of the manufactured products. Over the years this duty was extended and refined and took on in practice some of the characteristics of strict liability. Parliament has now imposed such a strict liability on manufacturers under the Consumer Protection Act 1997.Although this act does not expressly have effect in place of the rules of common law( in the way that the Occupiers’ Liability Act do, in practice it affords more satisfactory remedies , and the narrow rule in Donoghue v Stevenson need no longer be studied in detail. 4. 3 Liability for employers An employee injured at work has three possible actions against the employer. i) An action in negligence for breach of the employerâ €™s duty of care. This is the concern this chapter ii) An action for breach of statutory duties imposed by parliament on the employer. The principles of the tort of breach of statutory duty will be explained later.The content of the various regulations prescribing safety equipments, clothing, procedures and so forth fall outside the syllabus and are part of a specialist course in employment law. iii) The employer may be vicariously liable for the torts committed by another employee. The principle of and the justifications for vicarious liability will be explained in detail later. For the present if is enough to note that an employer (even if not personally at fault) is in law answerable for the torts committed by employees in the course of their employment. The inter- relation between these actions is of some interest.Before 1948 an action based on vicarious liability was not available because of the doctrine of ‘common employment’. If A, an employee of X Ltd, tortu ously injured B, another employee of X ltd, then X Ltd would be liable to C, but not to B, because A and B were in the ‘common employment’ of X ltd. This doctrine provided protection for the employer against possible expensive tort claims. To offset this however the courts (a) modified the common law negligence action in a way that favored the employee and (b) permitted civil action for damages to be brought for breaches of safety regulations.The doctrine of common employment was abolished by statutes in 1948(Law Reform (Personal Injuries) Act 1948. So employees now have a vicarious liability claim and also the benefit of the modified common law action and actions for breach of statutory duty. The Nature of the Common Law Action The employer’s common law duty of care differs from the ordinary duty of care. It is said to be ‘non-delegable’. This is most clearly explained by Lord Hailsham of St Maryleborne in McDermid v Nash Dredging[1987] AC 906 as fo llows this special sense does not involve the proposition that the duty cannot be delegated in the sense that it is incapable of being the subject of delegation, but only that the employer cannot escape liability if the duty has been delegated and then not properly performed’. The facts of the case were that M was employed as a deckhand, by the defendants, but was sent by them to work on a ship operated by a different company (in fact the parent company of the defendants). He was seriously injured when the captain of the ship (not an employee of the defendants) carelessly operated the safety systems.The defendants were liable because their duty had been delegated to the employees of the parent company and not properly performed. Details of this area would be discussed when looking at vicarious liability. But in summary it is worth noting that employers owe a duty of care to their employees, but this duty is different in nature from the normal duty of care, being described as non-delegable. Court are now developing principles under which employees can also recover for the effects of work related stress. ==================================END========================================