Global Warming Essay

There are many causes of Global Warming. The destruction and burning down of tropical forests , traffic clogging up the city streets , rapid growth of unplanned industries, the use of CFCs in packaging and manufacturing products, the use of detergents etc. cause Global Warming. Besides, overpopulation, deforestation are the causative factors of Global Warming. The setting up of mills and factories in an unplanned way has a great effect on environment. These mills and factories produce black smoke which gets mixed with air and increases the amount of CO2. Burning of Gas such as Methane (CH4) and fuel also increase CO2Â ­ in the environment. Killing animals like birds, big cats, lions, tigers is also a alarming cause of Global Warming. The effects of Global Warming is very dangerous for our existence and survival. The sun’s scorching heat comes to earth in a direct way. Therefore, the earth’s surface becomes seriously heated. Agriculture, forestry and fishery is seriously be damaged. This can catastrophically reduce mankind’s ability to grow foods, destroy wildlife. Global Warming also cause sea-water to swell up. All species are important for maintaining ecological balance. If one is lost, the whole natural environment changes. To prevent the dangerous effects of Global Warming necessary steps should immediately be taken. People should not be allowed to cut off trees which causes deforestation. Rather they should be advised and suggested to plant more and more trees in accordance with their capability and convenience. Forests also control the natural balance. People should be made aware of it. Mills, factories, brick-fields should be set up in a very good planned way. There should be well drainage system to pass away waste materials, wastages and poisonous chemicals. The alarming world’s climate is very dangerous for mankind and ecological balance. Unless Global Warming is not controlled, no men, animals will be able to live, grow and thrive. So, we should try maintain the ecological balance to decrease the effects of Global Warming.

Current Issues in Business Law

Business law really tends to describe an extensive body of bylaws that tend to govern the business transactions. Business law also includes every major aspect of trade together with the advertising as well as marketing collection plus the bankruptcy, contracts, banking, secured transactions, negotiable instruments and trade as a general rule.It is sometimes considered as a branch of communal law however it deals with issues of public along with private law. Business law covers foreign and domestic trade hence it tends to regulate business among the states. In this same connection, there is a uniform commercial code which has by now been adopted in all the parts of every state within the United States which tends to be the main primary authority which governs the business transactions.Despite the fact that uniform commercial code normally controls so many aspects of domestic commercial law, state laws and other common law of contracts, it at the same time applies to other types of bus iness transactions which tend to arise as far as business is concerned. Consequently, business law is a very essential component of within this particular area.Even if the trade world faces a continuous change, the commercial laws have remained static in general. As a consequence, commercial law is not only uniform throughout the US but as well to those people who normally do business are at the position of proceeding with business transactions with some degree of confidence towards the law which governs these particular business transactions (Samuel, 2008).Commercial law encompasses titles as agent and principal, carriage by both sea as well as land. It is as well known because it regulates hiring practices, business contracts, manufacturing and the retailing of consumer goods. Thus there are so many countries which have really adopted the civil codes because these codes contain complete statements of their own business law.Looking back at the United States, business law is the mai n zone for the United States Congress beneath its powers to govern and rule the interstate business as well as other states under the authority of the police. These days they are really trying quite harder to create an amalgamated body of business law within the United States. They are going to succeed since they actually adopted the consistent commercial code.This identical commercial code has made things much easier as far as business law is concerned. However, there are quite a number of authoritarian schemes that tend to govern and control on the way business is supposed to be conducted. Some of the authoritarian schemes that control are the safety laws, privacy laws, and drug and food laws among others (Samuel, 2008).So many small and middle sized businesses currently lack the financial strength to make payments in the potential wrongful release awards in lump sum. So many labor and groups on employment defend successfully those businesses that are established well and mid size businesses from claims pertaining to wrongful removal from office from former employees.Whenever they seem not to be succeeding in the lawsuit, it seems like the company is forced in one way or the other into bankruptcy removing all the present workers from the office. Such cases are so many compared to previous days. Such developments are equally resulting in extensive businesses that survey the likelihood of gaining protection through the purchase of wrongful dismissal insurance.The current business law these days is very essential because it really helps people to realize the business ethics. It assists them to follow these business ethics in running their businesses in a proper and authenticated manner. This has to be in an agreement with the set of laws and guideline prevailing within the society.However, business law is mostly offered to those people who are intending to set up nice businesses together with an authenticated business registration and license in the future. Thi s is what makes the business law studies extraordinary essential. So many customers are very comfortable in doing their businesses as long as they have a government license at hand as well as an approval stamp for their individual businesses.However, the government policy that issues licenses is actually not complex. It is always very necessary that the business law studies are really considered very carefully. Currently business law studies are taught by the professionals who are experts in business law consultancy.These professionals normally plan a course structure which can assist an individual in realizing his business law obligations together with the rules which are applied into the business trade system. Current business laws help all the individuals in setting up their businesses in the future. These businesses do well because the owners are experienced and educated on how to carry them on. They use the knowledge to expand their type of businesses hence they are able to par ticipate in the market (Emmanuel, 2001).Any case study of business law tends to teach a business, a good manner in which the business is going to be initiated. Business processes have got so many matters for example the copyright issues, legalized marketing of the business, registration fees and so on. The business law case studies really focus on business activity.So many packages and relief are obtainable by trading and this will enable an individual to learn more about the methods of getting the governmental facilities. It involves tax cuts, tax write off, getting funds as well as government loans together with the raising any business right from franchise. To take a business law case study assists an individual to the greatest out of the facilities that the government has given to the business.Consequently, business law is very necessary for those people who need to run any line of business within the law agencies as well as the consultancy firms. An individual is actually taugh t all the main aspects of trade law plus the ethics. This automatically provides a person with a chance to begin a career as a legal advisor, consultant for very big budget businesses as well as trade mechanism.These days, business law is very important for very tiny businesses because these businesses are operated on a very limited financial resource because they are some kind of self employment. However, the government tries so much to encourage such small businesses as well as devises extraordinary laws, restricted to small business. Currently the tax cut offs are so much for these small businesses (Emmanuel, 2001).The modern commercial law has enabled business countries on civil and common law system to become more considerable in the extensive use of business arbitration that is comparable to the former private courts of merchants. In the United States, they are having similar commercial statutes that tend to smooth the progress of the business from end to end of a particular n ation.Certainly, Europe business law is still a separate subject matter due to its special courts. During the time when the business law got adopted by the state meeting during the year 1997, it appeared like a watershed within the country’s financial reforms.In any busy profit-making world, the business which is operated nicely must equally involve the agents.   Business law normally represents the emergent and ordinary morality of all the human beings. All the businesses are however seeking to partner themselves with the prevailing customs in proclaiming as right only whereby all the businesses perceive to be always right.They tend to be right in enforcing as law the rules that are considered by the great number of people or very powerful to be moral and just. For the reason that business law is and it is still supposed to be reflective in prevailing morality, societal control over the businesses is very necessary. The aim is self control which is based on the person†™s own moral philosophy (Manfred, 1929).As a matter of fact, all the business activities happen in an officially authorized system framework. Business law places business in its lawful framework and it also develops skills in compliance, risk assessment and troubleshooting.The program on business law focuses so much on the application of law in business as well as government sectors. Business law covers a very wide part of trade, consumer and commercial transactions. However, business law underpins the operation of regulates, markets conduct in the markets as well as the addresses instances of the market failure in which voluntary business mechanisms are not able to attain relevant policy objectives.The business law practitioners really identify lawful standards as the law gradually changes and determine important policies together with the practices in meeting the legal requirements. On the other hand, commercial law regulates hiring practices, corporate contracts and the manufac ture plus the sales of customer merchandise. This law sometimes regulates their directors, corporations, corporate relations and shareholders with the third parties.There is taxation law within this context which deals with taxation of persons and the businesses. This includes income tax, goods as well as services plus a diversity of nation taxes.

DEVELOPING AND MANAGING PERFORMANCE Essay Example | Topics and Well Written Essays - 2000 words - 2

DEVELOPING AND MANAGING PERFORMANCE - Essay Example nce is recognised to bestow an organisation with pertinent statistical understanding of its existing situation in the global marketplace which in turn enables it to initiate future initiatives for developing the products/services for its customers. Hence, it can be affirmed that measuring the performances of an organisation fundamentally concentrates on the process of collecting and accounting the information about the productivity of its workforce along with the quality of services rendered (Armstrong & Baron, 2005). With due consideration to developing and managing performance of the workforce, the report intends to critically evaluate the key elements of employee reward and development policy along with practice contributing to the overall performance of Pentangelli’s in its restaurant business. Pentangelli’s is recognised as a restaurant chain situated in East and North Ridings of Yorkshire. It specialises in Anglo-Italian food items. Moreover, the discussion of this report will further include the challenges that could be faced by Pentangelli’s in terms of designing effective strategies for its employee in relation to rewards and development policies. Employee reward and development policy and practice play an imperative part for an organisation to continuously keep its employees motivated and focused towards achieving the overall goals of the organisation. The two key elements of employee reward and development policy comprise: It can be extensively observed that paying appropriate or at times higher wages to the employees or paying additional compensations is highly beneficial to increase the talent engagement as well as the method also helps to reduce the attrition rate of the employees within the organisation. A successful organisation prudently exploits compensation plans according to the performance of the workforce in order to uphold organisational values as well as recompense workers for contributing whole-heatedly towards meeting the

Advantages and disadvantages of private labels Essay

Advantages and disadvantages of private labels - Essay Example A private label may be defined as a label that is unique to a specific retailer. According to Weitz's definition, "Private-label brands, also called store brands, are products developed by a retailer and available for sale only from that retailer (2004)." There are many categories of private labels such as, store brands, store sub-brands, umbrella branding, individual brands and exclusive brands.In order to fully discuss private labels, an original company, Macy's, has been used as an example in this essay. I would like to propose several ideas related to private labels that can help improve Macy's profitability.Macy's was founded by Mr. Rowland Hussey Macy in 1851 and established on Broadway in New York City. In 1896 the store was acquired by Mr. Isidor Strauss and underwent a large expansion during the 1920's and 30's http://en.wikipedia.org/wiki/Macy's).Today, it is perhaps as well known for its annual Thanksgiving Day Parade, as its chain of large American department stores. Its flagship store is located in New York City, and currently holds the record for largest department store building.R.H. Macy & Co. merged with Federated Department Stores on 19th December, 1994. Federated merged its Abraham & Straus/Jordan Marsh division with "Macy's East". Federated acquired Woodward & Lothrop/John Wannamaker in 1995. In 1996 Federated purchased and dissolved Broadway Stores and incorporated it into Macy's West. The year 2001 saw the acquisition of the Liberty House chain which had departments and stores in Hawaii and Guam. It was converted into Macy's West. Bon-Macy's (Pacific Northwest) and Burdines-Macy's (Florida) were soon named as Macy's Northwest and Macy's Florida respectively. And Macy's Central Division included the Memphis and Atlanta Macy's became a part of Macy's central division. In 2005, Macy's acquired May Department stores and retained its brand name to be sold at the Macy's store. Thus, May became a private brand for Macy's. This was an important merger for Macy's since Famous-Barr, Filene's, Foley's, Hecht's, The Jones Store, Kaufmann's, L.S. Ayres, Meier & Frank, Robinsons-May, and Strawbridge's were all included in this acquisition. Later the same year Macy's announced that Marshall Field's would be acquired by Macy's and would become the company's North Division. Federated Department Stores has thus successfully eliminated much of its competition by buying them out and converting them to the Macy's nameplate. By 9th September 2006, Macy's will have approximately 850 stores in United States(http://en.wikipedia.org/wiki/Macy's) . The CEO and Chairman of the store is Terry J. Lundgren and the CFO is Karen M. Hoguet. The vice president of Corporate Communications and External Affairs is James A. Sluzewski (http://www.hoover.com). Macy's has seven divisions, the names of which are provided below; Macy's East Macy's Florida Macy's Midwest Macy's North Macy's Northwest Macy's South Macy's West The top competitors for Macy's are Dillards, Inc (DDS), J.C. Penny Corporation and Saks Incorporated (SKS). The company has a number of subsidiaries and affiliates; namely After Hours Formalwear, Bloomingdale's, Inc., David's Bridal, Inc., and the various regional divisions of Macy's. The company had 232,000 employees in the year 2006 and had a growth rate of 43.30% and (http://biz.yahoo.com/ic/12/12493.html). The annual revenue of the store is 2.5 billion U.S. dollars (http://www.fashioncareerexpo.com/show_co_profile_and_jobs.cfmemployer_id=87&show_id=11). Historically, private labels were inexpensive copies of original designer clothes, often a season or two behind runway fashion. In addition, most of the private labels had a homely feeling to them. However, this is not the case anymore. Trends have drastically changed in the past few years. Whereas private labels were once sold at the back section of departmental stores,

Educational Leadership Theories Research Paper Example | Topics and Well Written Essays - 1250 words

Educational Leadership Theories - Research Paper Example Educational leadership includes the process of establishing teams, as well as a united staff. Transformational leadership discusses how new levels of energy and commitment which the educators show can also lead to a general transformation of the organization. In the study, Robinson, et.al., (2008) demonstrated how transformational leadership improved the capacity of the workers to collaborate with each other and to assist each other in overcoming challenges in the fulfillment of their goals (Robinson, et.al., 2008). The study also discussed that the more teachers were actively involved in applying transformational leadership and in participating in collegial discussions, the better the impact they had on their students. With active transformational leadership, there was also an oversight and coordination of the general instructional program (Robinson, et.al., 2008). Applying transformational leadership has also been apparent in good performing schools with teachers adhering to clear performance standards in their teaching. With these applications of transformational leadership, it is apparent that it is a strong leadership theory to apply in teaching. McCormick (2009) discusses the essentials of transformational leadership and he cites how this leadership is defined in terms of its idealized influence and individual considerations. McCormick (2009) also discusses that transformational teachers are those who help students consider the bigger view of education by establishing idealized influence. These teachers often communicate with their students and point out to them how important education is and how it can provide a good vision for their future. In applying this leadership, the students have to be exposed to different lifestyles; and in the process consider various opportunities for their future (McCormick, 2009). This type of leadership has also been able to encourage frequent trips for students in order to view the bigger world, and to seek strong solution s for the problems they witnessed during these trips. Through transformational leadership, educators have been able to teach their students how to view themselves as leaders. Teachers applying the transformational leadership approach were able to get their students to read Romeo and Juliet as early as their sophomore year. These teachers were able to encourage the students to narrate the story in their own in way. In effect, the students were actually able to gain much depth in their understanding of Shakespeare and his poetry. By setting high standards for their students and by encouraging them to be more active in the learning process, the students were able to gain more skills and knowledge (McCormick, 2009). Transformational teaching also involves challenging assumptions about the school system. Where students were considered ‘unteachable,’ the transformational leaders were able to prove such concept wrong by teaching their students new ways of learning, as well as and new knowledge. Alger (2008) discusses that building an organizational culture which highlights stable improvement in educational programs can be a significant challenge. The leaders can be challenged in advocating strong leadership in these instances. Transformational le

Independent Television (ITV) Essay Example | Topics and Well Written Essays - 1500 words

Independent Television (ITV) - Essay Example Companies Strengths and Weaknesses ITV Comprehensive income statement year ended 31st December 2011 indicated that, the company was able to attain a cost saving of twenty million pounds through its wastage and efficiency program (ITV, 2012). It was predicted that the company was going to attain another cost saving of twenty million pounds by the end of 2012 fiscal year (ITV, 2012). The report further indicated that, ITV was able to obtain net advertisement revenue of 1% by the end of 2011 fiscal year (ITV, 2012). During this year, ITV subsidiaries reported higher positive growth, for example, 1% growth was obtained from viewers followed by a 10% in digital growth (ITV, 2012). The report indicates that ITV was able to attain 21% growth through online revenues which translates to thirty four millions pounds as on 31st December 2012. Additionally, the company was able to achieve a 44% growth through distribution of its content (ITV, 2012). Connectively, revenue of thirty five million po unds was obtained from international production and another seven million pounds from investments (ITV, 2012). However, despite having a positive growth, the company has also been faced with some challenges. This is because, by the end of 2011, the company revenues from distribution business declined substantially by four million pounds (ITV, 2012). In above connection, another 5% decline in growth was reported by the end of 2011. Additionally, the company incurred a loss of thirty nine million pounds; the loss was attributed to bond that was purchased during this period (ITV, 2012). On the contrary, the financial statement of Wire and Plastic Product (WPP) reported operating profits of ?14.0 millions by the end of 31st December 2011, while in the previous year; the company reported... Independent Television (ITV) Independent Television was one of the ancient business networks established in the United Kingdoms in 1995 with an aim of channelling news and eradicating monopoly business that was dominated by BBC during that period. The company consists of broadcasting Channels that include the following; City television, Itv1, Itv2, Itv3 and Itv4. ITV Company sells formats and programs in the United Kingdom as well as in other parts of the world. The major sources ITV revenues emanates from sales and advertisement. Additionally the company provides online services to its clients through itv.com. Among the services being rendered by ITV include; online advertisement and online sponsorship. In above connection, the company conduct other operations through its ITV studios such as; entertainment, dramas, factual to name just but a few. In 1958, ITV directors issued 300,000 common stocks at four dollars each to the public through initial public offer.The company had been expanding across the world and has been portraying positive growth in the stock market. Therefore, based on the above report on portfolio analysis, I would advice Mike to invest his savings in ITV company because the company has higher returns that Mike can obtain and retain the rest given the fact that he is a conservative investor. Additionally, the company has lower risk exposure as indicated by its gearing ratio. Therefore, if Mike invests his savings in ITV securities he is guaranteed security of his investments.

Cyberbullying Essay Example | Topics and Well Written Essays - 750 words

Cyberbullying - Essay Example The website stopcyberbullying.org defines cyberbullying or online bullying as â€Å"when a child, preteen or teen is tormented, threatened, harassed, humiliated, embarrassed or otherwise targeted by another child, preteen or teen using the Internet, interactive and digital technologies or mobile phones.†The site further states cyberbullying involves minors; otherwise, if adults are involved it is labeled as cyber-harassment or cyberstalking. There are several ways how a minor is cyberbullied. These include pretending to be someone else to trick the other person, spreading lies and rumors about the victim, deceiving people to provide personal information, sending cruel or malicious messages and posting pictures of the victims without their knowledge.2 There are a number of measures which can be done to prevent cyberbullying. â€Å"Education and awareness is the key. Parents and teachers need to understand the problem, and understand the technology.† Since it is next to i mpossible to limit the access of kids to electronic technologies, parents can purchase software programs which can monitor their children’s communications and the websites they visit. On the other hand, schools should educate their students regarding cyber ethics, discuss cyberbullying, advice students how to stay away from it and talk about its negative effects. Among the other institutions, it is the schools that play an important role in stopping and remedying cyberbullying. They should promulgate policies that will discipline students who engage in such acts, whether inside or outside the campus, especially if it adversely affects other kids in school. Schools, however, should be careful not to exceed their authority, lest they be sued. They should encourage their students to report to their teachers or other school authorities if they are victims or are aware of cyberbullying incidents. Schools can also provide pamphlets which could give advice on how to be â€Å"cyber- safe†, such as not sharing or posting personal information online; not divulging internet passwords with anyone except their parents; not personally meeting anyone whom they just know through the net and to always remember to talk to their parents on what activities they do online.4 As of February 2011, there are already 44 states that have cyberbullying laws according to the Cyberbullying Research Center.The Center goes on to specify that of these 44 states, six states specifically mention â€Å"cyberbullying† while 31 states specifically mention â€Å"electronic harassment†. These legislations are indeed a welcome improvement in the status of prevention of cyberbullying. In an article written by O’Neil, he suggested that it is difficult to pursue a civil or criminal case on cyberbullying because of the high standards that the Supreme Court has established for incitement.6 He pointed out further that although the Tort and Libel Laws are in place, they are inadequate to protect an individual from cyberbullying. I believe that legislation against cyberbullying have a long way to go. The state should not be reactive in introducing new laws against cyberbullying; rather it should be proactive and not wait for more tragedies to happen before it begins to act. Aside from government policies, the business sector also has a responsibility in barring cyberbullying.  

Summary of Thirteen Days by Robert Kennedy Essay

Summary of Thirteen Days by Robert Kennedy - Essay Example The Soviet Union was putting her nuclear missiles on the grounds of Cuba ready to strike the United States. Given the magnitude of the threat, President John F. Kennedy had no choice but to make a decisive decision on the issue to avoid the eminent danger that United States was in. Making a decision on such a grave matter was not easy. The president had to understand the consequences that that awaited any of his actions and the impact they would have not only on the United States, but also on the entire world. He therefore had to rely on the Committee of National Security Council for advice. The members of this committee were to argue, discuss, and even quarrel to eventually advice his on the best course of action to take concerning the crisis. Many a member of the committee rooted for the deployment of military to destroy the Soviet Union missiles in Cuba. Robert Kennedy, then the attorney general, was of the idea that the navy should be deployed around the Cuban island to block any offensive that the Soviet Union might employ against America. ... They perused through past similar crisis and their resolutions and the mistakes committed and how they could avoid repeating such mistakes. They did their best to understand the situation before any decision could be made by President Kennedy. They knew any decision taken would have a huge effect on humanity. Robert Kennedy vividly explains how decisions were arrived at during these momentous times and how those taken by the President himself and his advisors. It gives detailed information on the efforts of both Robert Kennedy and John Kennedy towards ensuring that any decision taken centered on diplomacy and law. This approach was done at the United Nations. ‘13 days’ also highlights how Robert Kennedy was powerful in the John F. Kennedy government and how he used his power to exert influence on other advisers of President Kennedy. In the book, there are correspondences between President Kennedy and the Soviet Union leader Nikita Krushnev and the speeches that President Kennedy gave concerning the Cuba nuclear crisis as well as photos of nuclear weapons that the Soviet Union had already brought to Cuba. The book further reveal that even the Soviet Union wanted a peaceful end to the Cuban crisis since they realized they too had families that would suffer because of employment of nuclear weapons between the two super powers. Any passionate lover of John F. Kennedy’s president would find this book captivating and inspiring to some extend as it gives the reader a rare opportunity to read and understand the mind of President Kennedy. The book outlines the historical lessons learnt from the crisis and how they can be avoided in the future, so as under no circumstances should there be any disregard for

Contraction in Smooth Muscle Cells compared to Contraction in Skeletal Essay

Contraction in Smooth Muscle Cells compared to Contraction in Skeletal Muscle Cells - Essay Example In this assignment, based on studies, a comparison has been drawn between the contractions of these two types muscles at the cellular and molecular levels. Before going into this discussion, contraction must be defined. Contraction is defined by activation of the muscle fibers with a demonstrable shortening of the muscle fibers2. The physiological events in relation to muscle contraction have been delineated in great detail, and they reveal that basically, with neural stimulation there occurs a series of molecular events initiated by increase in the cytosolic calcium concentration. In this assignment, these events will be looked at in a greater detail to compare these events between the striated and nonstriated muscles. Each skeletal muscle is made up of a large number of skeletal muscle fibers, which are thin cylindrical multinucleated cells of variable length, which in turn are made up of myofibrils, which are bundles of filamentous structures running along the length of the fiber. While observing skeletal- or cardiac smooth muscle fibers through microscope, a series of light and dark bands perpendicular to the long axis of the fiber are very conspicuous. Actually, each myofibril consists of repeating sarcomeres, and the alignment of these sarcomeres3 between adjacent myofibrils gives rise to these bands in the skeletal muscle. The structural plan of the myofibril is such that the sarcomeres are placed end to end, and this fundamental contractile unit is visible within skeletal and cardiac muscles. On the contrary, smooth muscle cells do not show a banding pattern. Actually, the arrangement of sarcomeres leads to the striated pattern in skeletal and cardiac fibers, and sarcomeres in turn comprise of alternate arrangements of numerous thick and thin filaments in the cytoplasm to give rise to roughly 1-2 micrometer cylindrical bundles. Smooth muscles are abundant mainly in the visceral organs, such as, gut, blood vessels, bladder, and uterus, and they are to serve a particular function. For example, smooth muscles present in the sphincters are designed to maintain a steady contraction for long periods of time and then rapidly relax or in other muscles, they remain constantly activated. To suit these varied functions, the smooth muscles consists of sheets of many small spindle-shaped cells linked together by junctional contacts. Although these serve as mechanical continuity between adjacent spindles, actually, in places there are gap junctions that are designed to provide electrical continuity between cells. Each cell is uninucleated, shorter than striated muscles, and broader than a myofibril. Unlike striated muscle, no cross striations are visible, although they contain the same contractile protein filaments, actin and myosin. It is important to note that their arrangement is irregular in a loose lattice unlike th e regular arrangement of skeletal and smooth muscles. Myosin has been termed as a molecular motor. This consists of two heavy chains and two pairs of light chains. The two terminal ends of the heavy chains create a coil that aggregate in the cell to create the basic unit of a thick filament. The remainder of this molecule juts outward from the thick filament creating the cross-bridge. Thus, these polypeptides combine

The Limits of Efficiency Essay Example | Topics and Well Written Essays - 750 words

The Limits of Efficiency - Essay Example And so unions formed, and enough of a public outcry was raised to stir Congress to action. The COPE Act sounds like a promise to return to the easier days before regulation in some parts of the cable television and Internet industry. Because it can take months for cable companies to be awarded franchises, this bill sets up a system of "national cable franchising" in Title I (Summary of COPE Act). The bonus is that applications will now be awarded in thirty days. However, this will lead to the elimination of competition, and insufficient media infrastructure in poor communities, and so this bill threatens the access of many to affordable media. As a result, it should not be made into law as it is currently written. It may seem that creating one franchising standard nationwide would be a positive change. As it stands now, cable providers have to work out local franchising agreements with every local government where they want to offer their programming. Because telephone companies want to enter the cable television industry, they also have to go through this maze of negotiation, and one force behind the COPE Act is the telephone companies' complaint that the negotiation process is excessively "burdensome"(COPE Act of 2006). However, for this bill to be fair to all Americans, it should contain more specific requirements for infrastructure. There are currently no requirements for providers to set up infrastructure to all neighborhoods within a particular market, and so people in rich neighborhoods could end up with more choices, and therefore better pricing, than those in poor neighborhoods (COPE Act of 2006). Without this requirement, companies are likely to avoid areas where collections and maintenance costs could be higher, because of higher occurrences of delinquent accounts and vandalism. If one segment of the American population has the chance to receive lower cable prices, then all segments should have that chance. Also, by creating a national set of franchising requirements, this bill takes away the ability of state and local government to regulate the cable industry in the area of consumer protection, giving that ability instead to the FCC, an already burdened government agency that does not have the time to regulate the cable industry's consumer practices as well. The FCC is not currently authorized to order refunds, as state and local governments are - the FCC only has the power to fine companies, and that money just goes to the government - not to the victims (COPE Act of 2006). Another area of concern has to do with public, educational, and government channels, or PEG TV. If cable companies no longer have to answer to municipal and state governments, it will no longer have the incentive to give up channels for public/community access space (Davies). This will even further reduce the amount of non-commercial media available

Theories of Learning Essay Example for Free

Theories of Learning Essay Piaget`s Cognitive Theory of Learning Piaget`s cognitive theory of learning has remained popular among educators and has greatly influenced curriculum development.  Ã‚   This is for the reason that traditional schooling gives utmost importance to the development of the learner’s cognitive faculties.   This theory was the culmination of his systemic longitudinal research on children (some of whom were his own).   Piaget`s theory describes what may be expected of children at different stages of intellectual development. According to Piaget, all persons go through a sequence of four distinct stages of intellectual development from birth to maturity.    Although every normal child passes through those stages, the ages at which some children attain each stage may vary.   The four stages are (1) the sensorimotor stage, (2) the preoperational stage, (3) concrete operations stage, and (4) the formal operations stage (Piaget, 1977).   Each stage is characterized by the ability to perform particular major cognitive tasks. Piaget`s approach to learning is a readiness approach.   Readiness approaches in developmental psychology emphasize that children cannot learn something until maturation gives them certain prerequisites.   The ability to learn any cognitive content is always related to their state of intellectual development and ways of thinking as a result of this integration. The cognitive theories of learning allege that individuals differ in their intellectual abilities because of the developmental stage they are in and their interaction with the environment.   These theories further assert that cognitive growth and development are characterized by steady progression (i.e., from the simplest to the most complex). Piaget`s theory of cognitive development has guided the sequencing of learning content (knowledge, skills, processes) from the concrete to the abstract, and the selection of evaluation tools.   It has also facilitated the realistic setting of educational objectives and intended learning outcomes. Skinner`s Behavioral Theory of Learning   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Skinner (1953) developed the method of conditioning through what has been termed operant or instrumental conditioning. Operant conditioning involves voluntary behavior emitted by the learner which may be reinforced by its consequence.   In operant conditioning, whether a response occurs in the future depends upon the nature of the contingency.   If a response makes life better for the individual, it will likely occur in the future.   If it makes life worse, it will likely not occur again in the future.   Thus, operant conditioning makes use of reinforcements.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Anything that increases the likelihood that a behavior will be repeated is referred to by the behaviorists as reinforcement.   It is very important to note that the definition says nothing about whether the student â€Å"likes† or â€Å"dislikes† the reinforcement; whether it is deliberately given or not, or whether the behavior in question is the one desired. In operant conditioning, when a student responds with a behavior that is close to what is expected by the teacher, the latter delivers a positive reinforcer.   Positive reinforcers motivate the learner to repeat the behavior with increased frequency, duration, and intensity.   A reinforcer can be anything that the learner may perceive as reinforcing (e.g. grades, oral/written commendation).   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Negative reinforcement on the other hand, is the process by which a response that leads to the removal of an aversive event increases that response.  Ã‚   Further, behavior modification is a process of shaping a person’s behavior through the acquisition of new operants through a series of reinforcement and sequencing of desired responses.   It involves changing behavior in a deliberate and predetermined way by reinforcing those responses that are in the desired directions. A well-known behaviorist, B.F. Skinner, argues from an operant conditioning perspective that students must actively respond if they are to learn.   Cognitivists share that view with Skinner; however, they emphasize mental activity rather than physical activity.   According to the Cognitivists, if students control their own cognitive process, it is ultimately the students themselves who decide what information will be learned and how. A central component of Piaget`s developmental theory of learning and thinking is that both involve the participation of the learner.   Knowledge is not merely transmitted verbally but must be constructed and reconstructed by the learner.   Piaget believes that for a child to know and construct knowledge of the world, s/he must act on objects. Learners must be active; they are not vessels to be filled with facts.   Hence, a Piagetian curriculum emphasizes a child-centered educational philosophy and active discovery learning environments. Cognitive and behavioral theories of learning also serve as a psychological foundation of the curriculum.   Following are some ways each theory can influence the curriculum development process: Cognitive theory Learning experiences will be most effective if they are adapted to the normal growth of the learners; needs, capacities, and interests of the learner. Learning experiences must be â€Å"designed to match assessment of age levels on which certain processes of thought can occur†(Taba in Ornstein Hunkins, 1988).   Learning    experiences for different students should be adapted to their stage of cognitive development. Behavioral theory A motivated learner learns more readily than one who is not. Thee is no substitute for repetitive practice in the learning of skills. Information about the nature of good performance and knowledge of mistakes and success   Ã‚  Ã‚  Ã‚   aid learning. Meaningful tasks and materials are more readily learned than nonsense materials and those not understood by the learner. Active participation is preferable for passive reception. Learning has application and can be transferred to other situations. Since Piagetian curriculum emphasizes a child-centered educational philosophy and active discovery learning environments, instruction must be individualized as much as possible and children are given opportunities to communicate with one another, to argue and debate issues.  Ã‚  Ã‚  Ã‚  Ã‚   Further, the following are the four general principles of how the cognitive learning theory might influence the instructional design process: If learning depends on how information is mentally processed, then students` cognitive process should be a major concern of educators.   Students` learning difficulties can often be attributed to ineffective or inappropriate cognitive processes.   For example, disabled children process information less effectively than nondisabled children.   Teachers must become aware, not only of what students learn but also how they attempt to learn it. Educators must consider students` level of cognitive development when planning topics and methods of instruction.   For example, explanations based on concrete operational logic are unlikely to be effective ways of presenting ideas to pre-operational kindergarten.   Concrete operational elementary school children have difficulty understanding abstract ideas that do not tie up with their own experiences.   These students will learn more effectively if the same information is presented through concrete experiences prior to presenting abstract material. Students organize the information they learn. So teachers can help students learn by presenting organized information and by helping students see how one thing relates to   another. New information is most easily acquired when people can associate it with things they have learned.   Therefore, teachers should help students learn by showing them how new ideas relate to old ones.   When students are unable to relate new information to anything familiar, learning is likely to be slow and ineffective. Theories of learning, such as the cognitive and behavioral theories serve as a psychological basis f the curriculum. Hence, this great mass of theoretical and empirical information available to curriculum decision makers regarding the nature of the learner and how learning takes place.   Answers to questions like:   â€Å"What are the characteristics, capabilities, needs, and interests of children and the youth in the different stages of their development?†Ã‚   provide the psychological foundation of a curriculum, and serve to guide selection of curriculum objectives, content, learning experiences, evaluation scheme, and even the length of class sessions. For example, calculus has to wait until college (and only for those who are so interested in mathematics that they pursue specialized training in the discipline).   Preparatory school mathematics is limited to the basic notions of counting and the relationships of numerals (bigger/smaller0 and some very basic operations with the use of concrete objects, such as beads, blocks, and sticks. Essay tests are not given to preschool pupils, and so are test items that measure complex thought processes and require long attention span.   The length of class sessions per subject or course range from a few minutes on the nursery level to a couple of hours in the graduate school.   Long lectures will simply not work with the very young learners; neither will jumping, hopping, and running appeal to graduate students who might already be suffering from rheumatism, arthritis, or heart problems. The learning theories, principles, and assumptions have influenced curriculum development, most especially in the choice of curriculum content and learning experiences.   Just like the different educational philosophies, the different theories of learning have their respective strengths and limitations.   Curriculum developers have to make their own decisions as to which views of learning they will consider in planning the curriculum. References Piaget, J. (1977).   The development of thought:   Equilibrium of cognitive structures.   New York:   Viking. Skinner, B.F. (1953).   Science and human behaviour.   New York: Free Press. Taba, H. (1988). Curriculum development theory and practice.   New York:   Harcourts Brace World.

Concepts of Death in Medicine

Concepts of Death in Medicine Hufsa Ali The concept of death is one that has been shrouded with mystery and wonder for as long as humans have lived and died. The understanding and implications of death have varied greatly across eras and cultures. Historically, there has been little consistency in the understanding of the concept of the event of death, the moment at which one is dead. The Oxford English Dictionary defines death as â€Å"the end of life; the permanent cessation of the vital functions of a person [] or organism[2].† This definition, while precisely written, leaves considerable ambiguity about the diction of the definition itself. It is uncertain what is meant by â€Å"life† and â€Å"vital functions† of a person or organism. Further, one may question whether the vital functions of humans as persons differ from those of humans as organisms. Is death a process rather than an event? If so, when does it begin and end, and when is it appropriate to declare death? Is it possible that a human m ay experience two deaths, death of the person and death of the organism? If so, which death is relevant to medicine? In this paper, I will review the evolution of the definition of death in the Western world in the context of advancing medicine, and explore the implications in relation to organ donation. The philosophical examination of human death has concentrated two underlying questions: what is human death, and how can we determine that death has occurred?[3] The first question addresses the concept or definition of death, while the second concerns developing the corresponding standards: criteria and clinical protocol to be used to declare death. Examples of the answer to the first question include death as the functions of an organism or human death as the irreversible loss of personhood (Stanford Encyclopedia of Philosophy, 2011[4]). Examples of answers to the second questions include the cardiopulmonary standard, the whole-brain standard, and the cerebral standard. It was not until the last century that seeking answers to these questions became the source of a painstakingly complex on-going debate about death, personhood and medicine. Prior to the advent of the stethoscope in the 19th century, cessation of breathing marked the occurrence of death (Daroff)[5]. Then, the loss of pulse became the characterizing event (Jennett, 2001). The Fourth Edition of Black’s Law Dictionary was published in 1951, reidentifying the occurrence of death as the â€Å"cessation of life, defined by physicians as a total stoppage of heart of the circulation of the blood†¦Ã¢â‚¬ [6][7] in the United States. The definition of death (particularly the distinction between death of the body and death of the person) was not relevant because the death of the brain and the rest of the body tissues occurred concurrently. Cardiopulmonary failure inevitably led to irreversible loss of all brain functions, and the irreversible loss of all brain functions quickly led to cardiopulmonary arrest. The issue of distinguishing between cardiopulmonary failure and brain function failure was not clinically relevant until the invention and widespread use of mechanical resuscitation and ventilation devices[8]. A stopped heart could now be restarted and blood could be oxygenated without functioning intercostal and pleural muscles, after the tissues of the brain had began ischemic necrosis[1]. Although they were still occurring, the functions of circulation and respiration were being performed by mechanical respirators and defibrillators. While this did not meet the criteria for death as defined in 1951, it is important to note that such patients would have met the criteria for death as soon as the use of life-support machines was discontinued. Essentially, this meant that either death could be reversed, or that death could be delayed well beyond the failure of vital organs. This also meant that a body with irreversible loss of brain functions could be indefinitely kept â€Å"alive.â €  This highlighted the distinction between neurological failure, and circulatory and respiratory failure. During the 1950’s, several physicians around the world began to recognize the futility of continuing treatment for patients who had lost all neurological functions. In 1954, a neurologist practicing in Massachusetts, Dr. Robert Schwab, noted this while examining a comatose brain hemorrhage patient who was on a respirator. â€Å"The question was, ‘Is this patient alive or dead?’ Without reflexes, without breathing and with total absence of evidence of an electroencephalogram, we considered the patient was dead in spite of the presence of an active heart maintaining circulation. The respirator was therefore turned off and the patient pronounced dead.† In 1959, four French neurologists came to the same conclusion. However, they some of them preferred the term coma dà ©passà ©, meaning â€Å"beyond coma† (Mollaret, 1959)[9]. This was the prognosis of certain death, they argued, but not did not meet the criteria for death itself. Schwab disagreed, stati ng that death of the the death of the nervous system would be death of the patient. In 1963, he proposed criteria to consider certain patients dead in spite of continuing cardiac function: loss of reflexes, a flat EEG, and apnea[10][2]. Over the next five years, he reported having treated 90 such patients. None of them survived and autopsies showed that every one of them had pervasive tissue necrosis in their brains. His findings went on to greatly influence the legal and medical redefining of death. Meanwhile, there were developing concerns about the futility of extensive, expensive medical care for patients whose deaths were imminent and inevitable. In 1957, Pope Pius XII proclaimed that physicians were not obliged to give â€Å"extraordinary† treatment in such cases[11]. In 1962, psychiatrist Frank Ayd published a paper in which he contended that there was a moral obligation to withdraw care when death was inevitable. In 1965, THe American Medical Association held it’s First National Congress on Medical Ethics and Professionalism to detail guidelines for end-of-life-care.[12] As the initiation of the transition from heart to brain criteria for death, the field of organ transplantation was developing. The first successful kidney transplant was performed between live twins in 1954 by Dr. Joseph Murray. Eight years later, Dr. Murray performed a kidney transplant from a cadaver donor. In the years following, liver, lung and heart transplants were performed, using organs from cadavers. Most of the recipients died soon after the surgery. There was the idea that â€Å"live donors† would improve the chances of survival, but physicians were weary about using vital organs from patients that were â€Å"alive† by cardiopulmonary criteria, even if they had lost total brain function. The ethical standard regarding organ retrieval is the Dead Donor Rule (DDR), which prohibits organ vital procurement from donors that have not yet been declared death. This limits possible sources of organs to cadavers that still have salvageable tissues and organs. As medica l technology prevented more and more â€Å"deaths† through advancements in life-support technology, it also accelerated the demand for organs of dead donors, as the capacity to perform successful transplants increased. This growing concern for organ transplantation sources, coupled with the futility of having â€Å"hopeless† patients on artificial ventilation and resuscitation created a climate that facilitated the major change that occurred at the end of the 1960s. In 1968, an Ad Hoc committee was formed at Harvard University to address the â€Å"ethical problems created by the hopelessly unconscious patient[13].† The committee developed criteria similar to the concept of â€Å"coma dà ©passà ©.† Patients who met the criteria[3] would be considered essentially dead, but not actually dead. The final report was titled â€Å"A Definition of Irreversible Coma: Definition of Brain Death.† While this report didn’t explicitly realign the definition of death to brain-based criteria, it outlined appropriate standard of care for comatose patients whose deaths were inevitable and imminent. It was never said outright, but they implied that the death of the brain is the death of the patient, and hinted that the cardiopulmonary criteria for death were obsolete[14]. On the same day as the publication of the Harvard report, the 22nd World Medical Association (WMA) met and announced the Declaration of Sydney. The declaration distinguished the gradual process of the death of cells and tissues from the death of the patient. â€Å"Clinical interest lies not in the state of preservation of isolated cells but in the fate of a person [] the point of death of the different cells and organs is not so important as the certainty that the process has become irreversible.† While it has been overshadowed in the United States by the Harvard report, the WMA’s declaration was the first major committee distinguishment between the death of the body and the death of the person. Throughout the 1970’s, widespread acceptance of the implied Harvard definition grew among the medical community. State legislatures and courts began legally recognizing some form of death based on brain-criterion, although there was little consistency among the criteria across jurisdictions. In 1971, Mohandas and Chou (neurologist and psychiatrist, respectively) published their â€Å"Minnesota Criteria,† based on autopsy discoveries that identified the destruction of the brain stem as the cause of brain death. Thus, the requirement for the EEG was eliminated[4]. Because both respiratory control and consciousness originated [15]in the brain stem, the loss of brainstem function equaled death of both persons and organisms. In the UK, the criteria for brain death was tweaked to exclude the EEG requirement, which meant a patient with detectable cortical activity would be dead in the UK and alive in most of the US. The President’s Commision for the Study of Ethical Problems in Medicine and Biomedical and Behavioral Research was formulated in 1979 to clarify brain death and other biomedical ethics issues. The committee published a report in 1981 that provided a clearer and more practical definition of death than the previous, conceptually ambiguous ones that had been used before. The commission reasoned that death occurred when the â€Å"body’s physiological system ceases to constitute an integrated whole[16].† Because the brain functions as the â€Å"great integrator and regulator,† the death of the organism occurs when the total brain functions are lost, and the organism disintegrates to a collection of it’s parts. As a result, the Uniform Determination of Death Act (UDDA) gave both brain-based and circulatory-respiratory-based criteria a â€Å"separate but equal† status in the eyes of law and clinical care. In the United States, death could now be det ermined by the â€Å"irreversible cessation of circulatory and respiratory functions† or â€Å"irreversible cessation of all functions of the entire brain.† While the UDDA recognized the whole brain standard as a means to determine death, it did not specify the neurological test criteria to be used. It also did not specify the amount of elapsed time required before stopped circulation can be considered irreversible. Different hospitals, providers, and associations used varying sets of tests to determine death. In 1995, the American Academy of Neurology (AAN) attempted to standardize the clinical protocol used to determine death using brain criteria. Tests to be performed were similar to the Harvard report criteria, without the EEG requirement and the 24-hour repeat was left unaddressed. While the UDDA and AAN’s guidelines have brought consistency to the clinical process of determining death, there has been widespread disagreement about the criteria of death itself. The traditional criteria for determining death, the cessation of heartbeat and breathing, have been updated by the UDDA. The circulatory-respiratory standard holds death as the irreversible cessation of circulatory-respiratory function. Leaving aside the implications of word â€Å"irreversible,† this definition may still not be entirely accurate nor practical. Rather than changing the reality of the nature of death, life-support devices and other technologies of modern medicine have shined a light on an aspect of the process of death that was not visible before. Before the possibility of mechanically and artificially continuing respiration and circulation, the failure of these processes were associated with the occurrence of death. However, after such â€Å"death† could be reversed and put off indefinitely, it became apparent that the onset of cardiopulmonary failure was not the moment of death, but simply indicative of death. As Bernat, Culver and Gert argue, heartbeat and regular breathing usually indicate life, but they do not constitute life (Bernat, Culver, and Gert 1981)[17]. â€Å"Life involves the integrated functioning of the whole organism.† Brain-based criteria better suited this understanding of life because the brain is responsible for much regulation of the entire organism. Thus, including brain-based criteria to declare death is seen as an â€Å"update† to the previous understanding of death, not a complete overhaul of it. The transition to brain-based criteria is nowhere near free of criticism. For some, one of the most obvious flaws in the logic behind the brain-based criteria for death was its basis on the idea that the brain is the sole organ responsible for integration of the organism as a whole. If death is defined as the irreversible loss of functioning of the organism as a whole, then only after the complete cessation of all whole-body integrating functions may a patient be considered dead. While the brain plays the biggest role in integrating interdependent functions of the body, somatic integration is a holistic phenomenon that involves organs and tissue systems throughout the body. Immune responses, regulation of blood glucose levels, and hematopoiesis are regulatory functions that can continue to occur without the entire brain (Shewomn, 2001)[18]. Therefore, if the definition of death is understood to be the end of the existence of the organism as an integrative whole, then the death of the whole brain does not necessarily mean the biological organism has died. Brain-based criteria may have been a step in the right direction, but perhaps for the wrong reasons. The significance and necessity of the brain may lie in another aspect of it’s function; one that cannot be attributed to any other part of the body: personhood. The brain is the origin of human thought, reasoning, consciousness, emotion, and self-awareness. If the entire brain is dead, than the human person is dead, even if the human organism continues to live. Another problem with the development of brain-based criteria is again unrelated to the concept itself, but how it came about as standard of care. The ethically dangerous notion that the climate of evolving medical innovation, particularly organ transplantation, had influenced and driven the acceptance of whole-brain death is a very concerning one. When the Harvard committee met to discuss brain death in 1968, they seemed to be concerned about two things: the futility of spending resources on patients with no chance of recovery, and the idea of wasting the organs of these patient’s bodies. Their main focus of concern seemed to not be the well-being of the patients at hand, but protecting the physicians who would withdraw care from patients that would previously have been considered alive. Without the redefinition of death, doctors would have been morally responsible for the death of such patients. Officially, the reason the Harvard committee cited for their efforts was to free up resources spent in vain on untreatable patients. Murray, who was on the committee specified that the primary concern was the dying patient, and that organ transplantation was â€Å"distinct and unrelated,† ()[19] However, many have been skeptical of this separation, arguing that the motive for changing the definition of death had everything to do with organ transplantation. Neurosurgeon Richard Nilges, calls attention to the fact that respiratory and other life-support technologies had been in use for nearly two decades before the hasty formulation of the Harvard committee, and no one had so loudly expressed the urge to end such care. Instead, he points out, that the Harvard committee met less than a year after the first successful heart transplant surgery.[5] Based on the heart-lung criteria of death at the time, the act of removing the heart from a â€Å"live† patient on life support w ould have been the cause of death of that patient. Nilges suggests that a second, underlying reason for changing the criterion of death was the underlying motivation behind the Harvard report: providing organs for transplantation. This situation was an ideal one for organ transplant advocates, because it was an â€Å"opportunity to tailor the definition of death to fit the moral acceptability of transplanting living hearts. Taking a beating heart from a body is not equivalent to taking innocent human life if ‘brain dead’ individuals are ‘defined’ as already dead.† Interestingly, Nilges is not against the idea of using brain-based criteria for death in organ donors. Rather, he disagrees with the way this criteria is practiced. His experience working with such patients and organ transplant teams has left him with disdain towards the practice of organ transplantation. In his paper titled â€Å"Organ Transplantation, Brain Death, and the Slipper Slope: A Neurosurgeon’s Perspective,† Nigles proposes a causal relationship between the changes in the understanding and practice of death declaration to the desires of the insatiable transplant advocates. He recalls trying protect his dying patients from transplant teams, who he compares to hungry vultures eyeing a small, dying animal. He criticizes the unofficial leeway allowed when diagnosing whole brain death, pointing out that over 20% of patients declared dead on brain-based criteria actually had brain activity detectable by an EEG. Save for the finale: [HANS JONAS: uncertainty about border b/w life, death[20]] [1] Necrosis, death of tissue, can be caused by ischemia, insufficient blood supply to those tissues. Brain tissue is among the body’s most sensitive to ischemic hypoxia, and is the earliest to die. It is possible for the rest of the body to regain function after a period of time without oxygen, but the brain to have lost it permanently. [2] Schwab’s criteria were: loss of reflexes (dilated and fixed pupils, no elicitable reflexes, and no independent movements), a flat EEG (electroencephalogram detecting no electrical activity in the brain), and apnea (inability to spontaneously breath). [3] Harvard report criteria included the following: (1) deep coma, no withdrawal from painful stimuli, (2) cranial and spinal arreflexia, (3) apnea, persistent after disconnected from ventilator for 3 minutes, (4) flat EEG, no detectable electrical brain activity, (5) exclusion of hypothermia or drugs, which may sometimes cause false-negatives in the above tests, and (6) evaluation repeated twice, 24-hours apart. [4] The brainstem is the pathway through which the brain (cerebrum and cerebellum) sends and receives signals to and from the rest of the body. If the brain stem is dead and all brainstem functions are lost, then the communication between the brain and spinal cord is severed. A body of a patient with a dead brain stem is functionally equivalent to that of a patient with whole brain death. Thus, any electrical activity in the cerebrum is not going to affect the outcome of tests of the rest of Harvard criteria. [5] The first successful heart transplantation was performed in December of 1967. The committee developed their criteria in August of 1968, a mere eight months after the heart transplant. [1]Write later [2]Cite oxford english dictionary [3]either cite Stanford Encyclopedia of Philosophy. Definition of Death [4]Written 2007, revised 2011. Review? [5]Fix citation [6]Cite this [7]Black Laws Dictionary, 1951. 4e [8]cite source: either de goergia, stanford, or daroff [9]#8, De Geogia [10]cite swchab, from de georgia, pg 674 [11]Citation needed [12]another someone talks about this conference, but says something more relevant. [13]cite: beecher. (From De Georgia, 674. bottom left. [14]cite this [15]use a different word. Plagiarism [16]cite this: de georgia, #48, 49. pg 676 [17]cite. (stanford encyclopedia, 1. mainstream view) [18]http://www.ncbi.nlm.nih.gov/pubmed/11588655 [19]Murray, letter to Beecher, calling for committee formulation/meeting. De Georgia # 26, pg 675 [20]#40 De goergia, pg 676

Clash Of The Titans | Film Review

Clash Of The Titans | Film Review The film Clash of the Titans (2010), directed by Louis Leterrier, is a serious battle for power between men and kings, and kings and gods. However, the battle of gods themselves could devastate the world. Perseus (Sam Worthinfton), a demigod brought up as a man, is powerless to put away his family from Hades (Ralph Fiennes), the unforgiving god of the underworld, who feeds himself from human fear. Perseus put himself upfront to organize a dangerous mission to defeat Hades before he could overthrow Zeus (Liam Neeson) and expose hell on earth. Leading a group of courageous men, Perseus heads off on a dangerous journey into the heart of forbidden worlds. Fighting with worldly demons and fearsome beasts, he will only go beyond this challenge once he recognizes his power as a god and disregards his fate and create his own destiny. The film begins with a narration portraying the three Olympians who fought the Titans in the past: Zeus, Poseidon (Danny Huston) and Hades. Hades showed their way of conquering the Titans with his own creation, the Kraken, a giant sea monster. After the fall of the Titans, Zeus created humans and lead them while Poseidon governs the sea, On the other hand, Hades who have been betrayed by his brother Zeus, was forced to lead the Underworld and discovers an unusual way to have his power from humans that was different from his brothers gaining theirs from prayers. For him, he can obtain power through human fear. Thousand years later, Spyros (Pete Postlethwaite), a fisherman, comes across with a coffin floating in the sea, where he found a baby, Perseus, lies together with his dead mother, Danae. The fisherman comes to a decision of bringing up Perseus as his own son. Years passed, Perseus and his family are in the sea, fishing together when they saw a group of soldiers from the army of Argos tearing down a statue of Zeus as a proclamation of war against the gods. Hades reveals himself and orders harpies to kill the soldiers. Moreover, as he sees the fishing boat of the family of Perseus, he also destroyes it and sinks into the middle of the sea. As Perseus tries to rescue his family, without any reason, the surviving soldiers of Argos detain Perseus back to their homeland. During the feast for the soldiers who survived the battle, King Cepheus (Vincent Regan) and Queen Cassiopeia (Polly Walker) of Argos are differentiating themselves together with their daughter, Andromeda (Alexa Davalos), t o the gods to protect their kingdom. Moreover, after persuading his brother to loose the monster on humankind to reprimand them for their disobedience, Hades shows himself in the courtroom before executing the remaining soldiers while Perseus is untouched. Hades reveals that Perseus is a demigod son of Zeus. He also warns that if Princess Andromeda is not sacrificed to the Kraken, Argos will be devastated in ten days. Hermes (Alexander Siddig), the messenger of god, comes up to Zeus on Olympus to reveal where his son Perseus is. While Hermes recommends giving Perseus a safe haven, Zeus proclaim that he shall have his own fate together with the other mortals. The king asks for the help of Perseus after he is imprisoned. Perseus refuses at first until he meets Io (Gemma Arterton), a woman whose not growing old as a reprimand for refusing to be seduced by a god. Io then tells him about his origin and the punishment done by Zeus on Acrisius (Jason Flemyng), the former king of Argos, who was married to Danae, for opposing the gods. Acrisuis immediately orders the death of Danae and the baby Perseus after her giving birth. He decides to have them in the coffin float into the sea. However, an infuriated Zeus struck Acrisius with lightning, resulting to a dreadful damage to him. As Io finished her story and after knowing that defeating the Kraken will let him to have his vengeance with Hades, Perseus agrees together with Argos most formidable soldiers. They are also accompanied by Persian monster-hunters named Ixas (Hans Matheson) and Kucuk (Mouloud Achour), and Io, get on board on a mission to look for the Stygian Witches, the three women with gray skin and have one eye. Into the woods, Perseus and the soldiers discover a sword created in Olympus which will only illustrate its true power in the hands of Perseus. Wandering away from the group, Perseus runs into Zeus sacred herd of flying horses, the Pegasus. On the other hand, Perseus turns down the gods offering- the sword and the pure-black Pegasus, as he doesnt want to be a god. As per the order of Hades, Calibos attacks the group of Perseus and tries to take his life. Number of soldiers was killed in this act but Calibos failed to murder Perseus, and loses his hand before he can get away. But the drop of Calibos blood develops giant scorpions from the sand, which then attack Perseus and his men. Though the group was able to kill several scorpions, many of the soldiers were slain as well, and those who survived faced more monsters to fight with. Perseus and his group were saved by Djinn, a bunch of desert sorcerers who were humans before but changed their human flesh with ash and dark magic. The Dj inn were able to put the scorpions under their spell. Helping Perseus to heal his wounds, Sheikh Suleiman (Ian Whyte) Djinn leader, decided to join Perseus group to witness the gods obliteration of Argos. These brave men reached the Garden of Stygia, wherein they gathered information, from the Stygian Witches, that the head of the Gorgon Medusa (Natalia Vodianova) has the power to kill the Kraken, with the risk that they might be slain in the process. As they continue their journey, Zeus got to see Perseus to offer him a sanctuary at Mount Olympus, but still, Perseus refuses the offer. Instead, Zeus gives him a golden drachma, which he learns to be a means to buy off Charon for a way to the Underworld. On the other hand, Io was left outside of Medusas den, where a spell was cast that no women will be able to enter the area. Perseus, together with the remaining soldiers, gives all their strength to stay alive, but one by one, they turn into stone with her gaze. With Suleiman self-destructing himself and the sacrifice of Draco (Mads Mikkelsen), Perseus is able to behead Medusa. He came out in time to witness how Calibos kill Io by thrusting a sword from behind. Perseus challenges Calibo s in a battle and kills him with the sword given to him by the gods, which transforms Calibos back to his human form. As Acrisius draws in his final breath, Hades power leaves him and tells Perseus to refuse to be a god. Perseus stays with Io until she passes on, then rides on to Pegasus and prepares himself back to Argos with Medusas head. At the same time, some of Argoss citizens founded a cult of Hades, who is planning to sacrifice Princess Andromeda to the Kraken, in opposition to the kings wishes. Hades enlightens Zeus that the fall of Argos will bestow him enough power to remove the other Olympians from power. He then left Zeus defenseless to guarantee his triumph. On his way to Argos, Hades sends out his harpies to obstruct Perseus way back to Argos. Perseus overcomes the number of harpies sent by Hades and let the Kraken met the gaze of Medusa which turns the monster into stone. During this upheaval, King Cepheus was killed by the cult leader and has been crushed under the debris of the broken body of stoned Kraken. Hades shows up and scorns Perseus that he cannot kill him, since he is a god. Perseus snaps that Hades can live forever but it will not be in the world of men. He then uses the sword to send away Hades back to the Underworld. After saving Argos from destruction, Princess Andromeda advocates that Perseus should be the king and rule Argos at her side. Zeus gives Perseus a visit and offers to make him a god. Perseus declined both propositions. Zeus then advised Perseus that when Hades gathers enough fear from humankind, he will arise and return to rule the world in darkness. But Perseus will be prepared enough to stop Hades for the s econd time since he has all his intention of staying on Earth. With this, Zeus brings Io back to life, and the two rejoice while Pegasus flies above them. COMMENTARY ON THE FILM: CLASH OF THE TITANS (2010) The movie is a remake of the film Clash of the Titans that was aired almost thirty years ago. The first film was produced in 1981 and the new version of the movie is an inadvertently entertaining retelling of a classic Greek mythology. Fanatics of the earlier version of the film will not be in favor of the remake because of their concept of perfection of the original version. Thus, if movie goers will search for the original substance of the movie, they will be dissatisfied. However, for viewers who are searching for simple, enjoyable and exploration loaded with enormous mythological creatures of the original edition they will definitely take satisfaction in this movie directed by Louis Leterrier and distributed by Warner Bros. Picture. As a Turkish person, I chose BM Magazine to publish this review since BM Magazine accepted to publish my article in their May issue. At first, I am encountering problems in conceptualizing the film since many parts of the original version were cut and modify. However, since I was inspired by the movie Avatar which was aired in 3 Dimension (3D), the curiosity grew more as it was aired in more than hundred theaters in UK last month. As I watched this movie, I found out that this was an action-packed movie from beginning to end and I believe that generation of viewers today will be convinced that this film is better than the 1981 film in term of effects and cinematography. Many of us know that the element of Greek mythology is filled with sex, anger, and envy and other shortcomings. The film Clash of the Titans portrays the story of Perseus, son of Zeus- the ruler of the heavens, as he leads the humans in a combat against the gods of Olympus. Particularly, Persues has an unwell will against Hades, brother of Zeus and ruler of the Underworld, since the god killed Perseus adoptive family out of anger. Zeus adores the humans and believes he needs their worship, but Hades disagrees. He thinks that humans, particularly those in Argos, are high and mighty who believes they do not need gods. At the time that Queen Cassiopeia compared her daughter Andromeda, and claims that her daughter is more beautiful than Aphrodite, the gods instigate war on humans to teach them a lesson. The screenwriters, Travis Beacham, Phil Hay, Matt Manfredi felt that political power struggle between the gods was not interesting enough, so the film focused on vengeance. Aside from Zeu s and Hades, no other gods or goddesses are integrated and it seems that their arguments are better to be just a reflection rather than the films driving factor. The writers chose to keep the majority of the elements, order of events and even the dialogues from the original film, but then decided to change certain elements or add characters in the story. From the original movie, characters of Andromeda and Calibos have much greater roles. Also, other characters like Poseidon, Ammon, Pegasus, Hera and Thetis, who played significant roles in the original, have either minimal roles or do not appear in this remake. Some personage have different roles but are in both films like Danae, who is the wife of Acrisuis and mother of Perseus, but from the original film, Danae is the daughter of Acrisuis impregnated by Zeus. With the original film, Perseus love interest is Andromeda, and not Io, whom he married and became the King of Argos, which he declines in the remake. Things that the two films have in common are the attack of the scorpion, the combat with Medusa, and the final with the Kraken, and for Perseus being the son of Zeus. The movie started out as 2-dimensional film, but with the release of the 3-D movie Avatar, the Clash of the Titans was converted to 3-D. According to Director Leterrier, The adaptation to 3-D adds unbelievable depth to each scene, enhancing the chronicle and providing an all-encompassing clash familiarity. There are movies that are intended to be produced in 3-D. However this film was originally intended for 2-D version, but because of the success of Avatar, the director and producer decided to release a new version also intended for viewers who wanted to watch this film in 3-D. This new version in 3-D adds to the excitement but not to the entire effect of the story. The special effects, mostly digital, have been purposely made to gather some with the original film. However, viewers of this film may be perplexed to find the substance of 3-D since the dimensional layer does not agree with the camera. Moreover, the high dimensions of graphics also exposed little to the viewers. Thus, I would recommend to watched the film and in 2D instead of 3D to further appreciate the context of the film. On the other hand, the movie is definitely filled with striking settings and extraordinary creatures. Pegasus, the flying horse, is portrayed beautifully and the massive numbers of scorpions are indisputably frightening. The Kraken, a gigantic sea monster, is less remarkable than the trailer would have you believe. The film was shot in very lavishing scenery. As for the cinematography, it is very vibrant- jumping out and zooming in or out around each character all the way through ravines and desert landscapes. Many of us know that Greek mythology gives emphasis on power, intelligence and beauty of the gods and goddesses. However, the interesting aspect such as beauty is not shown in the new version. Not a single goddess delivered an argument in this film. But still, Io is able to fill the missing part of the movie, showing more reasonable and more likeable female character and love interest than Andromeda. Moreover, I find the movie drew a cast of familiar faces. Sam Worthington showed only one emotion throughout the movie, seriousness, as Perseues, the most important character in the film. Liam Neeson, Ralph Fiennes and Dunny Huston portrayed as the three main Greeks gods: Zeus, hades and Poseidon. Not much participation for Neeson and Huston has very little to do with the movie. Character of Io, played by Gemma Arterton, a woman cursed with agelessness and watch over Perseus through his mission. Alexa Davalos as Andromeda, the princess offered as a sacrifice for the Kraken. In over all, Clash of the Titans is perhaps the first 3-D movie intended to the generation of today. However, it is very hard for me to visualize that this movie will incarcerate wider audience since more of the viewers will undoubtedly attend for its nostalgia value. Moreover, it offers no-frills approach for classical movies with monsters, chaos, and violence abundantly with just enough limits not to over step the leap of the PG-13 rating. For those viewers who will watch this movie in 2D might debate that it harkens back some of the classic fantasy adventure in the middle decades of the 20th century. Thus, I find the movie a flawed but a very entertaining remake of the Greek mythological elements.

The Lovable Mrs. Bennet of Pride and Prejudice Essay -- Pride and Preju

The Lovable Mrs. Bennet of Pride and Prejudice      Ã‚  Ã‚   The general impression of Austen's novels, which critic D. W. Harding says relieved him of any desire to read them, is that they offer readers a humorous refuge from an uncertain world.   In his article "'Regulated Hatred': An Aspect in the Work of Jane Austen," Harding claims that this impression is misleading and that Jane Austen is actually very critical of her society, covertly expressing downright hatred for certain members of it by means of caricature.   Mrs. Bennet, from Austen's Pride and Prejudice, is one of these "comic monster[s]".   Harding claims that in order to view Mrs. Bennet as anything other than utterly detested by Austen one must ignore this Austen's summary of her at the end of Chapter One: "She was a woman of mean understanding, little information, and an uncertain temper."1   Actually, Austen's Mrs. Bennet is much more complex than Harding acknowledges.   Austen's initial summary notwithstanding, Pride and Prejudice even loo ks at Mrs. Bennet forgivingly.   Her behavior is often provoked by her environment: both her society and her family.   Because she helps, or tries to help, her family, Mrs. Bennet's ludicrous actions can even be seen as lovable.        Ã‚  Ã‚  Ã‚  Ã‚   Mrs. Bennet's society and family condemn her to a series of conventional roles.   Mrs. Bennet snags a husband by playing the role of the good-humored, pretty young woman.   Mr. Bennet also believes that good looks will make a good wife, and he marries her.   However, once she and Mr. Bennet take off their courting masks and Mr. Bennet discovers her "weak understanding and illiberal mind, [which] had very early in their marriage put an end to all real affection for her" (155),... ...Mrs. Bennet in a critical and funny, but understanding way, Austen becomes the satirist that Harding claims she is not.   As a satirist, Austen helps us to deal with the Mrs. Bennets in our world.   While exposing their weaknesses, we can forgive them and even try to help them.   We can also, by understanding how a Mrs. Bennet comes to act like Mrs. Bennet, keep our sisters and ourselves from becoming like her.                   Notes    1. D. W. Harding, "'Regulating Hatred': An Aspect in the Work of Jane Austen," in Jane Austen, Pride and Prejudice, ed. Donald Gray (New York and London: Norton, 2001), 297-298.    2. All references to Jane Austen's Pride and Prejudice are from the Norton Critical 3rd edition, ed. Donald Gray (New York and London: Norton, 2001).    3. Harding, 297.    4. Harding, 297.      

Essay on Freedom and Satan in John Milton’s Paradise Lost

Freedom and Satan in Paradise Lost  Ã‚  Ã‚  Ã‚     Ã‚   Satan's primary operational problem in Paradise Lost is his lack of obedience. The fundamental misunderstanding which leads to Satan's disobedience is his separation of free will from God's hierarchical power. In the angel Raphael's account, Satan tells his dominions, "Orders and Degrees/Jarr not with liberty" (5.792-93). Tempting as this differentiation seems, Satan is mistaken. Free will and hierarchical power are not mutually exclusive, as Satan suggests, but overlapping concepts. Even though Satan has been created with sufficient freedom to choose to disobey, he tacitly acknowledges God's sovereignty when he exercises his choice. Satan is constrained existentially, from the outset, by having a specific choice to make about whether or not to obey God. Satan, just as all angels, demons, and humans, may exercise his freedom as assent or dissent, for God had created him "Sufficient to have stood, though free to fall./Such I [God] created all th' ethereal powers/And spirits . . . /Freely they stood who stood, and fell who fell" (3.99-102; cf. 5.549). If Satan would choose neither to assent nor to dissent, thereby refusing to exercise his free will, he would be discarding his free will. But this is impossible, as the demons determine in counsel in Book II; so long as he exists, Satan must make choices with respect to his possible obedience to God. If Satan's first mistake was to completely divorce his free will from God's power in giving him that freedom, his second mistake occurs in his conception of what it means to exercise that freedom. God says that "Not free, what proof could they [Satan et al.] have given sincere/Of true allegiance"? (3.103-04). But Satan has exactly the... ...lthough one can choose, as Satan does, to dissent and disobey, such purportedly self-creative acts are in fact merely an acknowledgment of God's hierarchical power. When pride and ambition to be like God prevent humans from hearing the "umpire Conscience" God has placed within us (3.195; Satan likewise has been given conscience enough to remember the call to obedience, 4.23), we become like Satan, for the same reasons constrained to listen only to the Satanic voice dissenting in our ears. Works Cited Scott Elledge, ed., Paradise Lost, second edn. (NY: Norton, 1993). Millicent Bell, "The Fallacy of the Fall in Paradise Lost," PMLA 68 (1953), 863-83; here p. 878. Northrop Frye, The Return of Eden (Buffalo: Univ. of Toronto, 1965), 39-40, 43 Barbara Lewalski, Paradise Lost and the Rhetoric of Literary Forms (Princeton: Princeton U. , 1985), 174.   

A Child Called IT Essay -- essays research papers

A Child Called IT What did I learn from this book? The only thing that comes to mind when I'm asked that question is pain. I didn't know what real pain was until I tried to understand what this child went through. Everything that meant anything to him, his family, those who should be the closest, was drowned out. He didn't know what to think and so often in the world today, we are naive. We don't have a clue of how life could be, and of how lucky we truly are to have the kinds of backgrounds that we were blessed with. On a more professional note, I learned that this type of obsession can take over one's life until they don't know what is real anymore. All they have in their mind is their uncontrolled illusion. It is really hard to not get angry at these people. One must realize that they...

Charities Essay

The legal definition of charity has historically been somewhat elusive and stands distinct from any understanding of charity in a general or popular sense. As Lord Wright observed, in its legal sense the word â€Å"charitable is a word of art, of precise and technical meaning†[1]. Viscount Simmonds further remarked that, â€Å"no comprehensive definition of legal charity has been given either by legislature or in judicial utterance, there is no limit to the number and diversity of ways in which man will seek to benefit his fellow men†. The Preamble to the Charitable Uses Act 1601, also referred to as the Statute of Elizabeth I, contained a list of purposes which were then regarded as charitable. It assumed a central role for the courts as a reference point or catalogue of accepted instances of charity until almost 300 years later when Lord MacNaughten in the Pemsel case, famously classified charitable objects into four principal divisions: (i) trusts for the relief of poverty, (ii) trusts for the advancement of education, (iii) trusts for the advancement of religion, (iv) trusts beneficial to the community not falling under any of the preceding heads. These four heads of charity were used as reference whenever the inherent charitable nature of a purpose or institution was questioned until the Charities Act 2006 received royal assent. Section 2(2) of the 2006 Act now provides a modern statutory definition of charity by listing 13 descriptions of purposes deemed charitable at law. In order to be charitable, an organisation has to be established for one or more purposes within the descriptions recognised by the law as capable of being charitable, and for the public benefit. Charity law in England and Wales has developed within the context of the traditional monotheistic religions but it has embraced for many years religions other than Christianity and Judaism. In Bowman[3], Lord Parker effectively held that it was not just the promotion of Christianity that would be recognised but that the Courts of this country were not precluded â€Å"from giving effect to trusts for the purposes of religions which, however sacred they may be to millions of His Majesty’s subjects, either deny the truth of Christianity or, at any rate, do not accept some of its fundamental doctrines†. Furthermore in the Commission’s Scientology[4] decision it was firmly established that â€Å"The law does not prefer one religion to another and as between religions the law stands neutral†[5]. The English courts have, for a long time, resisted closely defining what makes some belief systems religious and others not. However in the Scientology case, the Commissioners accepted that there are various characteristics of religion which can be discerned from the legal authorities: †¢ Belief in a god or a deity or supreme being – R v Registrar General[6] †¢ Two of the essential attributes of religion are faith and worship: faith in a god and worship of that god – South Place Ethical Society[7] †¢ To advance religion means â€Å"to promote it, to spread the message ever wider among mankind; to take some positive steps to sustain and increase religious belief and these things are done in a variety of ways which may be comprehensively described as pastoral and missionary†. United Grand Lodge v Holborn BC[8]. Having considered these characteristics, the Commissioners concluded that the definition of a religion in English charity law was characterised by a belief in a supreme being and an expression of that belief through worship. This definition is further refined in the 2006 Act where s2 (3) a gives a partial definition of the word religion. However, the law does not automatically recognise as a religion everything that may designate itself as a religion and there are some principles to which a purpose must conform if it is to be regarded as within the Charities Act’s description of ‘the advancement of religion’. These general principles are gathered from the common law of England and Wales but also take into account the body of law which has developed concerning the European Convention right to freedom of thought, conscience and religion. As a general proposition, for its advancement to be capable of being charitable in this context, a religion should have a certain level of cogency, seriousness, coherence and importance[9]. Also, in order to be charitable for the advancement of religion, the content of any system of faith and worship has to be of a positive nature, impacting beneficially on the community. Sir John Wickens, V-C. in Cocks v Manners[10] observed: â€Å"It is said, in some of the cases, that religious purposes are charitable, but that can only be true as to religious services tending directly or indirectly towards the instruction or the edification of the public†¦Ã¢â‚¬  Hence, to be charitable a religious purpose has to be serious, tend directly or indirectly to the moral and spiritual improvement of the public as well as being for the public benefit. In Holmes v Attorney General[11] Walton J commented: â€Å"†¦ It is not for the benefit of the adherents of the religion themselves that the law confers charitable status, it is in the interests of the public. † Hence, as a general proposition, in the case of charities for the advancement of religion the purpose must not simply be for the benefit of the followers of the particular religion. Formerly, the proposition stated that â€Å"as between different religions the law stands neutral, but it assumes that any religion is at least likely to be better than none†[12]. Plowman J in Re Watson[13] considered a case for the publication and distribution of the fundamentalist Christian writings of an individual where he quoted authority that the court does not prefer one religion or sect to another and said that â€Å"where the purposes in question are of a religious nature †¦ then the court assumes a public benefit unless the contrary is shown†. He then went on to say that the only way of disproving a public benefit is to show that the doctrines inculcated are adverse to the very foundations of all religion, and that they are subversive of all morality. However, that part of the judgment being inconsistent with the judgment of the court of appeal and opinions given by the House of Lords in Gilmour v Coats, where it was held: â€Å"†¦the question whether a trust is beneficial to the public is an entirely different one from the question whether a trust is for the advancement of religion†, it is not regarded a binding. Since the Charities Act 2006, there is no longer any presumption that, because a purpose falls within the description â€Å"the advancement of religion†, it is for the public benefit. Section 3(2) of the Act provides: â€Å"In determining whether [the public benefit] requirement is satisfied in relation to any †¦purpose, it is not to be presumed that a purpose of a particular description is for the public benefit†. Hence, with the removal of the presumption and in the modern context the proposition may now be interpreted as meaning that advancing religion can be seen as a public good if such advancement can be demonstrated to be in relation to a system having a benign and positive content which is being advanced for the benefit of the public. Over the years, there are some purposes which, despite being beneficial and religious and indeed seriously religious, did not fall within the legal framework. For example, fostering private piety, although being a religious activity, is not a charitable purpose due to the absence of benefit to the public. In Cocks v Manners[14] (supra) it was said that â€Å"a voluntary association of women for the purpose of working out their own salvation by religious exercises and self-denial seems to have none of the requisites of a charitable institution. † In the Re Joy[15] case it was held that the real object contemplated by the testator was the non-charitable purpose of improvement of the membership of a society by prayer. Further, in Re White[16], it was held that â€Å"a society for the promotion of private prayer and devotions by its own members and which has no wider scope, no public element, and no purpose of general utility would not be charitable†. Lord Simonds in the Gilmour[17] case later confirmed the decision in Cocks v Manners and said that activities â€Å"good in themselves but solely designed to benefit individuals associated for the purpose of securing that benefit, which may not have some repercussions or consequential effects beneficial to some section of the general community† do not meet the prerequisites of a charitable institution. In Re Warre’s Will Trusts, on the matter of a retreat house, Harman J said: â€Å"Activities which do not in any way affect the public or any section of it are not charitable. Pious contemplation and prayer are, no doubt, good for the soul, and may be of benefit by some intercessory process, of which the law takes no notice, but they are not charitable activities. † Thus, in Re Hetherington[18] it was held that the celebration of a religious rite in private does not contain the necessary element of public benefit since any benefit of prayer or example is incapable of proof in the legal sense and any element of spiritual or moral improvement (edification) is limited to a private not public class of those present at the celebration. However, in the same case it was also held that the holding of a religious service which is open to the public is capable of conferring a â€Å"sufficient public benefit because of the edifying and improving effect of such celebration on the members of the public who attend. † There are also other purposes related to religion whose pursuits have not been considered as charitable because the purpose itself is not exclusively charitable. For example a trust ‘for Roman Catholic purposes’ may not be for exclusively charitable purposes furthering the Roman Catholic faith[19]. Also a gift to an Anglican vicar of a parish â€Å"for parochial institutions or purpose†Ã¢â‚¬â„¢[20] was not considered charitable. A bequest to an archbishop to be applied â€Å"in any manner he might think best for helping to carry on the work of the Church in Wales†[21] is not charitable either and neither is a generally stated purpose â€Å"for religious, educational and other parochial requirements†[22]. On the other hand, In Re Schoales[23], it was clarified that there is no distinction, from the point of view of validity as a gift for charitable purposes, between a gift to the Church of England and a gift to another Church. A gift for the general purposes of a particular church or denomination or faith community falls are considered in law as a gift which has to be applied only for such of its purposes as are for the advancement of religion for the public benefit, and hence charitable. As mentioned above, charitable purposes require some promotion or advancement that is to â€Å"spread its message ever wider among mankind; to take some positive steps to sustain and increase religious belief†[24]. Proselytising is one way of advancing religious purposes[25] but it may raise public benefit issues if it breaks the law or results in harm or detriment. Therefore, it would not be compatible with public benefit principles for an organisation to seek to inhibit anyone from their rights of freedom of thought, conscience or religion (Article 9 ECHR) and to manifest or change such beliefs. This matter was considered in Kokkinakis v Greece[26] and the court in considering attempts to forbid activities of a Jehovah’s Witness confirmed that a democratic society has a plurality of beliefs and held that freedom to manifest one’s religion includes the right to convince one’s neighbor. But, the court drew a clear distinction between bearing Christian witness and improper proselytism by stating that the former was true evangelism and the latter representing a corruption or deformation of it. Furthermore, proselytising being unlawful in some countries, the Commission dealt with the issue of whether it was possible to recognise a religious purpose as charitable in England and Wales which is not charitable and may be illegal abroad in its annual report in 1993 which mentioned: â€Å"One should first consider whether they would be regarded as charities if their operations are confined to the United Kingdom. If they would, then they should be presumed also to be charitable even though operating abroad unless it would be contrary to public policy to recognise them. Hence, an organisation whose purpose is to proselytize, even if its activity is carried out internationally, may be charitable in England and Wales unless it causes harm or detriment which outweighs the public benefit. The High Court considered the statement in the Sonsino case[27] in 2002 and upheld it. However, it still remains unclear as to what the courts would rule contrary to public policy. Another way of advancing a religion would be by means of undertaking pastoral work. However, where a charity is operating solely for the purpose of advancement of religion, then any secular pastoral work which it undertakes should be as a means of advancing the particular religion. A convent in Cocks v Manners[28] was held charitable and there the nuns were engaged in exterior works (teaching the ignorant and nursing the sick) as part of their religious work. In the United Grand Lodge[29] case, Donovan J said that taking positive steps to sustain and increase religious beliefs was something done â€Å"in a variety of ways which can be comprehensively described as pastoral and missionary†. More recently, the Pilsdon Community House, a religious community living according to Christian principles and giving practical help in cases of drug addiction, drink, having been in prison or loneliness was considered in Re Banfield[30]. The court held that the fact that a religious community makes its services available to those of all creeds and of none does not prevent it being a charity for the advancement of religion also that furthering the purposes of the community amounted to the advancement of religion.