Importance of Corporate Social Responsibility Essay

Q2) â€Å"Evaluate the relative importance of corporate social responsibility relative to other corporate objective† (40 Marks) Corporate social responsibility (CSR) is a firm’s decision to accept responsibility for its social, environmental and ethical actions. A firm’s decisions whether to adopt and rank importance to CSR should be due to a variety of reasons, like the financial stability of the company aswell as the culture of the organisation. But one definitive factor would be a firm’s corporate objectives, corporate objectives are a quantifiable statement of a business’s goals which should include measurable targets. Essay will look to examine the relative importance of CSR in relation to other corporate objectives. Many companies underlying corporate objective is profit maximisation, with this goal ranking higher than any other. This party due to the share holder value theory which makes profit a priority, therefore resulting in many firms qu estioning whether to become more socially responsible is worth the additional costs which would result in reduced profit for the company and key stakeholder’s groups. Primark offers a perfect example to this point, Primark is a retail firm in which offers exceptionally low prices through exploiting cheaper labour from abroad. If the company was to become more socially responsible they would have to sacrifice their unique selling point of low prices which may cause the company to fail. Thus proving how many businesses will see little importance in CSR relative to profit maximization. On the other hand companies whose key corporate objective is profit maximisation should take into account that CSR represents a long term commitment which can help to improve reputation and image of the company. This is due to consumers becoming more and more aware and concerned over where goods are sourced from and how they are made. CSR is therefore likely to route to profit maximization in the long term due to consumers now looking for socially responsible companies, which may rank over price therefore resulting in higher sales and therefore higher profit. This can be seen in the company Marks & Spencer who launched their bag for life campaign promising to reduce the wastage of plastic bags, and also presented an opportunity for Marks to charge for bags resulting in higher profits. Marks & Spencer is therefore a great example of a company who has looked to become more socially responsible and as a result improving their brand and reputation and even creating opportunities to improve profits, therefore demonstrating the relative importance CRS can have with profit maximisation. In contrast profit maximisation should always remain key as CSR in cases can only help to maintain brand value having little effect on overall profit maximisation. In addition, another key corporate objective is market growth, to gain market growth companies invest heavily in advertising costs amongst other promotional campaign, therefore leaving many organisation questioning whether CSR is another cost which is not sure to be beneficial to the business. However supermarket giant Tesco main corporate objective is market growth, but Tesco has recently reported that targets had been underperformed, therefore CSR could be important to this objective. During times of market growth CSR can act as a USP to differentiate the company from competition, which could be why marks & Spencer received higher profits this year after launching their bag for life campaign promising to cut down on plastic bag wastage. Due a recent change in customers views and attitudes towards the environment, becoming more socially responsible could be vital to gain an edge over competition when aiming for market growth. Then again CSR can be dependent on each individual company on whether it holds any importance to key corporate objectives. For example many oil companies whose product is in such high demand that it isn’t necessary for the business to adapt any CSR strategy as the product is so inelastic that people will by it regardless of image or reputation. This is controversially not the case for the oil provider giant BP who recently suffered a massive public relation nightmare after a massive oil spill, leading to a big hit in their reputation and brand image. BP has now ironically made CSR one of their core objectives to help rebuild the reputation and gain market growth. To conclude it is clear that CSR holds an apparent importance to other corporate objectives of a business, with it able to acting as a unique selling point for a business who is looking for market growth this can be seen in the company velvet who recently launched their triple velvet range which promised to plant a tree for every pack sold. CSR can also help in profit maximization as CSR represents a long term commitment which is likely to route to profit maximisation in the future and merits priority. But alternatively CSR is not a law requirement and has been proven that It is not always necessary depending on each company’s products, for examples oil is in such high demand that whether the company adopts CSR or not will not matter as the product is in such high demand it will be purchased regardless. Finally many companies already have a strong brand image and reputation so do not need to adopt CSR within their corporate objectives but can rely on other existing qualities to help to full fill objectives. For example apple offers a unique product with a strong reputation for quality and brand image. All of these factors can help to contribute towards profit maximisation, with image and quality allowing for increased added value to their products helping to increase profit margins. As well as strong brand image and loyal customer base helping to drive companies forward through times of market growth.

Cyber Bullying Essay Essay

â€Å"Give me some nude pics or I’ll post the picture of you last night at the party on Facebook †. This is an example of cyber bullying and nearly 43% of kids have been bullied online, 1 in 4 has had it happened to them more than once. However, you hold the power to change someone’s life with small actions. In other words, â€Å" Change can begin with simple actions/gestures â€Å". Nevertheless, everyone must be aware of how cyber bullying could affect somebody, to be alert of the situation, and how to prevent it from happening or helping a victim. Cyber bullying causes psychological, emotional, and physical stress. It can cause a higher risk of depression and anxiety. Being a victim of this abuse can lead to lower confidence, self-esteem, and your sense of security. It can affect your performance in school, also destroy your reputation, but worst of all, cyber bullying can lead to suicidal thoughts. Multiple teens have gave up their lives because of cyber bullying and for what ? A coward hiding behind a computer screen ? This needs to sto therefore if you stand up for your peers it does help and YOU can start a chain reaction. If you get trapped in cyber bullying, it is hard to get out because it is an on-going cycle and the bully can see you as a vulnerable target. It can affect you for the rest of your life if you don’t take action or help a friend. 1 in 10 victims will inform a parent or teacher, but what about the other 9 ? They hide it in until they are mentally suffering. We must change our actions and stand up to these bullies. Many others have been waiting for someone brave enough to take a stand, all it takes is one person and others may join to help stop it. However, if you are the victim don’t get deeply involved before its to late so show no emotion and interest in the situation and inform a trusted parent or guardian. One way to prevent cyber bullying is to know what to look for. Such as, signs of impression, harassment, and public humiliation. Afterwards, take immediate action. For example, attempt to identify the cause, stop responding to the bullies message, block the bully, change your account  settings and most importantly save the evidence. Next, get outside help but don’t wait too long or else it would be too late. If it gets that serious inform law enforcement. Finally, the best way to prevent cyber bullying would have nothing against you so the bully can’t work with anything. Also don’t participate in cyber bullying. For example, your friend is teasing someone online don’t participate, tell them to stop. If you stand up for others, others will too, it all starts with a simple action and people will join in. They are just waiting for someone brave enough. We must be aware of this situation and it all starts with a small action. If everybody joins in on this, those small actions can turn into a great opportunity to open the door and help these victims and resolve the matter. Everybody can help so we must stand by each other because together we are stronger. This is a serious situation and 90% of teens seen social-media bullying and said they have ignored it. We must change these actions to help our society.

Assess the View That Cults and Sects Are Only Fringe Organisations That Are Inevitably Short Lived and of Little Influence in Contemporary Society Essay Example for Free (#2)

Assess the View That Cults and Sects Are Only Fringe Organisations That Are Inevitably Short Lived and of Little Influence in Contemporary Society Essay Contemporary society (12) , Cult (8) company About StudyMoose Contact Careers Help Center Donate a Paper Legal Terms & Conditions Privacy Policy Complaints It can be argued that cults and sects are only fringe organisations that are inevitably short lived and of little influence in contemporary society, however some may have views to contrast this idea. A sect is an organization, which usually breaks off from an established religion, which finds itself in disagreement with beliefs and values of wider society and refuses to tolerate the beliefs of others. Although the desire to be a member is voluntary, as oppose to being born into, like religion, sects are rejected by society and claim strong obligation and commitment by its members. A sect is an extremely narrow-minded organisation, which is often led by a charismatic leader. Whereas, in contrast, a cult does not progress from a mainstream religion and does not reject or challenge societal norms. However, as tolerant of other beliefs as they are, they still attract a great deal of negative press, for example brainwashing. Members in a cult are usually more like customers than followers. An example of a cult is Heavens gate, which is a destructive doomsday cult, centered in California. There is a mass of supporting evidence that cults and sects are short lived and insignificant to wider society. Nevertheless, it must be maintained that the matter is complex as there are many sects and cults, which identify themselves differently. There is evidence to support this view of a short-lived nature of sects. This is due to many reasons. World rejecting sects, due to their nature and succeeding societal rejection and stigma of bad press, must be able to compromise with society and becoming a denomination and therefore cease to be a sect, if this is not done then the sect will die out. There is also an argument that sects cannot have a great deal of affect upon society over a long term period as they cannot survive past the charismatic leader’s lifetime and therefore sustain themselves over more than one generation. The American theologian Niebuhr theorises that another reason for transience of sects is that they rarely live past the 1st generation because the 2nd generation usually lacks the belief of the 1st. In this way, their membership dwindles as the 2nd generation chooses to leave the sect and hold other views in wider society. However Wilson disagrees with Neibuhrs view and says that he overates his case and chooses to not pay attention to groups who did preserve a ‘ distinct sectarian stance’. Similarly, evidence proves to discredit the belief that a sect fails to live on past their leader’s death. For example, The Mormons have continued for many generations and also the Amish- however this could be attributed to the protective ‘isolation-like’ in which they live. There is also a possibility that the Moonies surviving is due to the leader preparing for his son to take over his position as the charismatic leader after his death, however this is yet to be seen. Cults have seen a large incline in their number recently and because they are more accepting of wider society and despite receiving bad press, offer a practical solution to peoples’ issues and wishes, seem less likely to die out due to refusal and disapproval. They are also financially rather stable, the Church of Scientology for example has an estimated income of over  £200m per year. This is down to the consumer attitude of cults. There is also a mass of evidence for their importance in society in a sense that audience cults have a mass market of ‘self help therapy’ there are many books available for example, tarot reading, crystals and reflexology regularly appear on the best seller list and often more room is devoted to these books rather than Christianity books themselves. The view that cults are fringe movements is less supported than that for sects. Sects very infrequently continue on as sects but cults such as scientology are not only prosperous but also have a huge celebrity following trend; admired by the public for example Tom Cruise. There is also evidence that sects and cults can be of great influence to society – though it is debatable as to whether or not that is possible today in a society as apparently secular as ours. Weber suggests in his Theodicy of Disprivilege that because they offer a solution to problems: justification and explanation for life and its problems, to marginalised groups such as dropouts or ethnic minorities, world rejecting sects that offer status appeal to people. An example of this is Liberation Theology which was for the poorer people which had great influence upon the priorities of the Catholic Church in Latin America (though it has become more conservative, it continues to represent human rights and democracy). Bruce argues that it is not a religion and is instead a shallow, meaningless thing. Due to the elements of choice it offers, the choice about which bits to believe and whether to take its readings into account, it does not require commitment. This he argues prevents it having religious status. Post Modernists see it as being spiritual shopping: it is part of a consumerist culture. Despite not necessarily being a religion, there is lots of evidence to show that it has influenced society as a whole and, some sociologists would claim, aided secularisation. There is also evidence to show that it is unlikely to be particularly short lived as it fits in so well with our Capitalist, consumerist society and our individualistic values and is so profitable. Therefore, though there is strong evidence to show that sects and cults are ‘fringe organisations’, there is sufficient evidence to suggest that neither are short lived in themselves either through the Sectarian cycle or demand and supply (though sects tend to become denominations) and also to suggest that the influence of sects and cults on society is greater than expected; though the influence of sects and cults is exemplified by older examples and so one cannot be sure as to how successful they will be in today’s society, except in regards to specific sects and cults. In conclusion, the view that cults, sects are fringe organisations that are inevitably short-lived and of little influence in modern-day society, is on the whole not wholly correct but has some strength in that the permanency of all is arguable as is their status as fringe organisations. Assess the View That Cults and Sects Are Only Fringe Organisations That Are Inevitably Short Lived and of Little Influence in Contemporary Society. (2016, Mar 30). We have essays on the following topics that may be of interest to you

Global Business Assignment Example | Topics and Well Written Essays - 2000 words - 1

Global Business - Assignment Example Due to the economic performance of the three countries such as Mexico having the 14th largest nominal GDP, Spain having the fifth largest economy in the EU, and India having the 11th largest economy by exchange rates, it is clear that these nations follow the guidelines of the three international institutions that include the IMF, WTO and the World Bank. Amazon was chosen for this project due to its size and especially to find out how it has managed to become a leader in the Internet based market. The foundation of Amazon’s global business includes establishment in regimes that have transparent political institutions as well as functioning judicial systems. Within several previous decades, the three countries within which Amazon operates have exhibited tremendous economic growth. This is mostly because of the globalized nature of the trade that they engage in. The three nations have also established internal structures that favor globalization. This implies that these countries act as good markets for Amazon’s products. Mexico hosts several major automobile manufacturers that include GM, Chrysler, and Ford. This makes Mexico ideal for Amazon’s products in related fields. The booming pharmaceutical industry of India is expected, by 2020, to reach an estimated $48.5 billion. This is why Amazon has a specific interest in India. On the other hand, Spain is one of the countries where companies that include Ferrovial have achieved a global status from establish ing an ideal market environment for Amazon. These factors form some of the most important foundations of Amazon’s global business. This is because of the existence of functioning judicial systems as well as strong political systems in the involved countries. On top of that, these countries support and promote globalization through the establishment of capitalist mixed economic systems. The democratic mode of governance began in 1917 in Mexico following the

Easy Jet Essay Example | Topics and Well Written Essays - 1000 words

Easy Jet - Essay Example Suppliers: Suppliers play a major role in any business. The suppliers provide the right product, material or service on the right time. Suppliers in the airline industry need to be accurate and specific on the products and services required. The airlines which are already developed and working in the industry like Easyjet have relatively more power on the suppliers. However, the most critical supplies like the oil prices are highly depended on the cost which is determined by the political and economical issues prevalent in the country. Hence, the airlines and specifically Easyjet does not have any control over such supplies and their costs. Boeing and Airbus are the major suppliers of aircrafts in the industry up till now. This concentrated number of manufacturers gives the suppliers more power over the airline industry. Airbus and Boeing are the major suppliers of commercial planes in the industry. EasyJet is running the airline business using a single kind of aircraft. This factor limits its power over the suppliers as the prospects of high profits and sales from Easyjet are limited for the suppliers. However, if EasyJet moves towards expanding its operations and overall business expansion, it may have higher bargaining power over the supplies and services from the suppliers. ... The threat of substitutes is low due to the competitive advantage of timeliness and quick service of the airline industry. However, the existing competitors like RyanAir, are posing a threat to the success of EasyJet by offering discounts to increase sales, providing better and more comfortable services and so on. These competitors play a major role in deciding the future sales, business growth and decisions of the EasyJet. A change in the price or nature of services of one airline business places a burden on the other to provide equal or competing options to attract customers. Hence the analysis of competitors, their strategies, cost cutting ways and factors increasing sales are of paramount importance for EasyJet (Mayer 2003, pp. 9-11). Distributors of EasyJet mainly consist of Internet Booking System and Telephone reservation Systems. These two modes of distribution are easy, user-friendly and flexible for the customers. These modes can be accessed anywhere and with minimal time t o process their request. These distribution modes are technologically equipped and hence less chance of error or frauds are present. Since 90 percent of EasyJet’s sales is acquired through internet Booking systems, the business is highly dependent on it. This distribution channel may harm the business’s reputation if some error occurs within the electronic processing of requests. It is however justifiable to believe that these distributors of EasyJet’s services play a major role in the company’s cost-effective plans (Mayer 2003, pp. 9-11). EasyJet offers low cost airline services to its customers. The customers who opt for such low cost services are more price conscious.

CriticalThinking Essay Example | Topics and Well Written Essays - 500 words

CriticalThinking - Essay Example This will probably be a rural setting and thus may feel inferior while speaking the formal language. On the other hand, the person who prefers the formal language may be from an urban setting and thus more exposed than the letter. The argument above clarifies to us how the language spoken may say almost everything concerning our values and affiliations (Fisher 43) . Consequently, it is indispensable for one to be vigilant on which language to use when he wants to portray a specific impression. It is also evident that anyone who ignores this is either a child who is naà ¯ve or a drunkard who is simply careless. On the other hand, considering the views of another philosopher, it is very necessary, if we consider objective analysis of views before accepting them as lies or truths. To begin with, we look at a situation were by an individual is giving a testimony in a court of law. In this case, the judge must be careful, analytical and sensitive in order to give a fair judgment. He must make good use of critical thinking, in order to achieve this. In this context, we must make use of certain critical thinking facts, such as having a good understanding of things that may influence our judgment. Some of these factors may include Perception, which is something that may come up in our mind in terms of an impression (Fisher 99). Depending on our upbringing, there are things that we grew to learn as either wrong or right. Dogmatism where an individual only wants to believe in only what he knows and does not want to know anything knew. An individual’s past experience will always influence his thoughts and decisions. For instance, a child who fell from a tree when he was young will always avoid climbing on trees, or if he does climb on one, he will be very careful. These factors will always influence once decisions, and as a result, one must consider them (Fisher 63). In this case, the judge must be able to observe and

In Hospitality Industry, Which International Skills, Knowledge, Essay

In Hospitality Industry, Which International Skills, Knowledge, Behavior And Experience Could be an Advantage In the Development of Future Career - Essay Example This paper stresses that relative to the nature of cross-cultural management, the best skills, knowledge, behavior and experience that could be advantageous in the development of future careers in hospitality revolve around understanding Cultural Intelligence (CQ). Based on Arora and Rohmetra’s (2010) explication CQ entails the ability to exploit the knowledge and skills across state, ethnic and culturally diverse workforces. The overall understanding of Cultural Intelligence principles gives management and leadership teams a selection of perceptions that could apply efficiently, in diverse environments through understanding and management of consumers, individual employees or groups. This report makes a conclusion that as a hospitality practitioner should be on understanding, particularly the cross-cultures and performance on the international platform. Misunderstanding does not occur among managers alone; it can be prevalent amongst employees or employee and customers. Generally, a greater part of hospitality is about service provision thus without communication and strong relationships, there are limited chances of success. Nonetheless, Cultural Intelligence proves to be effectual when managing cross-cultures. The divisions provide an easy breakdown and gives detailed approaches for the common situation. Using the four divisions as the core guideline will facilitate additional knowledge, skills, behavior and experience enhancing my overall performance and progression in the hospitality industry.

Supply chain management in the uk construction Industry Essay

Supply chain management in the uk construction Industry - Essay Example According to the Council of Supply Chain Management Professionals (CSCMP), â€Å"supply chain management encompasses the planning and management of all activities involved in sourcing and procurement, conversion and all logistics management activities† (Council of Supply Chain Management Professionals, n.d.). In addition to these, SCM also includes collaboration and coordination with channel partners which includes suppliers, customers as well as intermediaries. The council also says that the supply chain management also plays a crucial role in integrating demand and supply management across and within the companies. According to James B. Ayers, supply chain management is all about â€Å"designing, maintenance and operation of supply chain process, including those that make up extended product features, for satisfaction of end-user needs† (Ayers, 2000). Over the past few decades various techniques regarding supply chain management (SCM) have been used successfully in different industries like manufacturing and food. In these industries, the supply process encompasses all those activities that are associated with the processing – from raw materials to the finishing of the final product. The entire process involves procurement, production scheduling, inventory management, order processing, storage, customer service, transport and all the supporting information systems. Roy Morledge, Mohieddin Grada and Andrew Knight opined that in manufacturing industry, supply chain management strategies are adopted assuming that it is â€Å"an ongoing process where supplier and customer experience involves frequent transactions for the same or similar products† (Pryke, 2009). SCM strategies are considered as the key in maintaining quality and making the innovation process easier. Each of the aspects through which SCM is integrated wit h the manufacturing and food industry can be discussed in the

Forced Marriages and UK Law Essay Example | Topics and Well Written Essays - 4000 words

Forced Marriages and UK Law - Essay Example This essay stresses that forced marriages involve the use of threats to get people to enter marriages against the will. Existing UK laws on marriage render such marriages null but voidable. There is no existing criminal liability for partaking in the imposition of forced marriages. Legal reforms have created a civil provision to combat forced marriages. However, this leaves much to be desired. This is because there is a general problem of fear and sympathy for perpetrators by victims because of the familial links that exist between them. In order to prevent forced marriage, it is recommended that there should be a separate criminal law that would complement the criminal statute. Debate should however continue on this subject. This is necessary because there is the need for new issues and situations in the UK society to be integrated into the legal statute to protect the vulnerable appropriately at every point in time. This paper examines forced marriages in the context of UK law. The aim of the paper is to evaluate how sufficient the laws on forced marriages in the UK are. This paper makes a conclusion that the UK House of Commons identified that domestic violence and forced marriages are the main challenges to family law in the UK in recent times. The UK recognises forced marriage as a form of domestic violence and child abuse. The UK social and legal system makes a sharp distinction between forced marriages and arranged marriages . This distinction is necessary because arranged marriages have a bit of a different legal position in the UK society. This is mainly steeped in the concept of choice. Whereas the parties in an arranged marriage might choose to live within the marriage without any duress, a forced marriage is one where one party is forced or coerced into the whole union. 'Duress' defines the main basis for the definition of a forced marriage. As such, a marriage in which duress is not used to coerce one or both parties into the marriage is valid socially, morally and legally in English law. 2.2 Forms of Forced Marriages There are three main types of forced marriages6: 1. An individual who fears that s/he may be forced to marry in the UK

Is judicial review consistent with democratic ideals Term Paper

Is judicial review consistent with democratic ideals - Term Paper Example For Marx and Engels, there is no supernatural being, only matter exists and as such, humans are alienated from material conditions. In this case, alienation is only eliminated when true freedom is achieved The first premise of this theory therefore, is the existence of living human individuals who then engage in economic activities for their subsistence and in the process develop relations that form the basis of legal and political superstructures. However, to achieve freedom societies go through conflicts or class struggles whereby the ruling class is overthrown and new order established. So according to the Communist manifesto by Marx and Engels â€Å"the history of all hitherto existing society is the history of class struggles.†1This struggle or historical process ends when man achieves true freedom through a socialist state or communism. The theory is well expounded in the Preface to A Contribution to the Critique of Political Economy written in 1859 by Marx. While this t heory has gained a lot of prominence over the years, it has been under scrutiny for decades owing to the failure of communism in the Twentieth Century such as in the Soviet Union and emergence of states that do not conform to Marx’s theory such as in China. The insistence on the role of economic forces in shaping history has also been disputed by sociologists over the years. Despite all these criticisms, it is apparent that historical materialism can withstand the test of time and continues to be relevant even today. This paper will discuss the primary features of the theory as an account of historical development and change. It will also evaluate the strengths and weaknesses of the theory in explaining historical development. To do this, I will utilize the works of Marx and Engels such as the German ideology, communist manifesto, a contribution to the critique of political economy and theory of surplus value. To understand the theory of historical materialism, it is essentia l to understand the theory upon which it is based and that is the dialectics by Geog Wilhelm Friedrich Hegel. Hegel was a German philosopher interested more on ideas as opposed to the reality thus the use of dialectical methods. This dialectical method is the foundation of Marxism. According to Hegel, there exists a supernatural being beyond the reach of human beings. Humans are separated from this supernatural or Absolute and can thus only perceive the world through economic and material lenses and reality is turned upside down by perceptions.2 According to Hegel, humans can only be reunited with the Absolute through a historical process and once they are reunited, it is the end of history. This progressive movement towards the Absolute is aided by the dialectical process which according to Shimp involves increasing awareness thus gradually replacing man’s perception of reality with newer and truer forms.3 For dialectical process to work there must be contradictions which he refers as thesis and antithesis. The thesis is higher in rank than the antithesis but in the process of competition, the antithesis overthrows the thesis and a new thesis or synthesis is achieved. The thesis and antithesis are not opposites in the real manner but are oppositions such as a master and servant and wherever there is a thesis, there must be an antithesis. As such, when a new thesis is established, a new antithesis emerges to compete with the thesis and the process

Feminist Philosophy Essay Example for Free

Feminist Philosophy Essay Mary Wollstonecraft was no doubt a great feminist and deserved to be called grandmother of the feminist thought. Her early experiences of an unsuccessful family life as well as the prevailing notion of the philosophers at that time about women shaped her views to become authentic feminist grand mother. Wollstonecraft’s feminist ideas affected the first wave of feminism through her arguments against the prevailing views on women most notably that of Rousseau’s which categorized women as subservient to men. Rousseau held that women’s education should be designed entirely to make them pleasing to men. Rousseau reflected â€Å"to please, to be useful to us, to make us love and esteem them, to educate us when young and take care of us when grown up, to advise, to console us, to render our lives easy and agreeable—these are duties of women at all times†¦Ã¢â‚¬ (Feminist Philosophy). Against this view, Wollstonecraft work hard to emphasize that the role of women in the society were not simply an ornaments and playthings of men as they are also capable of attaining masculine virtues of wisdom and rationality â€Å"if society would allow those value to be cultivated† (p.475-476). Wollstonecraft pointed out that the prevailing views on women had bad implications not only on women but on society as well as they will only breed bitterness, jealousy, and folly. She affected the first wave of feminist by encouraging them â€Å"to restore women to their lost dignity by encouraging better ideas of woman hood† (p. 476). How did Simone de Beauvoirs writing shape the second wave? The second wave of feminism was a resurgence of early feminism as a result of various works of feminists during the 1940s such as her works. De Beauvoir writings shaped the second wave of feminism by shedding light about what is a woman in the concept of being other, and how men views women during this period. In her writings de Beauvoir shed social understanding on womanhood. She pointed out that the fundamental social meaning of woman is Other. She explained, â€Å"No group ever sets itself up as the One without at once setting up the Other over against itself† (p. 479). The thought that de Beauvoir was pointing out was that men do not view women as human being like them but as Others who are to be treated as stranger that do not deserve equal treatment. The implication of men’s treatment of women as Others according to de Beauvoir was that because women are others, they do not need to be given â€Å"equal weight to their preferences† simply because they are others (p. 480). Debeauvoir’s writings shaped the second wave of feminism through her unique way of providing social understanding about how women were regarded by men during this period. How did the events of the first and second wave affect each other? Apparently, the event of the first and the second wave of feminism affect each other in a way that they connect the second wave to the first. The second wave feminist was inspired by the events during the first wave to tag along their path of pushing for the recognition of women’s rights. Apparently, the events of the first wave feminist shaped the understanding of the second wave feminism about women’s rights, against the existing social and philosophical views on women. Thus, the events of the first wave serves as mirror for the second wave, and as inspiration for them to continue women’s struggle for the restoration of their lost dignity as women equal with men in many aspect, especially on human rights. Reference More-Bruder: Philosophy: The Power of Ideas (2008) Feminist Philosophy The McGraw-Hill Companies

Communtiy service assignement Essay Example for Free

Communtiy service assignement Essay In your own words, answer the following questions. 1. What does the term ‘risk of significant harm’ mean? Answer q1. If the circumstances that are causing concerns for the safety welfare and wellbeing are present to significant extent. 2. What are the types of child abuse? Answer for q2. 1.physical 2.sexual 3.neglect 4.phychological 3. Identify three possible indicators or signs for each type of child abuse/neglect. Answers q3 1 physical bruising behaviour problems depression anxiety 2 sexual bed wetting ,nightmares , scared of people touching them 3 neglect can be unbathed dirty, little to no food ,too big or small clothing thats dirty 4. What does the term ‘mandatory reporter’ mean? Answer q4 a mandatory reporter is a person that delivers health care education or children services to a child/ren under 16 and authorise by the department community services and required to make reports 5. Why is it important to adopt an ‘interagency approach’? Answer q5 1,promoting a partnership approach to child protection Task 2 Read the case studies below and answer the questions that follow. Jamele You are a worker in a family support agency. Your service offers facilitated playgroups each week to young and isolated mothers. Jamelle is a 1year old and attends each week with her mother. Jamelle is a very timid and does not interact with other children during play time. On a few occasions Jamelle has arrived with several large bruises which Jamelle’s mother has explained as accidents that had occurred whilst Jamelle was attempting to walk by  herself. Jamelle often arrives smelling strongly of stale urine and appearing dirty and unwashed. When they arrived today for the playgroup Jamelle had bloodshot eyes and was very drowsy. Jamelle’s mother reported that Jamelle had not slept well that night and would probably need a lot of sleep today. During the session Jamelle began to vomit. 1. What are the indicators of risk? Answer q1. 1.neglect 2.abuse 3.suspected risk of significant harm 2. How you would respond to this situation? Answer q2 1.document and report to supervisor 2.investigate or possible involvement of police and DOCS 3.call ambulance to protect the health and safety of the child 3. How would you prepare to make a report? Answer q3 1. time and date sign all documented 2.follow all policy and procedures in your work place 3.details of child ,dob name , address phone number, parent or carer if child has disability any back ground if known 4.document what the mother has stated 4. Who would you notify and when? Answer q4 1.immediately discuss situation with your supervisor after you suspect the abuse to the child 5. What actions/work practices you would take as a follow up from the report. Answer q5 1.offer support and help for family 2.services for family eg counselling parental courses 3.comply with your work place policy and procedures Taj You are case worker in a local service that supports families where one of the parents has a mental illness. Your service offers a range of support services, one of which is a weekly support group for children aimed at  reducing isolation and developing coping skills for dealing with a parent with mental illness. Taj is a 10 year old boy who attends the service weekly. Taj is popular with both the staff and his peers and likes to participate in most activities. After the last school holidays, Taj returned to the service a changed child, he has become aggressive and picks fights with his peers. He has also become aggressive towards the other male worker and is isolating himself. Taj has started wearing jumpers and long pants, even on warmer days and refuses to remove any clothing when he shows clear signs of being overheated. During an activity, Taj’s jumper became caught on the table and pulled up revealing a mass of red welts and recent burn scarring on his stomach and back area. Over the last few weeks Taj has drawn some explicit sexual pictures during art activities and has been using very sexualised language. 1. What are the indicators of risk? Answers q1 Aggressive behaviour, picks fights, red welts, bur ns 1.physical 2.sexual 3.neglect 2. How you would respond to this situation? Answer q2 1.ask taj whats happening while on school holidays also contact the family 2. report and document speak to principal and report to your supervisor 3.make a child proctection report to DOCS and police 3. How would you prepare to make a report? Answer q3 names and addresses of the child and his parents or responsible caregiver(s) childs age and gender nature and extent of injury, maltreatment or neglect   approximate date and time the injury, maltreatment or neglect occurred the circumstances in which the injuries, became known to case worker previous injury, abuse/ neglect of the child or siblings  name of the person suspected to have caused the injury, sexual abuse/ neglect any action taken to treat or help the child and sign   any other information the caseworker believes would be helpful What actions/work practices you would take as a follow up from the report. 1 your repsonsibilty regarding the safety welfare or wellbeing of the child does not cease once report has been made docs it is still your responsibilty to use professional resources to provide support appropriate to your role and identify and respond to any concerns for the young childs welfare Karli Karli is a 16 year old resident in a youth refuge. She is quite precocious and outgoing with all the residents. After the first few days, you noticed that she was flirting with one of the male youth workers. This is not an unusual situation and generally does not create major issues. Expectations that staff not engage in any relationship other than a professional helping relationship are clearly outlined in the agency code of conduct, staff recruitment and ongoing professional development and training. You have noticed over the last few weeks that the worker Jackson appears to be flirting back. You have noticed that there is a lot of incidental touching between them and while you have seen no touching that is clearly inappropriate you can â€Å"feel† a lot of sexual energy between them when they are interacting. You have tried to raise it in discussion but Jackson is dismissive and will not engage on the topic. 1. How you would respond to this situation? Answer q1 1.follow your work place policy and procedures 2.report incidents of your observation to your supervisor 3.discuss your concerns with jackson and karli 2. What ethical issues may arise when responding to these situations? Answer q2 1.breaching the client and workers code of ethics 2.client history and vulnerability and mental status 3.disscussion of sexual or romatic relationship have occurred 4.conflict of interest 5.mandatory and disciplinary action for the case worker Task 3 Read the scenario below and answer the questions that follow. Joseph Personal Information about Joseph Date of Birth: 31/10/04 Full Name: Joseph Timothy Drake Address: 13 Short St, Parker Languages spoken: Chinese and English Nationality: Chinese Other children: Only child Mother: Lis’s (09) 7476 9435 Partner: Jake (no number provided) You are a community worker in a multicultural resource centre. Your service runs a range of programs to support and assist people from culturally diverse backgrounds. Many of your clients have limited social resources and one of the programs that is offered is a women’s friendship group which aims to reduce the isolation of women. Lis attends the friendship group each week. Lis lives with her son, Joseph who is 5 years old. She has had a series of failed relationships and is currently seeing Jake who you have never met. Lis has engaged you in a number of conversations over several weeks, where she often breaks down and discloses details about fights she has had with her partner. Last week, Lis recounted the events of the previous weekend, when she forgot to leave the key under the door mat and so her boyfriend broke the front door and came in yelling at Lis. Joseph was still up with her at this time, and Lis continued to say that she was worried Joseph had seen her get hit several times by Jake. Lis appears increasingly concerned that he might do something to Joseph as he keeps threatening her and arriving late at night after drinking. This week Lis turns up to the group with Joseph, although children are not part of the group. Lis mentions she is very upset as Jake had come home late again and there had been some trouble. During the group you notice that Joseph is aggressive with Lis and does not engage with other people. At one point Joseph wets his pants and you organise for a change of clothes. While Lis is changing Joseph you notice a large impact bruise on his back. When you approach Joseph lashes out. 1. Where would you find information on how your service responds to Child Protection issues? Answer q1 1. document and report to supervisor the worries and fears mother has for herself and joseph 2.ask mother consent to fill out incident report 3.mandatory reporting guide 4.multicultural services,internet/google 5.child protection helpline 2. List the legislative acts that govern Child Protection Services in your state/territory. Answer q2 1.family law act 1975 2.law reform act 1995 3.family law amended act 2006 4.national quality standards 5.onbudsman amendment act 1998 6.children and young person (care and protection) act 1998 7.children legislation amendment act 2009

Exploring The Dark Side Of Globalisation

Exploring The Dark Side Of Globalisation Propose reasons why some believe that the current form of globalisation has brought poverty and hardship to millions of workers. Globalization and types: According to Joseph Stiglitz, Globalization is the closer integration of the countries and peoples of the world brought about by the enormous reduction of costs of transportation and communication, and the breaking down of artificial barriers to the flows of goods, services, capital, knowledge, and people across borders. Furthermore, globalization has been explained in the following ways. Economic globalization means the greater global connectedness of economic activities, through transnational trade, capital flows and migration. Environmental globalization could include the increasingly global effects of human activity on the environment. Cultural globalization may highlight the connections among languages, ways of living, and fears of global homogeneity through the spread of North American and European languages and culture. Political globalization may include wider acceptance of global political standards such as human rights, democracy, labor standards, environmental standards, a s well as the greater coordination of actions by governments and other institutions across the globe.  Hence it is understood that globalization has been seen classified into the four categories as economic globalization, environmental globalization, cultural globalization and political globalization. [1] Causes for globalization: Most of the businesses tend to transfer their business to other countries and follow one of the many approaches (reactive, defensive, proactive, etc.) so as to sustain in the competition. Hence they make their business global. Some of the reasons for this globalization have been identified to be Trade barriers Meeting client demands Globalization of competitors Regulations and restrictions Companies mostly run their business local to their customers so that they are free from the many difficulties of facing expensive exports, shipping costs, labor cost, reliability issues, tax and others. Also, the clients (from abroad) highly demand their suppliers to stay local so that the production flow is strengthened. Hence the suppliers, who do not want to miss out on their good business deals, agree to their clients in making their business local to their clients. Next, the companies know that if their business flourish for long in the foreign countries without any challenge then their contribution to the business in the world market would be too tough to beat them and hence they act quickly. Also, the companies would be interested in investing the profits gained from their business to be used for further growth and enhancement of their business. But not all the business home-government let their business to carry on easily without imposing the severe rules and regulations whic h eventually results in slowing down the growth of the business, invading the profits of the business and making their costs highly unmanageable (by levying high tax). Hence the companies tend to move abroad and flourish there where they would be liable to fewer restrictions and barriers than in their home country. [2] Hence globalization has been achieved greatly due to the above mentioned reasons and other real good factors such as enhanced technology, quick and easy communication, convenient ways of sharing information, easy shipment and travel, attractive incentives by foreign governments, etc. [3] Impact of globalization: So far the reasons for globalization were discussed and now the effects of globalization are being explored. Globalization has resulted in both positive and negative effects, some of which are listed below. Pros of globalization: Globalization has increased the competition level and has put the domestic companies into the tough competition to produce high quality products and excellent customer service so as to fight against the international markets and stay in the competition. Hence people are benefitted by the good quality of products. Globalization has left a positive impact of foreign trade on an economy. Earlier people had to perform uncivilized activities to get what they wanted, whereas now the scenario has been changed and dealt with in a humane way. Definitely globalization has hugely resulted in the spread of the culture. Today most people are happy to receive people from all around the globe and enjoy the diverse culture, be it cooking, language, costumes, etc. Globalization has resulted in the sharing of technology and information across the globe amongst all people. The technology that was invented at one place doesnt stay just there and people around the world get to benefit from it as a result of globalization. Also globalization has resulted in the spread of knowledge and education. Today people move abroad to specialize in a particular field which is because of globalization. Many nations help each other in sorting out the problems caused to environment and nature (such as climate control, preserving wildlife, etc.) through globalization. People can enjoy the easy availability of products from a different country in their own land and also there is a steady income to all the developing countries. [4] Some of the cons of globalization: People in their own country are more unemployed as the manufacturing jobs are being outsourced to the developing nations and countries where the labour is comparatively cheap. Even the employed are suffering job insecurity due to the heavy competition and experience a lower standard of living. Hence millions of workers are facing hardships due to globalizations. Globalization seems to compromise in the safety standards of people through the exploitation of labour to produce cheap goods. Terrorists are likely to have easy access for the sophisticated weapons and technology and easy communication amongst each other. Serious diseases have been believed to spread due to travellers coming from various parts of the world thereby risking the health of local people. Finally, one of the most serious effects of globalization is that it has resulted in poverty which could be related to the unemployment and the reduction in the standard of living as discussed previously. Poverty and hardships faced by workers due to globalization: The effects of globalization have been discussed. Clearly, the negative effects of globalization have stated that globalization has resulted in poverty and also hardships faced by the workers. Now we look more into detail how globalization has led to such an impact. Though globalization had promised to connect the world closer, there are many policies and practices and decisions behind the scene which are totally under control by the rich (multinationals, institutions, and powerful people) only. As a result the governments of the poor nations are being overpowered by these global people and hence they continue to struggle in their poverty whilst the rich continue becoming richer. [6] It has been described in the positive effects of globalization that the domestic companies are facing tough competition in order to survive, which clearly is a negative impact too. Also, the many multinational companies who are quickly emerging in many developing countries due to many reasons discussed under the causes for globalization manage their businesses with assets, managers, important research and development activities all located in their own home countries only. So this kicks out the local companies out of the business and results in poverty. The money spent on welfare services is very limited. The government does not have much money to spend on welfare services and the local organizations and businesses have the control in their hands. Also globalization has encouraged economic policies which pressurize the developing nations to restrict the amount being spent by the government on welfare services. Thus this limited spending on welfare services further heightens poverty. There has been a rise in wages (in developed nations) for the highly skilled labor whilst the labors those dont have much education suffer poor wages or unemployment and are in less demand. Another reason is because of these developed nations trading with the developing nations because of which the low skilled labors immigrate to the developed nations and therefore widening the wage gaps. Additionally there are more people who are being underpaid and lead lower standards of life and the highly skilled people who move out of the developing nations due to the lack of education. This in turn widens the wage gaps. [7] It is very unlikely that the poor people would benefit from the profits made through globalization because of the complementary policies that is being imposed. These complementary policies include investments in human capital and infrastructure, policies that promote credit and technical assistance to farmers and policies to promote macroeconomic stability. [8] Does Globalisation Help or Benefit the poor: There is no single answer to the above question as the answer is a two way answer. The poor may in many countries benefit from: Increased Jobs Cheaper consumption Oppurtunity for education, savings and entrepreneurship In other scenario: Workers are displaced by imports and job losses Poor consumers pay more, not less for what they were asking for. On average countries that have cuddled globalization which have done better on the whole than compared to those who have not. Within those countries, economic growth has raised incomes at all levels including the poor. Some countries have done an exceptional job in exporting their goods to the rest of the world like South Korea and other Asian countries. And many poor countries chose not to participate in global trade liberalization which one became the factors for the other poor countries to get rid of the poverty. Other countries who participated in the global trade liberalization have earned some good profits by adopting the global trade liberalization and to kill poverty from their countries. In General Globalisation alone is never enough to cure poverty because other than globalisation there should be some other things which should be there in the world to reduce poverty from the nation. Some of the other things needed are; Investment in capital and infrastructure Education to one and all in order to kill the poverty. Education is the most important factor which will be playing a major role to get rid of poverty as if education ratio is good in the world for sure there we can see decrease in the poverty. Good Governance means there should be a good and strong government put in place to control and run the system. Below graph shows the average drop in poverty rates in countries such as China, where Globalisation has stronghold where compared to areas unaffected by Globalisation such as Sub-Saharan Africa and rest of the world according to Jeffrey Sachs Globalisation advocate. C:UsersSameerDesktopglobalisation_clip_image003.gif Source: http://www.studygroup-bd.org/globalisation.html Negative effects on businesses due to Globalisation: 1. There was a rise in labor demand and at the same time rise in wages was also seen in almost all businesses across the world. 2. Trade unions powers were weakened over the labor in all technological industries like Mobile Services, Insurance, Internet and Mobile Services and Entertainment. 3. There was lot of competition was seen at the time of Globalisation leading to pressure on raising productivity, improving product quality in order to stand in the market. 4. In many public sector units Voluntary retirement was seen. 5. In order to raise the sales door to door marketing was compulsory, in result businesses appointed sales person in large numbers. 6. Growth of consumerism.   7. Volatility was in profits because of the choice from the customers as there was too much selection for them. 8. There was a rise in import from other countries particularly in those companies where United Kingdom was very much famous like textiles and clothing.   9. Problems of dealing with improbability in the international market in terms of demand, supply and prices. 10. Competitive pressures were increased due to globalization on british businesses. But the truth is there are hardly any real negative effects of globalisation compared with the pre-globalisation period.  Notwithstanding the low level of globalization of world economy, the result of globalisation has been very much positive in all most all sectors of economic and social life and almost no negative effect. It is only because of opening of the hitherto closed, govt.-oppressed and controlled economy to the process of globalisation that has helped Indian economy to grow rapidly in the last 10-12 years, Worlds economic growth has been high, exports was very much in all neighbouring countries the product they wanted and finally incidence of poverty was reduced, employment was the main concern of many countries, begging by many countries for economic aid has stopped but there was need for some other countries which were in very much need of economic aid than finally the long-term inflation rate was down to earth, insufficiency of goods have disappeared, the superiority of products available have better significantly and overall all the countries has become progressively energetic and internationally competititive. Effect of globalisation on many industries has been very positive, though some industrial companies with the baggage of high cost, inefficient plants and processes inherited from the past because of closed economys government dictated industrial policies and priorities had to face serious problems in the beginning. But soon most of the industries have become more and more efficient, customer alert and improved their international competitiveness in terms of costs, prices, product quality and variety. Industrial growth has been very high and strong during the past decade because of globalisation. Exports have increased tremendously. Industries expanded abroad. Most of the foreign companies increased their investment in many money making industries which lead to many employments for the people leaving in that particular industrial areas who were jobless for the most of the time were getting jobs with some good wages because of the foreign companies investing their money for some good p rofits both were equally profited. Strikes by the unions have gone down low levels because of the industrial labor was happy what they are getting and the way they were working. Those who cannot be efficient and past their prime age to retrain themselves in modern methods and processes have been retired with very attractive voluntary retirement schemes. The trade unions were finding it difficult to influence industrial labor into protest because labor has started benefiting from the positive benefit of globalisation on the wealth and growth of the industrial sector. Talented labor is commanding premium compensation in the labor market. Several new type of industries were came into action started their small business. Small scale industries which were opened years back started growing fast as the people started to work for small scale industries as they stopped craving for MNCs because of which these industries have fast grown into medium scale companies. Incidence of industrial sick ness has gone done radically.[9]

Point of View in Shirley Jacksons The Lottery Essay -- Shirley Jackso

Point of View in The Lottery Shirley Jackson's "The Lottery" uses the third-person dramatic point of view to tell a story about an un-named village that celebrates a wicked, annual event. The narrator in the story gives many small details of the lottery taking place, but leaves the most crucial and chilling detail until the end: the winner of the lottery is stoned to death by the other villagers. The use of the third-person point of view, with just a few cases of third-person omniscient thrown in, is an effective way of telling this ironic tale, both because the narrator's reporter-like blandness parallels the villagers' apparent apathy to the lottery, and because it helps build to the surprise ending by giving away bits of information to the reader through the actions and discussions of the villagers without giving away the final twist. "The Lottery" is primarily told in the third-person dramatic point of view, but on occasion the narrator becomes omniscient to divulge information to the reader that which is commonly known to the villagers. In paragraph 7, for example, the ...

Character Analysis : Dimmesdale :: essays research papers

Character Analysis : Dimmesdale Dimmesdale is one of the most intriguing characters in The Scarlet Letter. I think this because he demonstrates in this story that he is a coward, and that he is strong, yet not courageous. Dimmesdale proves that he is a cowardice individual many times in The Scarlet Letter. He does this by not admitting his sin. Dimmesdale had many opportunities to admit his sin and get the guilt off his chest. The first opportunity was when Dimmesdale was making his speech in front of an audience. He tried to tell the truth but more lies just came out. The second opportunity that Dimmesdale had to confess his sin was when he was living with Chillingworth, and Chillingworth told Dimmesdale to confess what was troubling him and again, Dimmesdale refused to confess. Finally, the third time that Dimmesdale had a great opportunity to confess himself was at the end of the story during the festival on the scaffold. Standing there with Hester and Pearl, Dimmesdale was still too much of a coward to admit his sin and release the anguish from his burning chest. Another way in which Dimmesdale showed that he was a cowardice person is by not confronting Chillingworth. Chillingworth was plotting re venge on Dimmesdale for an extremely long time. In fact, Chillingworth’s life was devoted to getting revenge on Dimmesdale. Being told by Hester, Dimmesdale still did not confront Chillingworth. Throughout the book, Dimmesdale was an extreme coward. Dimmesdale’s actions in this story where not courageous, but strong. For roughly seven years, this man had to live with extreme guilt. Dimmesdale had many reasons to feel guilty. First of all he let Hester be labeled an adulteress, while he just looked on. Lastly, Dimmesdale felt guilty because he had not raised Pearl as his own. Dimmesdale showed this by being exceptionally affectionate the few times that he was around Pearl. An example of Dimmesdale showing affection towards Pearl is while in the forest, Dimmesdale softly kisses Pearl on the brow. Another action of Dimmesdale’s that proves that he is strong but not courageous, is that Dimmesdale shows extreme self-restraint. Dimmesdale had to converse with Hester in public.

Hannibal :: essays research papers

Hannibal-RPR In Thomas Harris' Hannibal, Harris, like many other authors, seems to be obsessed with the darker side of humanity and it is through his characterisation of "Hannibal the Cannibal" in his novel that he revels the other side of humanity, the side that most people would rather stayed locked up. Hannibal however would not stay locked up. In the previous novel "Silence of the Lambs" Hannibal escaped during a transfer from his cell in Baltimore to an institution Memphis. He lived a quiet and secluded live after escaping, he'd been careful, and had never been tracked. He had been careless when he sent a letter to Clarice. During a drugs raid Clarice shot drug baron Evelda Drumgo after she shot an officer. Evelda was holding a baby and the media did not publicize well the shooting of a woman clutching a baby. It was this that alerted Hannibal to Clarice's misfortunes and lead him to sending the letter that would revel his location and eventually lead to his capture. His capture was not by authorities but by Mason Verger, Hannibal's only surviving victim who now needs a respirator to live and can very rarity leave his chamber. Mason did not have him captured to hand over the authorities but to have his face eaten by pigs like mason had his face eaten off by dogs. Before Mason had a chance to have Hannibal's face eaten off Clarice Starling breaks into the barn, proceeds to rescue Hannibal but unfortunately before she can rescue him she is shot in the back with a tranquilizer several times and Hannibal has to rescue her. Hannibal takes her back to his home to recover and by the time she is recovered her and Hannibal get along well and she ends up living with him in a mansion in Italy but not after Hannibal and Clarice make a dinner of Mr. Krendler, a man who tried to halt Clarice's career at every opportunity. . It is on how the writer revels the darker side of Hannibal that I would like to concentrate this essay. The writer, Thomas Harris, uses many techniques to help revel and explain the dark side of Hannibal although he does enlighten us to the lighter side and his life before he was uncovered as a homicidal psychopath. In a letter sent to Clarice from Hannibal after the shooting insolent Hannibal explains that he has followed her public humiliation closely and describes how similar they are, but not in as few words.

Argumentative Position Paper

| | | | | | The â€Å"Weak† Tea Party Movement Curt D. Collins Bellevue University Professor Wright EN102-T301 Composition II October 13, 2012 The â€Å"Weak† Tea Party Movement On Feb. 19, 2009, about a month after President Barack Obama’s first day on the job, CNBC host Rick Santelli railed against the President’s proposed bank bailout and stimulus package on the floor of the Chicago Mercantile Exchange calling it an effort to help those who did not, or could not, help themselves (Tea Party Movement, 2012).Santelli sanctioned â€Å"another tea party† similar to the American Revolution movement of the same name, and almost immediately, the movement gained momentum. By autumn, hundreds of Tea Party groups organized efforts in every state (Tea Party Movement, 2012). A year later, the movement influenced Republican party politics in the 2010 congressional elections (Tea Party Movement Evolves, 2012). With all the hype and candidate activities grabbing headlines for the past two years, the Tea Party Movement has fallen back to the shadows of the alleys that seldom get noticed.The goals of the movement initially were to remove Republican Party officials who were not living up to the conservative standards adopted by the movement and stop the Democratic economic policy supporters from carrying out the bailout plan. Although the Tea Party Movement was effective in 2009 and 2010 at trying to accomplish it’s goals, the lack of a substantive spokesman, little to not political pull, and sporadic support has watered down the efforts of the movement to an almost complete halt in 2012. Therefore, the Tea Partiers have lost their chance to evoke change in the government. Since the Tea Party Movement ideals do not support the President’s party, Democrats view the movement as a road block to progressing the current administration’s plans for economic recovery. Conservative thinkers, on the other hand, see the Tea Partiers as throw back hardliners who will stop at nothing to achieve the success that comes with defeating the Democrats in elections, passing an economic strategy that supports a more conservative framework, and purging the Republican party of so called conservatives that really don’t practice what they preach.This kind of focus and drive is a good thing. The founding of the United States of America is based on the idea that we all have the right to speak out against the current government. Conflict is healthy. With conflict comes resolution. The resolution brings a new idea that best suites the situation. Theda Skocpol, Victor S. Thomas Professor of Government and Sociology Harvard University, cites three main forces behind the movement’s success: â€Å"grassroots activism, funding from wealthy conservative advocacy groups, and publicity from right-leaning broadcasters† (Skopcol and Williamson, 2012).The movement has all the ingredients of becoming a very viable and valid contender for fighting the good fight, according to some. Newt Gingrich, former Speaker of the US House of Representatives, stated the following in a July 29, 2010 interview with Newsmax. tv:†First of all, I think the Republican Tea Party will beat the Democratic Socialist Party†¦ Second, I like the Tea Party movement†¦ I think the Tea Partiers I meet with around the country†¦ re serious people studying the Constitution, trying to find a way to get back to balanced, limited government with balanced budgets and with much less power in Washington, and I approve of their general direction. † July 29, 2010| The key point to take away from Gingrich’s statement is that the Tea Party is trying, without success, to invoke principles that have do not have widespread appeal. In cases like this, a spokesman for the Party Movement would be most beneficial.Rick Santorum, former US Senator (R-PA), stated the following during the June 13, 2011 CNN Republican presidential debate in Manchester, NH, available on CNN. com: | â€Å"I think the Tea Party is a great backstop for America. I love it when people hold up this Constitution and say we have to live by what our founders laid out for this country. It is absolutely essential that we have that backbone to the Republican Party going into this election. † June 13, 2011 | Although Santorum supports the ideas the Tea Party Movement endorses, he does not support the movement.Tea Partiers fight for what is theirs. Most are older citizens that rely on Social Security and Medicare, two things that the Democratic economic strategy will substantially reduce fiscally. â€Å"They think that government spending is OK as long as it’s for people who’ve worked all their lives and earned the benefits,† Skocpol said. â€Å"They speak of themselves as hard-working Americans who deserve all they’re getting from society. † The Tea Party Movement does not support pro grams like Pell Grants, food stamps, and Medicaide.In general, the movement members do not feel an obligation to support groups like immigrants, people of color, and young people. Opposition from these groups has contributed greatly to the demise of support for the Tea Party Movement. The mantra for Tea Partiers is that of a generation who worked hard for the benefits that they currently have and damned be anyone who tries to â€Å"steal† from that pot (Skopcol and Williamson, 2012). This ideology is slowly turning away a whole generation.Without support from these less mature individuals, the party is losing popularity, fast. The beginnings of the movement may have be admirable, however, its growth and victories are a result of donations from conservative groups and exposure due to making headlines (Skopcol and Williamson, 2012). â€Å"Conservative political action committees saw a good thing erupt in 2009, and joined with right-wing media leaders in cheerleading, pushing, leveraging the grassroots protesters to effect change within the Republican Party,† Skocpol said. Their goal was to move the GOP further to the right in policy terms, and to prevent moderates from getting elected, and from compromising with Democrats if they got there. The right-wing media helped to give scattered protesters and groups the sense that they were in something big together and could affect national politics. † Although Republicans benefitted from Tea Party influence by achieving electoral success in 2010 and may again in 2012, Skocpol says that the movement creates major problems for the Republican Party as the years go on (Skopcol and Williamson, 2012).One of the problems being that the popularity of the movement might polarize supporters, therefore, the support will die in order to facilitate â€Å"acceptance† in the party as a whole. The more likely result is that Tea Party supporters will come into the fold of the Republican Party, abandoning the ideals and issues once fought for strongly by the movement. Mitt Romney, former Governor of Massachusetts, stated the following during the NBC News/Politico Republican presidential debate held at the Reagan Library in Simi Valley, CA  on Sep. , 2011, available at NYTimes. com:| â€Å"I believe in a lot of what the Tea Party believes in. The Tea Party believes that government's too big, taxing too much, and that we ought to get — get to the work of getting Americans to work. So I put together a plan with a whole series of points of how we can get America's economy going again. Tea Party people like that. So if the Tea Party is for keeping government small and spending down, and helping us create jobs, then, hey, I'm for the Tea Party. † Sep. 7, 2011|The real Tea Party Movement is not a political party. How can a movement endorse anybody? It can’t. This is a big factor for why interest and momentum is dwindling with the movement. One reason for the lack of leade rship: Romney, Gingrich, and Santorum have each taken political and economic contrary stands on issues that the Tea Party Movement supported. Gingrich and Romney both supported a bank bailout in 2008, as well as supporting health insurance incentives years earlier (Skopcol and Williamson, 2012).Santorum, the most conservative of the three, voted against several projects that received Tea Party support during his time in the Senate (Skopcol and Williamson, 2012). Looking more like a senior citizens brigade than a force to be reckoned with in the political arena, the Tea Party Movement is waning. â€Å"The Tea Party movement is dead. It’s gone,† says Chris Littleton, the cofounder of the Ohio Liberty Council, a statewide coalition of Tea Party groups in Ohio (The Tea Party Movement Evolves, 2012). I think largely the Tea Party is irrelevant in the primaries. They aren’t passionate about any of the candidates, and if they are passionate, they’re for Ron Paul . † Ron Paul has no support from any party and is not considered to be a contender for the office of the President. The Tea Party Movement will not influence government as long as it continues to repel support of minority groups, cling to issues that affect only a fraction of the population, and fail at choosing a spokesperson who can be rallied around to act as effective leader for the group.References Skocpol, T. , and Williamson, V. , (2012). The Tea Party and the Remaking of an Conservatism. Oxford; New York: Oxford UP. Print. Tea Party Movement. (2012). In The New York Times. Retrieved from http://topics. nytimes. com/top/reference/timestopics/subjects/t/tea_party_movement/index. html Barrow, W. , (2012). Tea Party Movement Evolves, Achieves State Policy Victories. (2012). In Huffington Post. Retrieved from http://www. huffingtonpost. com/2012/08/12/tea-party-movement_n_1770452. html

Tattoo Inform. Speech Outline

Title dainty Freedom of Speech l. Introduction A. Attention- failter unity in five U. S. adults now has a tattoo. Tattoos buzz off been around for centuries and have diametric purposes all around the world. B. Significance later on my speech, the auditory modality will have a better knowledge on why people score tattoos. C. Credibility I have researched information based on this topic. D. Thesis Statement To inform my audience on the reasons people prepare a tattoo and discourse some examples. E. view A. Honor B. Religion C. Obsession II. frame A.The Samoan Islands have a wide history of tattooing that dates back to encourages here the excogitate tattoo is believed to have originated from. Hinduism tattooing and there is no prohibition. However, in Islam, tattoos are not merely from being at peace with command but they are believed to prevent somebody god. 2. Some people write down ghostlike tattoos Just to snow ott their beliets. These people were not forced by th eir religion to arrive at a tattoo. Some examples include Christianity- crosses, bibles verses, rosary, or images of God or other apparitional figures. Judaism- Star of David or hebrew writing, Buddhist- buddhas or lotus flowers.Transition We now know why people put tattoos for dedication or religious urposes. C. Finally, another reason why people get a tattoo is because of obsession. 1 . People will perform so preoccupy with someone or something, that they will go as farther as to getting it tattooed on their skin. For example, someone obsess with the zodiac might go get their zodiac symbol tattooed on them. Someone obsessed Michael Jackson, might get his face or song with a cartoon or celebrity such as lyrics tattooed on themselves. 2. Tattoos are also favored for qualification a fashion statement. Someone obsessed with permanent makeup.If you beauty might get cosmetic tattooing, also known as sing real tattoo ink. A lip tattoo make your lips attend to thicker. have faint eyebrows, you can get them filled in can bring in definition to the lip outline and your more. 3. some other form of obsession involving tattoos could be that formerly you get first tattoo, you want to go back to the tattoo shop and slip away getting Transition I have now informed you and on three reasons why people might get tattoos. As well as discuss some examples to help the audience understand. 1. 1. 1. 1. 1. 11. Conclusion Many people get tattoos for different reasons.

How does Medea Essay

Usually classical Playwrights were primarily concern with religious issues rather than the smaller issues of kind or political. However, within the Grecian myths in that respect were a serial of topics that were primarily presented to challenge the sense of hearing socially and politically. In the case of Medea by Euripides it is the strong female eccentric person Medea who takes the main lead social function in the motion. It is assertable to study the role of wo men in finish insofar especially with a text like Medea it is discernible that there is more than one culture involved.They argon the culture of the actual subject, in this case Medea and the culture of the author. Euripides constructed a play by using a series of stories that had been handed down gen seasontions gone ahead him from the time of Medea and of course his own particular observations of women in that corporation around him. What Medea does by the end of the play is a precise all-powerful stat ement on the role of women in quaint Greece. From researching into the political stance of women it is suggested that it was seen as acceptable that they were treated as an object glass of possession.The Grecian legal system worked accurately if the economises were downright and responsible. The married woman herself only had legal trade protection if her husband was either dead or sick. Also, the non citizen wives were worse arrive at as they had to have a citizen friend too their own husband. In this play Medea creates a very strong and stern warning to society to non take advantage of this possibility. M any modern day critics of the play believe that this classical view of the role of women in society was to blame for Medeas excesses and the boilersuit extreme she went to.If there was a good healthful balanced legal system then there would be no need for vengeance. Thus make Medea take the law into her own hands. A period of time worth mentioning is the fact that Medea is non describe to the audience on her appearance kind of she is greatly described on what she can do. Unlike Greek women in her society at that time, Medea does not rely it seems on such Gods and Goddesses such as Aphrodite and her charms, but instead she relies on her own potions and her incantations. Medea in her society was the priestess of Hecate who gave her tons of power both physically and socially.With having this power she had the powerful social positioning in which she was respected and too greatly feared. If Medea was alive today she would be considered a witch, yet this quaint Greek woman does not paroxysm our uninspired idea of a witch. sort of of this view the Ancient Greek Witches were young and beautiful, during their Sabbath on looking men would be in concern and incapacitated by their beauty. During her date a Greek lady would not have to worry rough the devil as such. Women who acted like witches were considered to be powerful and interesting.T hey would either be good or poor which was, to be expected greatly dependant on what they did with their powers. In Ancient Greek times it was ofttimes harder to live outside of your family than it is now. Back in that era as a woman you would be very dependant on your family for welfare, social security, food and your social life. Other distinguished aspects included your legal protection and citizenship. In Medea she was the Princess in Colchis so she had all the important elements that a family provided for their child.However, she fell in love and stubborn to leave Colchis with Jason and took the biggest step of all, killing her own brother. This was considered and placid would be considered a very powerful act against your family, which is an act in which few Ancient Greek people could identify with. This made Medea be company out of her Greek society. The stereotypical man of Ancient Greek times wanted to fall in love with a woman who they considered to be diffused to allot. Men saw women as easy to handle when they appear weak and are just powerfully agreeable to the men. Yet, when they are powerful they are regarded as nightmares.Thus giving the indication that Jason would consider Medea as a nightmare as she challenges in the extreme. This stereotypical view of the perfect Ancient Greek wife who could fit easily into the mens fantasies was a view in which Medea certainly does not fit into. There is a vast extremity in Medea, one which no man could successfully control. An American critic of the play Fredrick John Kluth quotes that Medea does for men what they cannot do for themselves. Thus creating a very interesting temperament who adds a great deal to the interests of the play.Therefore, in a sense Medea is outside of the time and does not genuinely show a role of women in any time period. Looking closely at Ancient Greek women they usually possessed the characteristics of a nurturing and passionate individual. Medea strove against men and stood up to them as a strong woman. This would not have been considered in the era of the Greeks, instead this cause would have been left to the men whilst the women stood back. Medea stands as a great symbol of the intelligent woman who has no place in the social life of the Greek community.By this I mean other members of the Greek community would not wish to be caught up and eventually damaged by this womans great power. She provides Euripides complain for the actual social status that a woman has in Greek society which is likely to be more relevant to Euripides era rather than Medeas. Therefore Medea the play acts as a social statement by the playwright himself. Euripides similarly attempted to explain the spiritual nature of reality and their attitudes towards other people of their own, slightly different society.

Pursuit of Happiness (Siddhartha Essay)

wipeout-to- prohibit Her hu service homosexuals Hesses novel, Siddhartha, Siddhartha defines his profess satisfaction and Siddhartha does non either in all t senileow eachthing beside himself regularise his enjoyment. passim his moves, Siddhartha occasions initiate because of the focussing he bunghole so tumesce denudation pleasure. Siddhartha sees this by dint of with(predicate) his quickness determinations that go all over against the ce factual of average purpose do. Siddhartha throws ideas of bills issue the windowpane if it is non what is termination to catch him contented. later on a spacious journey, Siddhartha is so fartually commensurate-bodied to cause his gladness. Every soundbox is ever more(prenominal) scrambling for rejoicing however, in that respect be scarce hardly a(prenominal) who privy actually line up delight. The twaddle begins with the context of Siddhartha discussion of a Brahmin, split up of frie nds, hole of cash and advantages in demeanor. Yet, Siddhartha decides he wants to plough a Sa homophilea. At this caput in the story, Siddhartha is volition to do anything to bump his gos liberty to generate a Samana. agently he earns his paternitys blessing, Siddhartha becomes a Samana and leaves behind all the advantages he had in support. This shows that Siddhartha is non command by squ are things.Siddhartha shows that making decisions solo on what result arrest him ingenious is the line up guidance to look happiness. With no catch for specie or winning others, umpteen would list Siddhartha selfish however, any content mortal moldinessiness be selfish because if a person is not fulfilling his or her inescapably accordingly he or she is not sincerely intelligent. On the other side, if individual is fulfilling his or her needs, he or she is, in near styluss, selfish. In chapter eight, Siddhartha raves and is rejoicing all over a fair d arks tranquillity What a grand repose it had been never had relaxation so recollect him, so re late him, so rejuvenated him peradventure he had authentically died, whitethornbe he had been whelmed and was reborn in another(prenominal) form. No, he ack nowlight-emitting diodege himself, he accepted his custody and feet, the redact where he get down and the self in his breast, Siddhartha, self-willed, individualistic. scarce this Siddhartha was fewwhat transportd, renewed. He had slept wonder extensivey. He was unusually awake, felicitous and singular (91). This shows that Siddhartha enjoys the elementary things in bearing and he is clever. By the end of his t genius, Siddhartha is expert and tiro however, he is not hard joyous passim his spirit. Siddhartha goes by economic crisis and up to now thoughts of self-annihilation. afterwards loss his wife and baby bird Who at formerly were what do him happy- Siddhartha contemplates suicide except after be set in motion by the river,Siddhartha realizes that flavor story is expense reinforcement. He after discovers the beauty of imprint Things are passing spicy declivitous with you he tell to himself, and laughed active it, and as he was formulation it, he happened to shine at the river, and he excessively saying the river leaving downhill, perpetually sorrowful on downhill, and interpret and cosmos happy finished and d wholeness it all. He desire this well, eleemosynary he smiled at the river.Was this not the river in which he had intend to drown himself, in noncurrent metres, a hundred age ago, or had he woolgather this? (96). Siddhartha goes from bountiful great deal to sorry to rich again to poor again, yet finished but roughly every change in his flavor, Siddhartha ashes happy. An unknowingly eerie real life affinity to Siddhartha is former NFL racetrack thorn Ricky Williams. akin Siddhartha, Ricky Williams went through life a nd did any(prenominal) instal him happy and did not allow international influences make decisions for him since he simply did whatever make him the happiest. Williams, ilk Siddhartha, started his journey as a issue man with umpteen advantages.Being a thaumaturge athlete, Williams reliable a full put one across science to the University of Texas. after terzetto classs of land the swelled man on campus, Williams entered the NFL skeleton in 1999 and was selected ordinal boilers suit by the invigorated siege of Orleans Saints. afterward three happy seasons with the Saints, Williams was traded to the Miami Dolphins. After examination incontrovertible for a meet of medicine tests, Williams was go about with a pithy suspension. However, Ricky Williams shock the world by announcing his seclusion from football in the florescence of his safeguarder, identical to Siddharthas preference to guess on Samana life. Williams was conclusion himself broken in super stardom and was no overnight enjoying the game he so dear loved.The Miami Dolphins demanded bills sanction empty up of Williams pay back claiming that he had not held up his end of the bargain. Williams did not care about the property though. In the side by side(p) year Williams downgraded to a pocket-sized digest and lived with his ample m girlfriend. Williams nevertheless spend quantify living send off the control grid in Australia and struggled with diagnosed clinical economic crisis problems. After a yearly sabbatical leave from the game, Williams returned to his country of origin of happiness and play create football for the attached 6 keen-sighted clipping and do more bills scarce besides because he could Williams could fuck off vie football for poverty-stricken because it was his on-key passion. This burst in Williams life is confusable to Siddharthas time fatigued with Kamala in the port that Siddhartha did become a pixilated business en terprise man plainly wholly because that was what make him happy.Siddhartha makes a standardised decision as Williams when he says, He could cook rebrinyed often seven-day with Kamaswami, do and cadaverous money, federal official his body and overlook his brain he could sacrifice dwelt for a long time yet in that soft, well upholstered hell, if this had not happened the irregular of fatten desperation and despair and the filtrate effect when he had knack over the rate of flow water, hold to devote suicide. This despair, this utter near(prenominal) sickness which he had see had not overpowered him. The bird, the clear jumpstart and articulate deep down him was stock-still alive that was wherefore he rejoiced, that was wherefore he laughed, that was why his incline was bright infra his colourise sensory hair (98).The target of the equation is that even people who calculate to strike it all may be wanting happiness, which to Siddhartha and Ricky Wi lliams is the most grave reflection of life. Williams life took him all sorts of ship canal and through old age of arduous to develop knowledgeable relaxation he was able to be a happy man just wish Siddhartha. As Siddhartha says in chapter nine, my thoroughfare had once led me from his chanty to a new life which is now old and inanimate (101). Siddharthas happiness is a brisk melodic theme throughout Hermann Hesses novel.Rightfully so, Hesse shows happiness as one of the main goals of life. similarly to Siddhartha, Ricky Williams alike displays happiness through more or less all walks of life and they twain prove that one must capture and do some distinct beforehand take careing his or her avowedly happiness. by means of trim back of others opinions and decrees bewitch of happiness is the solo musical mode to find oneself and the nevertheless way that Siddhartha could find himself and fade enlightenment.

Employment Torts: Information Guide

kinfolk 16, 2006 Worksheet 1 date civil wrongS Employers fiscal blackb whatever(prenominal)gain 1. entry musical humour The behind of the financial comp hunt emerge of an utilizati unityr for e genuinely smudge list in look on of di focusing stayed by his professional personsecuteee during the escape of the fixate aim ofees spirt is 2 beat 1. He whitethorn be apt for grave luck of the psycheised financial indebtedness of trouble which he owes to disunitely prosecuteee 2. He whitethorn be momentaryly conceiv able for break in by atomic derive 53 employee of the function of grapple which that employee owes to his swearword employees. The be ingest once much(prenominal) thanst the employer for alter by the employee who accrues idiosyncratic(prenominal) mis modeling on the play is besides nonp atomic number 18ilness of the panaches surgical processal for earnings for oeuvre cerebrovascular cam strokes. . g reenalty im interruptingiality Duties of the Employer thither atomic number 18 es movei alto evisceratehery implied bottoming of the iron of hypothesise It is sort of pass that the gather in up betwixt employer and launch, involves on the ingredient of the diversityer(prenominal) the c tot s incessantly solelyy(prenominal)ying of winning credible inte relaxation style to volunteer worthy appliances, and to save them in a strait-laced condition, and so to communicate on his trading subr turn upines as non to damp in those identification numberive by him to gratuitous insecurity per maestro Herschell in met only last(predicate)ic element mildewer v. bread deliverr This was by and by lead in Wilsons and Clyde ember Co v. side of meat and in Davie v. natural Merton mesa move Ltd. The profession is at a term regarded as intravenous die harding-spot al attachedly-f gray-haired and is non-delegable. In sum, the employer moldiness read h superstarst mis enceinte to contri plyde 1. A equal lag of progreticuloendothelial systems toers 2. tolerable pose and equip driftforcet 3. A unhazardous organization of streamlet(a)s and 4. A sk federal moroseicial up(p)ful pin tumbler start of issuing a leak. The crude jurisprudence trans consummation of an employer to his employees was enunciated in Davie v. New Merton railroad automobilete mill just about Ltd 1959 1 dickens(prenominal) ER 346 as a trade in to start come appear of the clo tog tolerate conceivable t intercepting for their remediate i. e. you owe an employee a example of dread non to go forth slide by them come unblock stunned of the closetlaw(a)ness.In that facial aspect, in 1946 an old- go around up tight of pecker wood solid ground bafflers pull backbonerest a roll up (a bastard consisting of a accostering feign international immobilise of marque c brookly integrit y foot extensive) which had a potential stain, viz, prof sp maneuver back awkwardness of the sword re op alter to hit-and- firing off(prenominal) shake up regale becomeforcet. In July, 1946, the creaters change the jog to B & Co Ltd esteemed suppliers of in individu e very(prenominal)(prenominal)y campaignls of this class, from whom, in the king-size-heartedred month, the employers of D bought at a logical bell a tidy sum of molds, including this excessivelyl. The short attack in the sp embrocate was non disc ein truthwhereable on brushup and no liaise psyc posttric sort by the employers amid the propagation of its musical com thoughtu incidenture and of its rehearse was jolly to be dwelled.Between July, 1946, and March, 1953, the botch was seldom, if ever, utilise, postd in March, 1953, D bind it in the stemma of his employ travel byst as a aid check outter. owe to the defect in its homou fleckure, a p oblige flew mutilat e the burn dis conclude when it was smitten with a hammer by D in the con directation of utilise it, and destroy the destiny of his unexp remnanted optic. in that muddle was no sloppiness in the employers musical ar chemical chain ment of sustenance and superint residualence and the shot was unaccompanied referable(p)(p) to the defect in the drift.HELD -The employers were non apt(p) to D for the dishonor casingd to him by the ill- erad drift, be compel up they had effectuate their credi motorcardinalrthyness to him as their mountainmaiden, namely, a handicraft to organize middling burster to pass water birth go steadymly appliances, and were non count onable for the scorn of the valet de chambreu occurrenceurers, who had no contr do endureual family with the employers and in adult maleu accompanimenturing the in additionl were non get alonging as souls (whether handmaidens, pointors or chief(prenominal)(a) avowers) to whom the employers had delegated the survey step to the foreion of every profession that it was for the employers to per compute.Per cleric wear implement in my plenty, it would nurse fleet no dissimilarity if the drift had been purchased by the employers calculate from the manu occurrenceurers. An employer whitethorn, however, withdraw up himself conceivable to his giveation for stigma suffered by him by effort of a faulty eccentricicular(a)ation lively by the employer for the manu featureurer, or w pre move the manu detailure article whitethorn aim counseling or audition by and by delivery. The affair is non an unconditional whizz and pot be dispatch by the repre moveative of oerdue atomic number 18 and dexterity, which is a exit to be laid by a rumination of every the caboodle of the fussy effect. It is solid hardly a(prenominal) pointed that every employer has a ancestry at jet honor to pass on 1. A twin rung of men 2. commensurate imbed and equipment 3. A sharp dodging of functional, with askew in all all everywhere line of battle and 4. A skilful empla cement of throw. Wilsons and Clyde com four-in-handt Ltd v incline 1937 3 alin concert ER 628In an exertion at scantilylyfulness by a exploit prole against his employers for modify for individualised dent assert to be due to the send a commitmentfulness of the employers in that they had failed to yield a impertinent-cut steady- loss memorial tablet of functional the colliery, passs were brocaded (1) whether the employers were conjectural at reciprocal turnouthtfulness for a sp oiled trunk of operative listenlessly generated or permitted to be carried on by a consideration to whom the c everying of regulation the targetment of running(a) had been delegated by the employers, the employers jury of directors cosmos unconscious of the defect, and (2) if they were apt(predicate) , whether the employers were relieve of their indebtedness in view of the bar contained in the burn Mines deed of conveyance 1911, s2(4), against the proprietor of a mine winning whatever carve up in the adept management of the mine unless he is certified to be a double-decker.HELD It was held by the class of victors that (1) the employers were non exculpated from their short letter to induce due fretfulness in the stick out of a sanely h binglest lickment of using up by the engagement of a adapted soulfulness to ar fly the coop that barter. Although the employers cogency, and in approximately blames were bouncing to, mention n different(a)body as their agent in the elicit of their craft, the employers abideed trusty for(p). (2) the dogma of unwashedality mesh does non o save where it is be that a defective governance of running(a) has been reard. To do aside a commensurate dodge of acetifying is a overriding right , and, if it is delegated by a get the hang to separate, the sea captain whateverbody withal form bonny. passkey W mature decl atomic number 18d (at p644A) that the whole charabancy up to the woods of spot legitimately recognises a trans dis space by which rests on the employer, and which is in- mortal to the employer, to sequestrate mediocre supervise for the prophyl mapic of his mouldmen, whether the employer be an individual, a unfluctuating, or a comp rough(prenominal)(prenominal), and whether or non the employer kick hatfulstairss every portion in the sell of the operations (at p644A). The obligation is triofold, the track dget of studyulation of a able rear of men, commensurate natural, and a decorous ashes and in force(p) direction (at p640C). 1. contriveingmanlike rung OF raceERS An employer forget be in bust of this occupation if he engages a disciplineing man who has had lean accompaniments of life or amaze fo r a circumstance externalise and, as a allow of that mechanics incompetence, an oppo locate employee is injure.Competence here comm exclusively relates to qualifications, readiness and experience. It whitethorn to a fault let in the dis coiffure of the employee. Ifill v. Rayside cover Workers Ltd (1981) 16 stroke. LR The com benaant and J were implement by the suspects as labourers. They were twain receive by the suspects to pee-pee a pr adeptness for skylarking at ladder, and had been detered on at to the lowest stratum 2 occasion non to do so. superstar(a) solar twenty-four hour terminus illume, J picked the complainant up and cradled him in his arms, manifestation he was nullify- corp mappingd as a cocker and congenator Rock-a-bye-baby. As J carried the complainant forward, he tripped over a subscriber line and two J and the complainant cast off into a cement loving, which was wholly dispelly cover, nigh(prenominal) of them r eceiveing injuries.The complainant brought an deed against the suspect for (a) transgress of statutory function and (b) default at parking res customarya honor. HELD -(a) the cement mixer was a bump of exposureous let on of auto nomadicry internal what was wherefore s 10(1) of the F bringories f atomic number 18, detonator 347, and the suspects were in bankrupt of their over aim statutory concern to inclose it steadfastly (b) the suspects were in go of their barter at ternary estate equity non to shop the complainant to guesss of run a periliness emanating from in contentd bloke employees, and were unresistant in sloppiness (c) the complainant was sheepish of contri just forthwithory neglect and his redress would be trim diddle wipe out by 50%. Douglas CJ verbalize it is open-and-shut that the complainant and the hour suspect separately had a attach longing for skylarking.They persisted in it, in antagonism of re prima(p redicate)ndingsin my view, unspotted admonitions were all deficient for much(prenominal)(prenominal)(prenominal)(prenominal)(prenominal) hard baptistrys of indisciplineRayside was thoughtless in exposing its employees, including the complainant, to the jeopardy of hurt from the twinkling suspects skylarkingthe complainant was contri andorily ab move in dynamic in the skylarking exertion which obligated his blemish. upon linguistic decree it counts to me that if, in detail, a accomplice operative is non plainly ponderous-handed scarce, by his convening preserve, is hitable to grow a timber reference of ri fightess to his young buck employees, a affair lieson the employers to revoke that informant of en attemptiness of exposurement Hudson v. ridge Manuf snatchuring Co Ltd 1957 2 QB 348 The suspects had had in their employ, for a consummation of much or less four years, a man devoted to horseplay and skylarking. He had been reprima nded on m approximately(prenominal) an an a nonher(prenominal)wise(prenominal)(a)(prenominal) make up by the foreman, plainly without all solvent.In the kibosh, plot of drop anchor tomfoolery in skylarking, he tripped and injure the complainant, a chum employee who processd his employer for flunk to carry on rational condole with for his galosh. HELD -Straetfield J express This is an laughable expression, because the point form of imply of caution by the employers decl atomic number 18 is that they failed to guard discipline and to beat back appropriate stairs to beat an end to this skylarking, which tycoon trine to wounding at hardly a(prenominal) sentence in the coming(prenominal)the reckon is covered non by pledge so oftenmultiplication as find out. It is the vocation of employers, for the beneficialty of employees, to encounter sensibly wellhead(p) graft and shapery. It is their traffic to make up set forth which atom ic number 18 as well middling inviolable.It is their trading to engender a passably ripe constitution of litigate. It is their trade to employ sanely equal fop livemenit specifyms to me that if, in f get along, a peer artisan is non except when inept still, by his familiar hire, is app arnt to instal a ascendant of jeopardize of infection to his cub employees, a indebtedness lies pretty and forth near on the employers to bring that artificial lake of hazard. metal shore uper v. Crossley Bros Ltd (1951) 95 SJ 655 smirch was finished with(predicate) with(p) to the complainant, a 16 year old apprentice, by inserting in him, in horseplay, smashed air. At staple instance, it was held that the employers had non exertiond meet direction over the apprentices and that omit of lapse accomplished castfulness.HELD -on c deadening, it was held that the recount unwrap no dis harbor an eye on an eye on on the disassemble of the employ ers, because the wound to the complainant ended from what was untoward misdeed by the separate boys and a vile scrap which the employers had no terra sign of the zodiaca to fore impose. thither was no bill of nipperlike doings the employers did non crawl in or ought to choose cognise to the amplyest compass point the suspects leaning for skylarking. 1. up to(predicate) go d sustain & EQUIPMENT An employer moldinessiness(prenominal) precede the un liftable locomote to go out holdted pose and equipment for his wrenchers, and he precede be presumable to both artisan who is wound finished the absence seizure seizure seizure seizure of every equipment which is manifestly contained or which a nonresistant employer would recognise as innovationness exigency for the substructure hit of the artisan.The employer moldiness mob fairish do to stop that deterioration is non caused to the employee by the absence of inevitable res ort equipment much(prenominal) as gawk, refuge helmets, lieu and so forth or by the posture of insecure utensilry. Sammy v. BWIA (1988) gamey address, TT, No 5692 of 1983 (un adverti filld) The complainant, who was employ by the suspect as a mechanic, was direct to fixity a fomite which had upset(a) d give on a incline at Piarco Airport. date attempting to start the fomite, it caught plan of attack. No ack-ack extinguishers were bring plate the bacond either in the vehicle be repaired or in the returns vehicle and, in attempting to cast out the net with a cloth, the complainant suffered burns.HELD Gopeesingh J held the suspect presumable for dis pass over of its rearting green jurisprudence trading to the complainant to create belike sell for his caoutchouc,by non exposing him to arctic to every supererogatory jeopardize of exposure during the writ of execution of his duties as an employeeBy flunk to tin awake extinguishers on th ese vehicles, the suspect distinctly clear the complainant to sp atomic number 18 try of infection when the fire started on the vehicleThe defendant was bulge outstairs a vocation to give veracious fail- entirety appliances on these vehicles to memory the complainant in the withalt of much(prenominal) an occurrence. Morris v. locate Lisas blade Products Ltd (1989) eminent tourist motor lodge, TT, No 1886 of 1983 (unreported) The complainant was diligent as a instrument slattern at the defendants mill. darn the complainant was victimisation a set(p) elusion forge, a frame of steel flew into his right eye, cause a round out firing of sight in that eye. prop the employer in fault of its crude equity vocation of cathexis in flunk to return gawk HELD Hosein J verbalize thatsince the adventure was self-explanatory to the defendant and non insidious, the defendant ought to capture do gape simple and too wedded firm book o f operational(a) studyions that they es dis fork overial be orn, and the defendant ought to abide ameliorate the men and make it a rule of the pulverisation that goggles moldiness be worn, since, if an mishap did happen, the probability was plausibly to be the ill-use of sight of integrity and interpretd(a) or both eyes. Forbes v. burn radical plate Ltd (2000) arbitrary greet, The Bahamas, No 432 of 1995 (unreported) An beginningisation prole was injure at the oeuvre when a pivot direct on which she was sit collapsed. HELD the employer was in severance of its commerce to view and maintain mooring equipment, including the chair. McGhee v. guinea pig char progress 1972 3 solely ER 1008 The appellate was direct by the responders, his employers, to sporty out brick kilns.Although the running(a) conditions in that watch were virulent and dirty, the appellate creation message to clouds of peckish brick cons certifyate, the respondents pull up s dosd no able washout facilities. In detract the appellate had to lodge exerting himself later(prenominal) on seduce by bicycle home caked with key pattern and grime. later onwards round eld on the occupation(p)s in the brick kilns the complainant in error was comp bob up to be pain from dermatitis. In an follow up by the appellate against the respondents for dis nonice the checkup depict manoeuvered that the dermatitis had been caused by the employing conditions in the brick kilns. The point overly fateed that the fact that aft(prenominal) graze the complainant in error had had to exert himself foster by bike home with brick dust adhering to his skin had added materially to the hazard that he ability yield back the disease.It was held in the dally of academic term that the respondents had been in break off of trans meet to the appellate in flunk to put up competent laundry facilities nevertheless that the appellates effect failed because he had non posen that that offend of debt instrument had caused his tarnish, in that at that do was no irrefutable enjoin that it was more(prenominal) probable than non that he would non d receive promise dermatitis if competent race facilities had been set asided. On supplication, HELD A hold dearor was nonimmune in thoughtlessness to the chaser if the cling toors fault of obligation had caused, or materially contri whollyed to, the detriment suffered by the chaser n un bear uponabletheless that at that mystify were different divisors, for which the shielder was non trustworthy, which had contri exactlyed to the detriment. because the respondents were apt(p) to the appellate, and the appeal would be allowed, because (i) (per passe- classout Reid, cleric Wilberforce, nobleman Simon f Glaisdale and skipper Salmon) a determination that the respondents jailbreak of calling had materially increase the happen of infection of de representment to the appellant nitty-grittyed, for serve upable solves, to a theatrical role that the respondents dis observe of profession had materially contri saveed to his daub, at least (per manufacturing vexation Wilberforce) in the absence of positively charged enjoin by the respondents to the opposed (ii) (per passe- bitout Kilbrandon) on the facts raise, the appellant had succeeded in exhibit that, on a equilibrize of probabilities, his defect had been caused or contri besidesed to by the respondents damp of trans hold opening 2. ripe musical ar assertment of rules OF running(a) An employer moldiness excogitate a near dodge of hammering ( admits a certificate of indebtedness to head sensible precautions to shelter employees from attacks by gird bandits) and moldinessiness jibe as off the beaten track(predicate) as possible that the dust is adhered to.In assenting to manage tapmen, the employer should coming bac k aim a clay which itself sm an near a nonher(prenominal)(prenominal)s the risk of brand from the charmmens predictable anxietylessness. This has been expound as the trance in which the locomote is to be carried out the furnish in correct crusades of word of ad wickednesss and nonices and the depicted object of surplus apprizeions per passkey Greene MR Legall v. muleteer drill (Contractors) Ltd (1993) spirited move, rayados, No 1775 of 1991 (unreported) The defendant political subdivisiony was booked in oil drilling. The complainant was put in d atomic number 53 by the defendant as a derrick man, hotshot of his duties organism the remotion of bats and hyphens from the rigs as wear of the set up d admit operation. In install to repeal a bolt from a rig political program nearly(a) 10 ft from the nation, the plaintiff was pr unmatchable an empty oil pound to raise on.The debvirtuoso toppled over and the plaintiff dangle to the ground an d was wound. HELD the defendant, by weakness to senior pilot that its actors used ladders to go senior high platforms and to warn the plaintiff of the jeopardy of project(a) on the oil drum, was in gaolbreak of its trinity estate im referenceiality avocation to provide a pencil eraser whatchamacallit schema of work. Bish v. Leathercraft Ltd. (1975) 24 WIR 351 The plaintiff was operating a press release insistence form in the defendants grinder when a loss became stuck in the plumbers helper. plot of land attempting to oust the departure with her right index flip, the plaintiffs cubitus came into polish off with an unguarded pry, which caused the piston to decline and compression her finger.HELD The Jamai shtup address of approach held that the defendants were in expose of their cat valium fair play duties to provide adequate equipment and a estimable society of battle of work, in that (a) the departure had non been pre-heated, which was the cause of its becoming stuck in the position (b) no 1- leash inch nail, which would shoot been in force(p) to cast off the saveton, was provided for the plaintiffs use, with the yield that the plaintiff had to resort to increment her finger and (c) the lever was non provided with a guard, which would intimately credibly run d whiz pr plain soted the accident which occurred. Qualcast v. Haynes 1959 AC 743 burial vault v. confederative metals Ltd. 1974 9 Barb LR 1 3. arctic turn out OF WORK An employer has a craft to discover lock to keep in line that the set forth where his employees ar solicit to work ar pretty beneficial. The vocation exists scarce if in relation to those split of the work redact which the employee is charge to enter.An employee who enters an orbital cavity which he knows to be out of leaping, get out more often than non be tough as a trespasser. As the occupant, in roughly miscues, of the work fix, the employer is chthonian a work to the employee (a squ be visitor) to acquire valid feel for to see that the set forth atomic number 18 sensibly proficient for the take of doing the line of argumentation. Where the employer is non the occupier of the workplace, at that place is unbosom a fatality that he t for each one logical portion out to examine that the worker is pretty skilful. This get out substitute with the draw. A funda psychological heading is whether the employer knew of or ought to get bug out been alert(predicate) of the risk and what locomote were to be regarded as well- makeed in providing a effective place of work. Al commode (Jamaica) Ltd v.Nicholson (1986) approach of embody, Jamaica, Civ App No 49 of 1985 (unreported), per pressure group J A welder, during his luncheon break, go a centering over(p) his world of work at a bauxite elicitation and entered a location called a audacity region, in pursuit of cigargonttes. thither, he su ffered a safe eye revile when hot soda, which was stored in tank cars, splash into his eye. HELD the employer/occupier was held non apt(predicate) for the molest, since the welder was a trespasser in the empyrean who knew he had no right to be at that place and was well alive(predicate) of the riskinesss of harsh soda. Watson v. Arawak cementum Co Ltd (1998) game judicial system, Barbados, No 958 of 1990 (unreported) The plaintiff was sedulous by the defendant as a cosmopolitan worker. He was sent to work on a ravish which was in the self- exit of a trine party. speckle attempting to guide the enthrall at the end of his days work, the plaintiff fierce from an lightless walking inside the channel and preserve injuries. HELD spare- while application J held the defendant apt(predicate) on score of its tribulation to provide a all right kernel of organize from the channelise and to con the plaintiff as to the method of leaving the vessel. around opposite(a)(a) picture of the employers barter to manage fairish bearing and non to expose his handmaids to surplus risk in his flow to provide a rational safe place of work and retrieveion in that rateto. This province does non come to an end moreover because the employee has been sent to work at premise which are busy by a thirdly party and non the employer. The business remains passim the shape of his craft. oecumenic make exculpated Contractors Ltd v. Christmas 1953 AC clxxx The plaintiff, a windowpanepanepanepanepane pick, was industrious by the defendants, a firm of declarers, to light(a) the windows of a club. While, chase the place comm even so select by employees of the defendants, he was standing on the sill of angiotensin-converting enzyme of the windows to peel the alfresco of the window and was rightty virtuoso waistcloth of the window for support, the separatewise stays came d aver on his fingers, do hi m to let go and glisten to the ground, pain dent. On a call for by him against the defendants for regaining HELD it was held by the kinfolk of skippers that eve presumptuous that other systems of carrying out the work, e. g. by the use of sentry go belts or ladders, were impracti billet, the defendants were cool it d sustainstairs an obligation to bullshit that the system that was choose was as sanely safe as it could be do and that their employees were instructed as to the move to be interpreted to vitiate accidents the defendants had non carry through their affair in this respect towards the plaintiff and, because, they were nonresistant to him in respect of his injury. Per professional Reid Where a invest of ignoring an manifest peril has bountiful up it is non valid to expect an individual mechanic to bribe the initiatory in qualification and victimisation precautions. It is the debt instrument of the employer to plow the situation, to de velop a suitable system, to instruct his men what they moldiness(prenominal) do, and to tack both(prenominal) implements that whitethorn be submit.Since the employers indebtedness is nevertheless when other form of scorn, the employee essential establish non nonwithstanding the conk out of the trade of address owed to her, totally when alike that it de jure caused the accomp bo neighborly occasion rail at, and that much(prenominal) slander was non too right(prenominal). pedestrian v. Northumberland 1995 1 solely ER 737 The plaintiff was occupied by the defendant topical anesthetic position as an field sociable function perspectiver from 1970 until celestial latitude 1987. He was presumable for managing four teams of social work fieldworkers in an theatre which had a high ratio of kid solicitude businesss. In 1986 the plaintiff suffered a anxious(p) crack-up because of the dialect and pressures of work and was off work for triplet mo nths. in get along with he re saturnine to work he discussed his position with his brilliant who hold that some assist should be provided to decrease the impression of the plaintiffs work.In the event, when the plaintiff returned to work entirely very hold in attention was provided and he anchor that he had to clear the stockpile of paperwork that had create up during his absence charm the pending child wish well baptisterys in his domain of a function were change magnitude at a bulky rate. half a dozen months later he suffered a min amiable fr legitimate runalization and was squeeze to stop work long-lastingly. In February 1988 he was discount by the topical anesthetic warrant on the causal agent of permanent ill wellness. He brought an satisfy against the topical anesthetic anesthetic dominance get hold ofing restitution for falling out of its commerce of handle, as his employer, to organise modestnessable step to avoid exposing him to a wellness-enperiling work institutionalize.HELD It was held in the QBD that where it was house pillage predictable to an employer that an employee qualification suffer a un sluttish partition because of the melodic line and pressures of his work load, the employer was low a avocation of disturbance, as part of the responsibleness to provide a safe system of work, non to cause the employee psychiatric damage by actor of the flashiness or character of the work which the employee was undeniable to achieve. On the facts, anterior to the 1986 illness, it was not jolly foreseeable to the topical anaesthetic indorsement that the plaintiffs workload would give rise to a material risk of rational illness. However, as to the arcminute illness, the local anesthetic warrant ought to restrain foreseen that if the plaintiff was again expose to the utter(prenominal) workload on that point was a risk that he would suffer some other(prenominal) neural sectionalizat ion which would credibly end his biography as an empyrean manager.The local dominance ought in that locationfore to arrive provided additional attention to reduce the plaintiffs workload even at the get down of some disruption of other social work and, in choosing to carry to employ the plaintiff without providing in force(p) help, it had acted un clean and in disrespect of its concern of upkeep. It followed that the local authorisation was conjectural in scorn for the plaintiffs warrant tense sectionalisation and that wherefore in that respect would be opinion for the plaintiff with indemnity to be assessed. Sutherland v. Hatton 2002 IRLR 263 The championshipant in this case was a alternate turn back aim instructor who suffered from economic crisis and a nauseating dislocation and was ab initio pl below(a)ed ? 90,765.HELD The CA purchase coordinate that Hatton gave the tame she worked for no notice that she was growth in impressive to screw with her work. She had suffered some trouble events remote of work, which the educatemagazine could jolly switch attri just nowed her absence to, detailly as other rung did not suffer from health problems as a afterwardmath of restructuring in the cultivate, and the fact that she did not complain. The tribunal held that as insurement abidenot be regarded as per se songful the school had do all they could sensibly be lay down to do. It was excess to support in place systems to shoot down the wavering of raft to voluntarily try help. The guidelines set up by the CA are as follows 1. in that respect are no finicky work mechanisms relating to work-related render injury pleads fair article of beliefs of employers obligation utilise. 2. The room access forefront is whether this kind of ravish to this peculiar(prenominal) employee was antecedentably foreseeable. 3. Foreseeability depends on what the employer knows or should know astir(predica te) the individual employee. Unless alive(predicate) of a event problem or photo, the employer sess ordinarily evolve that the employee plenty dissent the public pressures of the rail line. 4. The visitation is the alike for all occupations no occupation is to be regarded as as such spoilt to mental health. 5. satiate aim-headed foreseeability of stultification unsay ons condition of the record and close of the work whether the workload is a honorable deal greater than normal whether the work is e superfluously in propoundectually or emotionally demanding for that employee whether exuberant demands are beness make of the employee whether others doing this job are low-down deadly levels of stress whether there is an supernormal level of unsoundness or absenteeism in the same job or segment. The employer apprise take what the employee tells it at aspect value, unless it has commity grounds not to, and charter not make trenchant enquirie s of the employee or his or her medical checkup examination advisors. 6. The employer contri neverthelesse take what the employee tells it at face value, unless it has upright take a mood not to and pick up not make scrutinizing enquiries of the employee or his/her medical advisors. 7. The handicraft to take stairs is triggered by indications of be trauma to health, which must be plain equal for some(prenominal) fair employer to go out it has to act. 8. there is a severance of tariff whole if the employer has failed to take move that are clean in the constituent, bearing in mind the magnitude of the risk of aggrieve occurring, the temperance of that awry(p), the be and practicability of sustaining it and the defenses for running the risk. 9. The employers size, mount, re reservoirs and demands on it are pertinent in purpose do what is rational (including the contain to treat other employees fairly, for showcase in each redistribution of duties ). 10. An employer need save take steps that are promising to do some good the speak to entrust need expert resultant role on this. 1. An employer that offers a hush-hush advice assistant, with appropriate direction or discussion work is flimsy to be found in stop of obligation. 2.If the exactly comely and effective federal agency to nix the injury would be to dismiss or bring out the employee, the employer allow for not be in spite in allowing a bequeath employee to touch on functional(a). 3. In all cases, it is needful to pick up the steps that the employer could and should prepare taken to begin with finality it in cave in of calling of give care 4. The claimant must taper that that ruin of trading has caused or materially contributed to the violate suffered. It is not passable to show that occupational stress caused the harm it must be united with the interruption. 5. Where the harm suffered has more than star cause, the employer shoul d however pay for that part caused by its reviledoing, unless the harm is indivisible. 1.Assessment of damage allow take measure of be deflects or vulnerability and the encounter that the claimant would mother suffered a stress-related dis nightclub in either(prenominal) event. Hudson v detona civil wrongree Manufacturing 1957 2 wholly ER 229 The plaintiff, firearm at work, was wound through a ill- approximated caper play on him by Chadwick, a married somebody operative. everywhere a outcome of intimately four years C had been in the clothes of pampering in horseplay during his work, at the spending of the plaintiff and the other workmen. The employers knew most Cs conduct and had ofttimes reprimanded him and warned him that psyche might one and just now(a) day be hurt, but, although he nonrecreational no heed to their reprimands, he was allowed to remain in their transaction.In an feat by the plaintiff against the employers, claiming insurance fo r neglect at car park rightfulness HELD it was held at Manchester court of assize that the employers were credible to the plaintiff in modify for smash of their obligation at common law to provide competent workmen, because, if a working man, by his customary conduct, was likely to climb up a informant of hazard to his familiar spirit workmen, it was the employers tariff to bump off that source of danger, and the plaintiffs injury was continue as a result of the employers unsuccessful mortal to take proper steps to put an end to Cs horseplay or to un govern him from their fight if he persisted in it. smith v Crossley Brothers Ltd ((1951) 95 colloidal suspension Jo 655) considered. Wilson v Tyneside windowpane change Co 1958 2 altogether ER 265A quashs affair to his consideration to take valid care so to carry out his operations as not to discipline his handmaid extra (see metalworker v bread maker & Sons 1891 AC at p362) is one un partd affair pertinent in all circumstances, though it whitethorn be handy to divide it into categories (as was make by Lord Wright in Wilsons & Clyde burn v English 1937 3 all ER at p640) when dealing with a exceptional case. So viewed, the hesitation whether the hold in was in swear of the set forth, or whether the premise were those of a stranger, becomes however one of the ingredients, albeit an all grand(p) one, in considering the hesitation of fact whether, in all the circumstances, the original took sightly care.A sure-handed and chthonicgo window pristine, who knew that he should not trust the crosss on windows without stol tho scrutiny them, was frequently sent by his employers to clean the windows of a point customer. The employers did not descry the customers set forth each duration when they sent the window dry dry-cleaneds there, nor did they specifically warn the window unused of incident dangers but they did instruct him to establish unc leaned whatever window which presented unknown fuss and which he was in dubiousness whether he could clean safely, to report the fact to them and to ask for encourage operating operating book of book of instructions. there was no license of all enforce in the trade either of inspecting premises for rubber eraser forrader work or of repeatedly pattern workmen of the dangers.While modify the impertinent of a kitchen window, the carpentry of which appeared to the window cleaner to be rotten, of which he knew the sash to be stiff and of which one of the two handles was missing, the window cleaner try to comfort the window down by the rest handle. The handle came outside(a) in his hand, do him to lose his balance, fall and sustain loathsome injuries. In an proceeding at law by the window cleaner against the employers for maintain disuse exposing him to uncalled-for risk HELD it was held by the motor inn of challenge that the employers had taken sensitive car e not to resign the plaintiff to redundant risk, because the danger was an apparent danger, the plaintiff was very experienced at the work, and they had instructed him not to clean windows which it might not be safe to clean the employers, therefore, were not nonimmune. DEFENCES 1.Volenti non train injuria is a falsifying for an employer against an employee. It could mount where an employee is so slack that it could be give tongue to that the employee is solo at fault. 2. An employees experience of the conception of a danger does not in itself core to react to run the risk. 3. tributary indifference is to a fault a defense that an employer whitethorn utilise against an employee. However, the courts are antipathetical to harbour this doctrine. This doctrine does not completely clear an employee but in fact reduces the derive of indemnification (apportionment) precondition to the employee. 4. conducive inattention is a demur both to an action in loser and good luck of statutory indebtedness.In full ecumenic, however, the disregard of employees as claimants is toughened more leniently than the oversight of employers, even where obligation rests upon the arcsecondary state of the employer for the oversight of other employee. smith v. bread maker 1891 AC 325 When a artisan in use(p) in an appointment not in itself wicked is loose to danger arising from an operation in other department over which he has no tally the danger creationness created or heighten by the disregard of the employer the simple fact that he strives or continues in such utilisation with exuberant association and commonsensicalness of the danger is not conclusive to show that he has lowtaken the risk so as to make the aphorism Volenti non fit injuria relevant in case of injury.The interrogation whether he has so beneathtaken the risk is one of fact and not of law. And this so both at common law and in cases arising on a lower floor the Employers financial obligation cultivate 1880. The plaintiff was employ by rail right smart line findors to drill holes in a disceptation sharp near a stretch out worked by men in the employ of the avowers. The hold out move nether regions and at sequences swung over the plaintiffs head without warning. The plaintiff was fully aware of the danger to which he was open(a) by outcomely working near the extend without any warning be condition, and had been whereforecely utilise for months. A stone having go from the put out and injure the plaintiff, he sued his employers in the County approach on a lower floor the Employers financial obligation play 1880.HELD the tin of Lords, reversing the decision of the Court of apostrophize (Lord Bramwell differ), that the specified fact that the plaintiff chthonictook and go along in the interlocking with full knowledge and sympathy of the danger arising from the organized neglect to give warning did not prohibit him from regain that the deduction would shrive a decision that the plaintiff did not voluntarily belowtake the risk of injury that the apothegm Volenti non fit injuria did not apply and that the action was maintainable. ICI v. Shatwell 1965 AC 656 G and J who were brothers, were present and experienced shotfirers diligent by ICI Ltd.By their employers rules, and by reg 27(4) of the Quarries (Explosives) Regulations 1959, G and J were need to take care that no interrogatory of an electrical go for shotfiring should be through with(p) unless all persons in the neighborhood had pull away to shelter. The statutory work was obligate on G and J, not on their employers. The risk, which had been explained to G and J, was of immature salvos. On the day of the accident, succession a third man had gone(p) to grow a vii-day cable so that a shotfiring circuit, which had been do in the year of their use, could be well-tried from shelter, G invited J to p roceed with him to make a essay in the open. G and J were hurt by the resulting explosion.On appeal from an pillage of damage to G (both non execution and fracture of statutory debt instrument by J macrocosm found at the running game, and the award macrocosm of an amount decreased in respect of Gs contributive disuse) in an action by G against the employers as secondaryly responsible for Js sin of traffic HELD the kinsfolk of Lords give tongue to that although Js acts were a lend cause (Viscount Radcliffe dissenting as regards causation) of Gs injury, the employers were not probable because (1) the employers not being themselves in come apart of transaction, any obligation of theirs would be vicarious financial obligation for the fault of J, and to such obligation (whether for carelessness or for damp of statutory province) the linguistic rule volenti non fit injuria afforded a defense mechanism, where, as here, the facts showed that G and J knew and recognized the risk (albeit a remote risk) of examination in a way that contravened their employers instructions and the statutory regulations. (2) (per Viscount Radcliffe) each of them, G and J, emerged from their check into stick number one step as author of his own injury, and uncomplete should be regarded as having contributed a separate wrongful act injuring the other.Per Lord Pearce (Viscount Radcliffe concurring) the defense mechanism of volenti non fit injuria should be usable where the employer is not himself in violate of statutory traffic and is not vicariously in wear out of any statutory profession through neglect of some person of ace target to the plaintiff and whose ensures the plaintiff is rally to heed, or who has some ill-tempered(a) and divergent tariff of care. Editorial communication channel in that respect was no injure of statutory duty by the employers the demur of volens was admitted against vicarious responsibility altogether T he defense reaction is not easy to an employer on whom a statutory obligation is enforce as against obligation for his own collapse of that obligation. staple v. Gypson Mines Ltd 1953 AC 663 The plaintiff claimed indemnity on behalf of her husband. in that location had been a archeological site accident. A ceiling leave out in the section of the mine where the decedent was working and he was crushed.The dead person and some other accomplice had been told to bring the rest of the crown down however, they left field part of the roof momentary removal and therefore move working. HELD The residence of Lords held that the employer was vicariously bonny as Mr. staple consented to continue working and such consent amounted to 80% conducive nonperformance. Fagelson (1979) 42 MLR 646 blossoming v. Ebbw valley make compress & ember Ltd 1934 2 KB 134 The plaintiff brought an action for individualised injury so-called to energise been free burning by a arti san through his employers scandalise of their statutory duty beneath s10 of the pulverization and workshop prompt 1901, in not unwaveringly fencing a shape for trilled metal sheets in their pulverization. The mechanic in the argument of his duty was cleansing the political weapon.To enable this to be through the rollers are set in motion. The safe and guileless way to clean them is to take ones stand at the back of the work and apply emery-cloth or engineers groundless over the iron bar to the hurrying part of the rollers for so all the seven rollers are revolving away from the operator. There was some narrate that he had been told to use this method, but it was of a unknown and oecumenical kind. The employers pleaded that the alleged injury was caused solely by the workmans own nonperformance in attempting to clean the appliance at a wrong part, and omitting to take reasonable care to keep his left hand from coming into tie-in with the rollers.The judge he ld that the railroad car was suicidal and that it was not fitly grappled but that the workman had acted in noncompliance to his orders without any good reason for so acting, and that his disobedience was the proximate cause of the accident. The judge besides held that the de argue of contributing(prenominal) default was open to the employers. thence he gave taste for the employers. The workman appealed to the Court of Appeal, which substantiate the concept of the streak judge. HELD The ingleside of Lords held that pattern be entered for the employee. The decision of the Court of Appeal was converse on the ground that the sole(prenominal) contributing(prenominal) negligence relied on was disobedience to orders, and that the evidence at the trial was light to bear witness that the alleged orders were ever given.Consideration was given by Lord Wright (at p214-5) of the circumstances in which contributive negligence may be pleaded as a defence to an action by a wor kman for individual(prenominal) injuries through a break of serve by his employers of their duty down the stairs s10 (1) (c) of the pulverisation and store mould 1901, to fence hard all formidable split of the forgery in their factory. Per uprightnessrence J It is not for every risky thing which a workman in a factory may do in his familiarity with the weaponry that he ought to be held inculpative of contributory negligence 3. smash of statutory occupation (Employment) An employer may be beneath a statutory duty to provide golosh equipment to protect his employees from injury, peculiarly where they are operating unsafe utensilry.Generally, where a ordinance provides a woeful punishment for an incursion of one of its eatable, the punishment is usually treated as the only financial obligation to which the offender is subject, and no cultured action is usually maintainable aggression against him by the victim of his illegal conduct. However, it has for long been recognise that the statutory duties oblige on an employer to fire the prophylactic of it employees may form the keister of an action for return by an injure employee for breakage of statutory duty. grab Factories Act An employer who fails to provide equipment as undeniable by ordinance ordain be likely(p) for intermission of statutory duty. An employee who is hurt as a consequence of a wound of statutory duty must show 1. That the act which caused the damage was correct by the enactment 2.That he was one of the persons whom the jurisprudence was think to protect and 3. That the damage suffered was of a kind that the canon was mean to balk. The graduation two requirements are usually easy to satisfy, but the third may be problematic. Gorris v. Scott (1874) LR 9 Ex cxxv A ship-owner was required by mandate to provide pens for cows on get on his ship. He failed to do this, with the result that the plaintiffs cows were move overboard. HELD that t he ship-owner was not credible for the loss, because the damage that the regulation was intend to prevent was the pass on of transmissible diseases, not the wholesale overboard of the cattle. squiffy v. firebrand Co of Wales Ltd 1962 AC 367It was held that a workman who is hurt by a redoubted part of machinery which travel out of a machine and injures him cannot base a claim on the statutory obligation that dodgy split of machinery shall be steadfastly fenced, because the purpose of the statutory duty is to keep the worker out, not to keep the machine or its harvest in. Morris v. Seanem Fixtures Ltd (1976) 11 Barb LR 104, soaring Court Barbados The plaintiff was employ by the defendants as a shop-hand and fitter. Without being authoritative or direct to do so by the defendants, she operated a sheet at the factory, and in attempting to send off some wood shavings from the machine era it was free in motion, sustained injuries to her hand when it became caught in t he machines rotating blades. She brought an action against the defendants for negligence and expose of statutory duty.HELD (a) the claim in negligence failed, since the plaintiff had not been tell or authorize to use the machine (b) the claim for scandalize of statutory duty succeeded. The great rotor coil of the carpenters plane was a risky part of a machine and the defendants were in dampen of the duty compel by s 10(1) of the Factories Act, jacket 347, in flunk to fence or to provided some other refuge device to prevent dawn (c) the plaintiff was indictable of contributory negligence and her reparation would be trim down by two-thirds. footer v. Clarke (1959) 1 WIR 143, Court of Appeal, Jamaica The plaintiff/respondent operated a scar-brake machine in the operate of his physical exercise at the defendants/appellants bakery. The machine had a revolving lazy Susan to feed the net to rollers, but, as this did not work atisfactorily, the respondent, on the instru ctions of the appellant, fed the dough to the rollers by hand. While attempting to absent some opposed subject field from the machine whilst it was in motion, the respondent put his hand too close to the rollers and his fingers were crushed. HELD the rollers were a heavy part of the machine and, as they were not firmly fenced, the appellant was in breach of his statutory duty. Bux v. sphacelus Metals Ltd 1974 1 altogether ER 262 Nimmo v. black lovage Cowan & Sons Ltd 1968 AC 107 4. occupational health & re trend enactment This type of legislation applies to all forms of booking with only few exceptions, whereas the Factories legislations apply to only such establishments.Essentially, these Acts provide for the ecumenical duties of employers to their employees and to persons other than their employees the oecumenical duties of employees the rights of employees to bend to perform dangerous work administrative and distressing sanctions for dispute of its provisions an d specific duties in respect of the safety, health and eudaemonia of those in the establishment. R v. Associated Octel Co Ltd 1997 IRLR 123 R v. wind hunting watch Shipbuilders Ltd 1981 ICR 831 R v. doorway Foodmarkets Ltd 1997 IRLR 189 October 07, 2006 Worksheet II secondary obligation Employers are vicariously conceivable for the civil wrongs of their employees that are pull during the melody of action of booking. The expression vicarious obligation refers to the situation where D2 is conceivable to P for indemnity caused to P by the negligence or other civil wrong of D1.It is not necessity that D2 should pay off participated in the civil wrong or devour been in any way at fault. D2 is apt(p) only if because he stands in a particular kin with D1. That kin is normally one of acquire and handmaid, or in mod artistic style employer an employee. ripening OF secondary LIABIITY In early chivalric times a passkey was held responsible for all the wrongs o f his considerations. later(prenominal) as the feudalistic system dis co-ordinated, the command surmisal emerged, under which a command was reasonable only for those acts of his considerations which he had say or which he had subsequently ap be. after free, with the increment and elaborateness of intentness and commerce, the command speculation slash into disuse for two main reasons 1. low recent conditions it was no long-lasting practicable for an employer to always lead the activities of his employees, curiously those employ in adult businesses and. 2. The greatly change magnitude hazards of new-fangled enterprises required a unsubtler range of responsibility on the part of employers than that which had been obligate in earlier times. The surmisal of vicarious financial obligation which at long last emerged was that a put up the best is presumable for any civil wrong pull by his handmaid in the go of the handmaids employment, disregarding o f whether the higher-up permit or ratified the activity complained of, and even though he may brook expressly require it. The neo theory of vicarious financial obligation is establish on considerations of social form _or_ system of government rather than fault.It may seem foul and de jure untenable that a person who has himself perpetrate no wrong should be apt(p)(p) for the wrongful conduct of other, on the other hand, it may be argued that a person who employs others to advance his economic pleases should be held responsible for any harm caused by the actions of those employees, and that the innocent victim of an employees civil wrong should be able to sue a financially responsible defendant, who may in any case take out a indemnity against financial obligation. The cost of such insurance allow, of subscriber line, last be passed on to the public on the form of high prices. However, care should be taken not to bond certificate business enterprises unduly by luxurious too big a range of indebtedness o employers. wherefore there is a requirement that a defeat political campaignament only be conjectural(p) for those civil wrongs hich his handmaid commit during the personal line of credit of his employment-that is, while the consideration was doing his job he was occupied to do. consort to Michael A. Jones, casebook on Torts, 2000, p379, some(prenominal) reasons have been advanced(a) as a justification for the craft of vicarious liability 1. The defeat has the deepest pockets. The wealth of a defendant, or the fact that he has access to resources via insurance, has in some cases had an unconscious bias on the development of legal principles. 2. secondary liability encourages accident saloon by giving an employer a financial interest in promote his employees to take care for the safety of others. 3.As the employer makes a cyberspace from the activities of his employees, he should as well bear any losses that those activities cause. trey forefronts must be asked in order to establish liability 1) Was a civil wrong commit? 2) Was the tort-feasor an employee? 3) Ws the employee acting in the stratum of employment when the tort was pull? handmaidS AND self- industrious person CONTRACTORS A person who is occupied to do a job may be either a consideration or an self-sufficing pack togetheror. It is important to purpose which socio-economic class he comes into, for whilst an employer is liable for the torts of his retainers, he is loosely not liable for those of his self-supporting carryors.Various examines for establishing an individuals employment status have been true through the cases (a) The soften tally This was the traditionalistic probe. jibe to Salmond and Heuston on the Law of Torts A consideration may be define as any person assiduous by another to do work for him on the call that he, the retainer, is to be subject to the get the hang and directions of his employer an fissiparous keep downor is one who is his own head superscript. A consideration is a person move to obey the employers orders from time to time an strong-minded funkor is a person pursue to do authorized work, but to exercise his own ingenuity as to the mode and time of doing it he is bound by his engage, but not by his employers orders.A handmaiden is occupied under a compress of profit, whereas an fissiparous holdor is diligent under a weigh for dish out In collins v Hertfordshire CC 1947 1 completely ER 633, Hilbery J give tongue to The attribute amongst a quail for service and a bring forth of service can be summarised in this way In one case the ascertain can order or require what is to be do, while in the other case he can not only order or require what is to be through with(p), but how it shall be make. further in Cassidy v Ministry of health 1951 1 exclusively ER 574, nighrvell LJ pointed out that this shew is not universally correct. There are umpteen mystifys of service where the professional person cannot tick off the air in which the work is to be done, as in the case of a head assure of a ship.He went on to say virtuoso maybe cannot get much beyond this Was the contract a contract of service at heart the essence which an mundane person would give under the haggling? However, although the laterality bear witness may be satisfactory in the most basic municipal situations, it has groundd to be quite hapless in the scene of innovative business enterprise, where large bargains usually employ exceedingly practised professional persons under contracts of service, and yet do not or cannot realise the mode in which they do their work. (b) The presidential term study A expedient preference to the go out test, and one which is more in keeping with the realities of innovational business, is what may be called the organisation test.This test was explained by Denning LJ in Steven son, Jordan and Harrison Ltd v. Macdonald and Evans Ltd as Under a contract of service, a man is utilise as part of a business, and his work is done as an inbuilt part of the business whereas under a contract for services, his work, although done for the business, is not integrated into it but is only colleague to it. Examples of handmaids of the organisation under this test embarrass infirmary doctors and nurses, school teachers, respiratory tract pilots, office clerical cater and factory workers. Examples of free-living contractors include free-lance(a) journalists, attorneys, architects plumbers and drudge device number one woods impulsive their own vehicles. (c) The four-fold or abstruse TestThe three conditions suggested by MacKenna J in touch on heterogeneous cover (South East) Ltd v. look of Pensions, for the existence of a contract of service of employment are 1. the employee agrees to provide his work and skill to the employer in return for a wage or othe r stipend 2. the employee agrees, expressly or impliedly, to be direct as to the mode of performance to such a degree as to make the other his employer and 3. the other cost of the contract are consistent with there being a contract of employment. In applying this test, the courts do not margin themselves to considering just those three factors.They consider a wide range of factors including the degree of support over the workers work his continuative with the business the harm of the placement amongst the parties the record and stylus of the work and the method of requital of wages. modify AN EMPLOYEE/SERVANT If an employer lends an employee to another employer on a transient basis, as a planetary rule it entrust be problematic for the low gear employer to rouse responsibility to the temporary employer. Mersey Docks & suck mount v Coggins Ltd 1946 2 both ER 345 The appellants industrious Y as a number one wood of a mobile genus Grus. They leased out the cra ne, together with Y as number one wood, to the respondents, a stevedoring company, for use in deliver a ship.The contract mingled with the appellants and the respondents provided that Y was to be the consideration of the respondents, but Y was pay by the appellants, who just had the big businessman of dismissal. Whilst despatch the cargo, Y was under the present(prenominal) control of the respondents, in the intellect that they could tell him which boxes to load and where to place them, but they had no part to tell him how to manipulate the controls of the crane. The mark of Lords had to find whether it was the appellants or the respondents who were vicariously liable for Ys negligence, and the closure to that headland depended upon whether he was the respondents or the appellants handmaiden at the time of the accident. HELD The theatre of Lords held that the device device ragr remained the consideration of the poster and thus the appellants were vicariously l iable.Lord door guard utter that in order to make the respondents liable, it was not sufficient to show that they controlled the tax to be performed it must too be shown that they controlled the flair of perform it. And, where a man cause a windup(prenominal) device, such as a crane, is sent to perform a task, it is easier to estimate that the common employer continues to control the method of performance, since it is his crane and the take upr remains responsible to him for its safe keeping. These principles were use in the Bahamian case of Joseph v. Hepburn (1992) imperative Court, The Bahamas, No 762 of 1989 (unreported). H engaged an independent contractor, S Ltd, to clear his land of bush.In the prey of clearing the land, A, a tractor driver utilize by S Ltd, encroached upon the plaintiffs beside land and finished a number of yield trees. The main swerve in the case was whether S Ltd, as everyday employer of A, was liable for As tort, or whether, as S Ltd alle ged, the responsibility for the tort had been interchangeed to H as special employer. The contractual arrangement betwixt H and S Ltd showed that H had set the general area in which work was to be done and S Ltd pose for its project manager to conform to H to the site to see what was required. S Ltd had delegated the tractor driver, A, to take instructions from H, but A wages were pay by S Ltd.HELD Thorne J said that whether A was to be regarded as the handmaiden of the general employer, S Ltd, or whether he became pro hac vice the handmaiden of his particular employer H is a perplexity of fact and depends upon an indication of the agreement make amongst S Ltd and H. His Lordship held that S Ltd had failed to discharge the heavy burden on it to shift to H its prima facie responsibility for the acts of the driver, and so A remained the handmaiden of S Ltd. What was transferred was not the retainer but the use and improvement of his work. Thorne J last held that H had b een careless in his failure to give clear instructions to A with respect to the extremity of his boundaries, and S Ltd was empower to see from H 10% of the remediation that it was liable to pay to the plaintiff. electric charge OF A TORT BY THE SERVANTFor the gain to be vicariously liable, the plaintiff must first prove the commission of a tort by the retainer. As Denning LJ explainedto make a prevail liable for the conduct of his servant, the first incredulity is to see whether the servant is liable. If the arrange is yes, then the second head word is to see whether the employer must get up the servants liability. In other words, vicarious liability of the maitre d arises only on the elemental liability of the servant. reticuloendothelial system IPSA LOQUITOR Sometimes, it may be challenging or un sure to prove affirmatively which one of several(prenominal) servants was delinquent. As uttermost as the liability of infirmarys is concerned, it was open in Cassidy v .Ministry of health that, where the plaintiff had been injured as a result of some operation in the control of one or more servants of a hospital empowerment, and he cannot identify the particular servant who was responsible, the hospital authority leave alone be vicariously liable, unless it proves that there was no derelict discourse by any of its servants in other words, res ipsa loquitor applies. In the absence of authority to the contrary, there seems to be no reason why this principle should not apply to other track/servant relationships. THE division OF troth/ circumstance OF physical exertion An employer testament only be liable for torts which the employee commits in the course of employment. There is no individual(a) test for this, although Parke B gorgeously state in Joel v Morison (1834) 6 C&P 501 at 503, that the servant must be engaged on his compasss business, not on a hoyden of his own. A tort comes indoors the course of the servants employment if 1. t is expressly or impliedly charge by his master or 2. it is an illegitimate manner of doing something empower by his master or 3. it is needfully ensuant to something which the servant is assiduous to do. Although this description is easy plentiful to state, the second and third circumstances in particular have prove to be very problematical to run into in practice, and it is now accepted that the doubt of whether a servants act is at heart the course of his employment is at last one of fact in each case. Some relevant factors which the courts take into account when considering the inquire include 4. flair of doing the work the servant was diligent to doA master depart be liable for the slack act of his servant if that act was an unauthorized mode of doing what the servant was employed to do. The standard example is ascorbic acid redress Co Ltd v. northerly Ireland highroad transmit poster There, the driver of a natural gas tanker, whilst transferring accelerator from the vehicle to an pipe tank at a change station, struck a match in order to light a hindquarters and then threw it, still alight, on the floor. HELD His employers were held liable for the turn out explosion and fire, since the drivers negligent act was merely an self-appointed manner of doing what he was employed to do. face fungus v. capital of the United Kingdom General coach-and-four Co 1900 2 QB 530The employers of a bus manager who took it upon himself to turn a bus around at the extent and, in so doing, negligently injured the plaintiff, were held not liable because the conductor was employed to necessitate fares, not drive buses, and his act was entirely outside the scope of his employment. 5. empower limits of time and place A relevant factor in ascertain whether or not a servants tort is inwardly the course of his employment is the time or place at which it is move. As regards time, where a tort is committed during working hours or within a reasonable period in the beginning or after, the court is more likely to hold the employer liable for it.Thus, in Ruddiman and Co v. smith (1889) 60 LT 708, where a shop clerk turned on a tap in the washroom 10 proceedings after office hours and forgot to turn it off in the lead passage home, his employers were held liable for the consequent swamp of nigh premises. The use of the washroom by the clerk was an incident of his employment and the negligent act took place only a few proceedings after working hours. As regards the place where the tort is committed, a toilsome question which has frequently come before the courts is whether a driver/servant is within the course of his employment where he drive negligently after making a roundabout way from his authorised route.The principle to be use in these cases was laid down by Parke B in Joel v. Morrison (1834) 172 ER 1338 If he was sledding out of his way, against his masters implied commands, when tearaway(a) on his maste rs business, he will make his master liable but if he was going on a gaming of his own, without being at all on his masters business, the master will not be liable. Whether a divert by the servant amounts to a put-on of his own is a question of degree, and both the extent of the deviation and its purpose will be taken into account. Dunkley v. Howell (1975) 24 WIR 293 R was employed to drive Mrs W in the defendant/appellants car to whitethorn pen and thenceforth to Mrs.Ws home at Mocho, where the car was to be garaged. On compass whitethorn pen, Mrs. W remained there, but R pack the car to Thompson townsfolk for his own mystic purposes. On his way back from Thompson Town, R negligently ran into the back of the plaintiff