Pollution Analysis Essay Example

Pollution Analysis Paper Analysis Pollution can take many forms. The air we breathe, the water drink, the ground where we grow our food, and even the increasing noise we hear every day all contribute to health problems and a lower quality of life. Pollution is every,Inhere. Pollution is the unwanted introduction of substances that harm or destroy the atmosphere and our environment. The Economy is slowing third world nations have political unrest. Our culture is more focused on obtaining material possessions then addressing our geological problems. In this essay I am going to identify the history, causes of pollution, effects on our planet, and the solutions to the Problems of pollution in our world. With the growth of cities and industrialization urban waste and pollution are an important part of history. From the rise of the first urban settlements until the emergence of mega cities in the 20th century, the scale and intensity of pollution has increased. Here is a brief history of pollution on our planet. In Ancient Civilizations air pollution was common it came from dust, wood smoke, tanneries, animal manure and other things. Water pollution was less ever in come civilizations. Israel and Hindu cities tend to have less pollution due to strict religious codes about cleanliness. During the Middle Ages in the Renaissance area timbering in the foresting in England, France, German leaves large areas of deforestation. This led to the change to using coal as a replacement for wood as a use of power. We will write a custom essay sample on Pollution Analysis specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Pollution Analysis specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Pollution Analysis specifically for you FOR ONLY $16.38 $13.9/page Hire Writer The Era of Enlightenment reason begins to overcome superstition. Also during this period Ben Franklins starts his flight against Water Pollution. He led of group of Philadelphia to petition the government to stop tannery factories from dumping in the creek, a arbitrary of the Delaware River. He was trying to create awareness about socially responsible investing. The petition stopped the dumping, and helped to set a precedent for the future fight against water pollution. Ben Franklin was a big proponent of the good quality of life through a healthy environment. He advocated for socially responsible investing. He was a keen observer and worked hard to keep the city of Philadelphia environment clean and pure for all its citizens. He saw the necessity for green business even back then. He believed that people could be better and healthier also, by making a few changes in their lifestyle. His foresight, saws observation, and determination to create awareness for environmentally conscious companies to protect the environment, are many of the reasons Ben Franklin is a genius in American history. Anther important person during the Era Of enlightenment was Thomas Robert Malthusian. Malthusian was a British scholar; influential in controversial, in economic, political, social and scientific thought. Malthusian thought that the dangers of population growth depends on the sustainability of the earth † The power of population is indefinitely greater than the power in earth to produce subsistence for man†. In many ways these men were the founding fathers of our environmental polices that we see today. The industrial revolution led to horrifying living conditions people began to understand that unsay Atari living conditions and water contamination contributed to disease epidemics. This new awareness prompted major cities to take measures to control waste and garbage. Progress is slow but the common interest was to establish purr drinking water and sanitation. This was because of the epidemics of typhoid. Conservation of wilderness also started to take place because of a extremely old tree called the â€Å"mother of the forest’. Mother of the forest was an ancient and huge Sequoia Denton tree. The tree lived in the Sierra Nevada Mountains in eastern central California, Ignited States. In the mid-1 sass, Chicago built the first major sewage system in the United States to treat wastewater. Soon, many other U. S. Cities followed Chicago lead. In the United States, industrial chemicals and wastes, including sulfuric acid, soda ash, mercuric acid, limes, dyes, wood pulp, and animal byproducts from industrial mills contaminated waters in the Northeast. Air pollution from automobiles from the industrial processes, and the burning of coal in stories and in homes also became a serious problem. In the 19th century, episodes of smog in cities like New York and London resulted in many deaths. The rising problems of pollution led to the formation of the National Coast Anti Pollution League. It was formed by municipal officials from Atlantic City to Maine who are concerned with oil and sewage pollution detracting from tourism from the areas. Led by Gifford Ponchos, Teddy Roosevelt the league succeeds with an international oil dumping treaty passed by Congress in 1924. In late October of 1948, 20 people were asphyxiated and more than ,000 became seriously ill as the result of severe air pollution over Donors, Pennsylvania. In response was The Air Pollution control act that declared that air pollution was a danger to public health and welfare, but preserved the primary responsibilities and rights of the States and local government in controlling air pollution. The Seventies was the decade of awakening and clean up it began with the birth of the Environmental Protection Agency. The EPA is an agency of the federal government of the United States charged with protecting human health and the environment, by writing and enforcing isolations based on laws passed by Congress. Water Pollution was greatly decreased through a massive sewage treatment expansion program. Rivers, which were once sewers, now begin a gradual return from the grave. Air Pollution is cut back dramatically through use of catalytic converters on new cars that use only unleaded gasoline. From 1980-1990 Disasters showed the world the fragile side of industrial technology. The world’s worst industrial catastrophe took place in India a leak of methyl cocaine’s gas from the union Carbide India Limited pesticide plant and resulted in the exposure of he hazardous gas to the local communities. Estimates vary on the death toll. The official immediate death toll was 2,259 and the government of Madhya Pradesh has confirmed a total of 3, 787 deaths related to the gas release. Others estimate that 3,000 died within weeks and that another 8,000 have since died from gas-related diseases. Through these tragedies Environmental reform starts to gain momentum. Several peace seeking ships looking to stop the water pollution were bombed. The Rainbow Warrior was one of the first to take active action on the seas. The ship was active in supporting a number of Greenback protest. In 1990 the Persian Gulf War started to take place. Insurgents burn oil wells releasing hazardous gases into the ozone. In politics there becomes a standoff between conservatives and liberal factions in congress between environments over economic development. China begins production of the Three Gorges Dam, which became the world’s largest capacity hydroelectric power station with a generating capacity of 18,200. The new millennium brought upon changes in the presidents views of environmental policies. Bill Clinton a conservative steps down from the presidency and George Bush steps in to take his place. George Bush lowered environmental regulation on behalf of industry. Barack Obama in 2009 restored environmental and conservative missions for LSI regulatory agencies. Global Climate change became a pressing problem. An increasing number of scientist are warning that Global climate change is problem being created by pollution. All around us there are becoming more and more signs that our long history with pollution is going to have a negative effect on our planet and future generations More than two billion of the world’s poorest people still rely on biomass: wood, charcoal, Animal dung, crop wastes and coal-burning for household energy needs. Use of these fuels indoors leads to high levels of harmful pollution. This exposure increases the risk of diseases such as pneumonia, chronic respiratory disease and lung cancer. This accounts for a substantial proportion of the global burden of disease in developing countries. Evidence is also emerging that exposure may increase the risk of a number of important conditions such low birth rate and cataract. Household pollutants are contaminants that are released during various products in daily life. Hazardous household products fall into six broad categories: household leaner’s, paints and solvents, lawn and garden care, automotive products, pool chemicals, and health and beauty aids. Many commonly used household products in these categories release toxic chemicals. Household cleaners, paints and solvents, lawn and garden care, automotive products, pool chemicals, and health and beauty aids. Many commonly used household products in these categories release toxic chemicals. Insecticides, pesticides, weed killers, and fertilizers that are used for maintaining one’s lawn and garden are another source of household pollution. When these products are to properly kept or properly disposed they may leak into the ground. When these chemicals hit the ground destroy all the nutrients in the soil and plants that are trying to grow. After it rains the pollutants run into local streams that flow into large bodies of water that we use for drinking. The U. S. Is the #1 trash-producing country in the world at 1 ,609 pounds per person per year. This means that 5% of the world’s people generate 40% of the world’s waste. Trash from households plays a major role in our struggle against pollution. Americans generated 251 million tons of trash in 2006. Sixty-five percent name from household trash. Every year, each American throws out about 1200 pounds of organic garbage that can be recycled. The Garbage that does not get recycled get put into large landfills across our country. The problem is because we throw out so much garbage we are running out of room to store it. Another way households add to the pollution problem is through consuming extreme amounts of energy. Most people do not conserve energy so it wastes power and burns through fossil fuels. Energy conservation is also important because consumption of nonrenewable sources impacts the Environment. Households is many Ways add to the rowing pollution problem on our planet As Industries grew larger citizens are forced to contend with staggering quantities of industrial waste. The impact of pollution on the population varied according to prevailing methods of waste disposal, the shifting geography of manufacturing, and changes in the city’s economic strength. Pollutants given off by various industries and factories are often considered to be one of the prime factors contributing to air, water and soil pollution. According to the Environmental Protection Agency (EPA), it has been estimated that industrial pollution is responsible for almost 50 percent of the elution present in the United States. The main source of pollution from industries is air pollution. The emission of various greenhouse gases such as CO, methane (CHI), among others from various industries, increases the overall temperature of the earth, resulting in global warming. Dumping of various industrial waste products into water sources, and improper contamination of industrial wastes, often result in polluting the water. This is popular among chemical companies. Industrial wastes contain large amounts of various chemicals whish get accumulated on the top layer of soil resulting of a loss of fertility. This creates large amounts of soil pollution resulting from industry. Industries are a major source of pollution in our country. When industrial catastrophes happen most times it has the most negative effect on Environment. For Example last summer when the BP oilier blew up it dumped gallons of oil into the ocean. The effects of that spill will be felt for the next ten generations. BP lost a large sum of money but you cannot put a price on destroying a habitat for millions of living things. Industries have polluted our environment throughout our history and it will hurt our ecosystems on our lane for years to come. Pollution does not only damage the air it also damages the environments on earths surface. Plants and animals are harmed by air pollution. Sometimes it is the pollutants themselves that cause damage. Other times pollutants combine and change the resources that plants and animals depend upon such as water, soil, and nutrients. When an air pollutant, such as sulfuric acid combines with the water droplets that make up clouds, the water droplets become acidic. When those droplets fall to the ground as rain or snow, the acidity of the water can have damaging effects on the environment. When acid rain falls over an area, it can kill trees and harm animals, fish, and other wildlife. Acid rain destroys the leaves of plants. When acid rain infiltrates into soils, it changes the chemistry of the soil making it unfit for many living things that rely on soil as a habitat or for nutrition. Acid rain also changes the chemistry of the lakes and streams that the rainwater flows into, harming fish and other aquatic life. Thinning the ozone layer from air pollutants harms living things. Air pollution releases gases known as chlorofluorocarbons that destroy ozone molecules in the atmosphere. This leaves ozone holes that which ultraviolet radiation escapes through. Ultraviolet radiation causes skin cancer and damages plants and wildlife. Another Effect of large amounts of air pollution is Global warming. Our planet’s temperature is rising more rabidly than expected because of the additional greenhouse gases. Polar icecaps melt and permafrost melt are causing changes in the habitat and resources for plants and animals that live in these Polar Regions. This has had a major effect in the species on our planet. Disappearing habitats and resources makes it hard for an ecosystem o sustain itself. The earth was cover by 14. 8 billion acres of forest 8,000 years ago. Now only 8. 6 billion of acres remain. Species are currently going extinct at a faster rate than at any time in the past. This is not due to hunting but to chemical pollutants and over harvesting. Years of unregulated pollution have destroyed habitats and drove species to become extinct. There is no simple solution to the pollution problem on our planet. For years we have polluted our planet and have been set in our ways of doing so. The way for our planet to rebuild our ecosystem and reduce pollution is trotter regulations on hazardous waste and switching to renewable resources. Pollution taxes are charged on a per unit basis. Transferable Pollution permits allow firms to emit only the level of pollution, which they have permitted. One option for pollution control is the direct regulation by government officials. The Environmental Protection agency can set the emission standards for particular in industries and products. Also make punishments for going against these laws more severe. Another part of stronger regulation would be a market-based pollution control system. This would put a tax on every emission per unit. These solutions are making it so that pollution is not the cheaper option. The reasons why corporations choose to pollute because its a cheaper option most times then proper disposal. Pollution control clearly has its advantages but it is impossible to predict the total amount a of pollution reduction that will be created. Renewable resources are the way of the future. A major way to reduce the amount of pollution in the environment is using renewable resources that do not cause harm to the environment. Moving away from fossil fuels is important for our planet to achieve. The main types of renewable resource re Wind Energy, Solar power, and hydroelectric power. Wind power is the use of wind to power fan that connects to a turbine that creates renewable energy source. Solar power uses a grid that catches energy that is given off from the sun. Solar polar can generate the most amount of electricity out of the renewable resources. Hydroelectric power uses the current of a body of water to turn a turbine to create electricity. Using this solution will reduce the amount of fossil fuels that are being used on our planet since they are renewable we will never run out. It will be a long time before we see real hangers towards a switch to renewable resources.

Using the Italian Past Perfect Subjunctive Tense

Using the Italian Past Perfect Subjunctive Tense To complete the fourth of subjunctive-tense verb forms, theres the congiuntivo trapassato (referred to as the past perfect subjunctive in English), which is a compound tense. Form this tense with the congiuntivo imperfetto of the auxiliary verb avere or essere and the past participle of the acting verb. Forming the Compound Tense The compound tenses (i tempi composti) are verb tenses that consist of two words, such as the passato prossimo (present perfect). Both the verbs essere and avere act as helping verbs in compound tense formations. For example: io sono stato (I was) and ho avuto (I had). Auxiliary Verb Avere In general, transitive verbs (verbs that carry over an action from the subject to the direct object) are conjugated with avere as in the following example: Il pilota ha pilotato laeroplano. (The pilot flew the plane.) When the passato prossimo is constructed with avere, the past participle does not change according to gender or number: Io ho parlato con Giorgio ieri pomeriggio. (I spoke to George yesterday afternoon.)Noi abbiamo comprato molte cose. (We bought many things.) When the past participle of a verb conjugated with avere is preceded by the third person direct object pronouns lo, la, le, or li, the past participle agrees with the preceding direct object pronoun in gender and number. The past participle may agree with the direct object pronouns mi, ti, ci, and vi when these precede the verb, but the agreement is not mandatory. Ho bevuto la birra. (I drank the beer.)Lho bevuta. (I drank it.)Ho comprato il sale e il pepe. (I bought the salt and pepper.)Li ho comprati. (I bought them.)Ci hanno visto/visti. (They saw us.) In negative sentences, non is placed before the auxiliary verb: Molti non hanno pagato. (Many didnt pay.)No, non ho ordinato una pizza. (No, I didnt order a pizza.) Auxiliary Verb Essere When essere is used, the past participle always agrees in gender and number with the subject of the verb, so you have four endings to choose from: -o, -a, -i, -e. In many cases, intransitive verbs (those that cannot take a direct object), especially those expressing motion, are conjugated with the auxiliary verb essere. The verb essere is also conjugated with itself as the auxiliary verb. Here are a few examples of the trapassato congiuntivo: Speravo che avessero capito. (I was hoping they had understood.)Avevo paura che non avessero risolto quel problema. (I was afraid they hadnt resolved that problem.)Vorrebbero che io raccontassi una storia. (They would like me to tell a story.)Non volevo che tu lo facessi cosà ¬ presto. (I didnt want you to do it as soon.) Trapassato Congiuntivo of the Verbs Avere and Essere PRONOUN AVERE ESSERE che io avessi avuto fossi stato(-a) che tu avessi avuto fossi stato(-a) che lui/lei/Lei avesse avuto fosse stato(-a) che noi avessimo avuto fossimo stati(-e) che voi aveste avuto foste stati(-e) che loro/Loro avessero avuto fossero stati(-e)

Classical Art and Renaissance Term Paper Example | Topics and Well Written Essays - 1250 words

Classical Art and Renaissance - Term Paper Example The qualities of Romanesque art were presented in the construction of Basilica of Paray-le-Monial in France. Further, a perfect case of Gothic Art was employed in the construction of the Notre Dame Cathedral in French capital, Paris. Renaissance The expression Renaissance implies "rebirth." It began in Italy in the twelfth and thirteenth centuries and was upheld for more than three successive centuries. It signaled a period when urban areas became very common. The Renaissance society witnessed the resurfacing of traditional art and structural design of buildings. It led to the growth of renewed education of immense work from antique Greco Roman cultural heritage (King, 2003). The Renaissance era also spawned the best artistic and philosophical accomplishments of the West. Moreover, it illustrated the manner in which individuals perceived themselves in the general civilization compared to the classical period. Individualism assumed a remarkable role in the wake of the Renaissance era. Individuals in the Middle Ages looked upon themselves as comprising a ethnic segment of the society, relations or other all-encompassing demography. They never held the opinion that their individual accomplishments were of any importance until the Renaissance came to be. According to King (2003), throughout the twentieth century in the history of Italian society, individuals’ perceptions transformed as they appreciated their individual uniqueness. They gauged their individual characteristics, both strengths and weaknesses. The Renaissance encompassed Renaissance art, culture, and reorganization art. It is notable that a large percentage of the Renaissance art was during the sunset years of the... The expression Renaissance implies "rebirth." It began in Italy in the twelfth and thirteenth centuries and was upheld for more than three successive centuries. It signaled a period when urban areas became very common. The Renaissance society witnessed the resurfacing of traditional art and structural design of buildings. It led to the growth of renewed education of immense work from antique Greco Roman cultural heritage. The Renaissance era also spawned the best artistic and philosophical accomplishments of the West. Moreover, it illustrated the manner in which individuals perceived themselves in the general civilization compared to the classical period. Individualism assumed a remarkable role in the wake of the Renaissance era. Individuals in the Middle Ages looked upon themselves as comprising an ethnic segment of the society, relations or other all-encompassing demography. They never held the opinion that their individual accomplishments were of any importance until the Renaissan ce came to be. According to King, throughout the twentieth century in the history of Italian society, individuals’ perceptions transformed as they appreciated their individual uniqueness. They gauged their individual characteristics, both strengths, and weaknesses. The Renaissance encompassed Renaissance art, culture, and reorganization art. It is notable that a large percentage of the Renaissance art was during the sunset years of the thirteenth century, through the early seventeenth century. Oil paint was mainly used by painters of the time.

Technology trends Essay Example | Topics and Well Written Essays - 2000 words

Technology trends - Essay Example on news channels is immense and in order to retain their customer base, the need for adoption of suitable methods with the help of latest technologies is becoming the need of the hour. There has been found a noticeable change in the preferences of the customers as far as their choice of a particular medium of news delivery is concerned. To strive in today’s competitive world, it has become a challenge for the leading newspapers to make the news available to it customers as early as possible before its competitors grab the attention of the target audiences. To generate profits, some newspapers have adopted a scheme by which they make some news available for free and some content is marked as ‘premium content’ which can be accessed on payment of a considerable amount of fees. This strategy helps in building demand for the news within the audiences. Internet journalism has become the order of the day with audiences more interested in gaining information about different happenings across the world through leading newspaper websites rather than the printed newspaper(Group M., et.al., 2005). Web technologies have enabled these companies to gain feedback on the different news articles published on its websites. This helps the newspapers to understand whether any improvement has to be brought in the content or not. E-books have become a popular medium of gaining thorough in-depth knowledge about any topic which needs clarity. Topics can vary from something very theoretical to something very practical like the use of technologies in shaping the businesses of today’s organisations. E-books help audiences to surf easily through a wide range of books which might not be possible in reality. Audiences prefer e-books as they can have access to a wide range of subjects, story books, fiction books and technology related books without purchasing them physically. Many websites like e-snips and Amazon.com offers a wide range of free e-books to be accessed by its audiences

Global Marketing Research Assignment Essay Example | Topics and Well Written Essays - 3000 words - 2

Global Marketing Research Assignment - Essay Example It is the reason as to why they have continued to enjoy steady stream of growth and increase in the amount of revenue in their finances. It goes without saying that the company has enjoyed the near monopoly status on the global front (Hà ¤ikià ¶ & Virtanen, 2002).This paper will thus discuss the impact and growth of the Nokia Company as a single source from Finland to the external markets such as South Africa and Chile as prime exporting destinations of the mobile devices. The paper will also focus on the proper exporting mechanisms and techniques that Nokia as a Finnish company would penetrate and enter the Chilean and South African country (Kent, 2007). As much as the marketing team of the Nokia Company has strived to do its best in the recent past, there are other drafts of measures of in terms of global marketing that the company could explore for better growth. It stems from the fact that each and every country has a different market dimension and set up thus care and attention must be allocated to the various countries in a different way (Andersson & Wictor, 2003). In brief, this analysis will discuss the market topography and spectrum of the various countries with the feasible chances of penetration by Nokia, the company. South Africa is one of the most promising countries in the world in the form of a market because of the following outlined issues such as a viable economic environment (Myers, 2002). It is one of the emerging democracies in the African continent which has recorded good prospects of economic viability and growth in the recent as compared with other African nations such as Somalia (Myers, 2002). It is so because the country has one of the most diverse compositions of people with different tastes in electronic gadgets and devices (Clarke, 1996). South Africa in its structure and population has one of the most diverse societal spectrums in

Analysis of Doctrine of Equity

Analysis of Doctrine of Equity The doctrine of equity was created to fill in the gaps of common law by providing more flexible remedies, unlike common law which only provide damages such as injunction, specific performance, equitable estoppel etc. Equity only governed by the maxims where it is based on the principles of fairness and conscience and are not as strict as common law. Hence, as the doctrine of equity developed and became more and more flexible in the past centuries, it has now been argued by many academics that equity is now too conceptually messy to be useful.ÂÂ   It has been argued that equity is a blend of strict rules and discretionary principles which attributes to English Law with its flexibility. He further explained that equity comprised of firm rules as well as discretionary principles which will be applicable in different circumstances.[1] In deciding this, the flexibility of equity would be discussed, especially in the areas of such as the three certainties, Quistclose trust and doctrine of fiduciaries. In the case of Knight v Knight[2], Lord Langdale MR had laid down the three certainties test to create a valid private express trust. Certainty is an important element in trust as without certainty, the intention, object and subject of the trust could not be determined by the courts which would then lead to an invalid trust. Under certainty of intention, the settlor must use very clear words and expression to impose a legal obligation for the trustee to hold the property on trust. Generally, imperative words are more encouraged to be used in a will as compared to precatory words. In the case of Re Adams[3], the phrase in full confidence was used in the clause and it was held that there was no trust created as there is no imperative words used in the will. However, in Comiskey v Bowring[4], even the same phrase was used as in Re Adams case, but it was held that the wording created a trust. It could be submitted that the courts now no longer only look at a single word to determine whether there is a trust but look at the whole of the will. In more complex situations where there are no documents available, the courts might infer intention from acts or the words of the parties. In Paul v Constance[5], it was held that the words the money is as much yours as it is mine is sufficient to make a valid trust as there was repeated conduct and has a clear intention. It was suggested that the courts are being too generous in the decisions. However, in Jones v Lock[6], it was held that it was insufficient to manifest a clear intention for the father to create a trust for the son. The problem is that both cases were lack of specific intention to create a trust, there were only general intention to benefit. However, both cases were held differently. It could be argued that the actions were louder than the words in Pauls case. Gardner suggested that the difference of both cases was merely the reflection of changing judicial attitudes.[7] Next, under the certainty of subject matter, the test used by the courts would be whether the property could be certainly identified. However, the courts have recently created an artificial distinction between tangible and intangible property. In Re London Wine Co[8], it was held that no two bottles of wine are alike and therefore it could be identified for their customers. However, in Re Goldcorp Exchange Ltd[9], it was held that the claimants whose gold bullion had been segregated were successful in the claim but not those whose bullion had not been segregated. The reasoning was that the stock of the gold has been constantly changing and it was hard to say which particular piece of gold belongs to any particular customer. It could be submitted that the courts were trying to uphold the principle of fairness by having a different decision from Re Londonscase as the tangible property items here could not be segregated properly. On the other hand, in Hunter v Moss[10] where the property is intangible, a different approach was taken by the courts. In the case, it was held in favour of the claimant and stated that the segregation as in tangible property is not necessary where a trust is made over an intangible property. The reasoning for this is that since the shares is indistinguishable from one another, they will be treated as equal. Based on all three cases above, it could be seen that this area is messy as this certainty has not been applied consistently and the judges have too much discretion changing the judicial attitudes. Lastly, the certainty of object matter required that there must be ascertainable beneficiaries in a trust. Re Baden (No.2)[11] had shown that there are different approaches to deal with when there is a class of objects in a discretionary trust. The test used in the case was originated from McPhail v Doulton[12] where the application of a complete list test was impossible and borrowed the is or is not test from Re Gulbenkians Settlements[13] to determine the beneficiaries. However, there are 3 interpretations on the applicability of the test. Firstly, Sachs LJ upheld the literal application of the original test, but reversed the burden of proof on the claimant to proof that he falls within the class of beneficiaries. Sachs LJ further noted that this does not apply to all discretionary trust situations as a lot of trust with uncertainty would be validated. Secondly, Megaw LJ suggested the approach used in Re Allen[14]which was overruled by Re Gulbenkians case where it held that a trust should be valid if a substantial number of people can show that they are in the class. Finally, Stamp LJ suggested a strict approach where he stated that it is necessary for both conceptual and evidential certainty to exist without any unknown of the certainties. Any unknown of the certainties would lead to an invalid trust. It could be submitted that this area would be too messy for the future cases to refer as there are too many different views. The flexibility of equity could also be found in Quistclose trust which created by Lord Wilberforce in Barclays Bank Ltd v Quistclose Investments Ltd[15]. The Quistclose trust arises when a company borrows money with a particular purpose in mind for that money. Lord Wilberforce suggested there are primary trust to pay dividend and secondary trust arose in favour of the lender if primary trust failed. However, this was heavily criticised as it failed to meet the three certainties to be a valid trust. Later, Lord Millet in Twinsectra v Yardley suggested that there is only one resulting trust instead of two trusts while majority of the court held that it was an express trust. In Re EVTR[16], Dillon LJ suggested that it was a constructive trust for the purpose of the loan.Moreover, academics like Alastair Hudson had suggested that the better analysis for this should be an express trust.[17] Furthermore, in Re Farepak Food[18], Mann J held that there was no trust and described this is as a contractual relationship as opposed to trustee-beneficiary.[19] Furthermore, equity also shown its flexibility in fiduciary area. A fiduciary is a person who holds a position of trust and confidence. Fiduciary has the duty to act in the best interest of the principal in a fiduciary relationship. A fiduciary is bound by the no conflict rule where he must make sure that his duties to the principal do not conflict with his own interest and not allowed to make a profit. The leading case would be Boardman v Phibbs[20] which involves trust where it applied the strict rule which originally from cases such as Keech v Sandford[21] and Bray v Ford[22].The decision was a made in majority of the judges while the other two judges gave dissenting judgments. Lord Upjohn in dissenting suggested that the case should be approached in a more equitable angle and should be decided on its own individual facts instead of laying down a strict rule to be followed like the common law courts. However, in Murad v Al-Saraj[23], the majority of courts again decided by following the rules. Arden LJ from the majority suggested that the court should revisit the inflexibility of rule of equity in harsh circumstances. Furthermore, Jonathan Parker LJ from majority also suggested that it is the time for the court to relax the severity of the rule. In minority, Clarke LJ suggested that the fiduciary could argue for a share in profits even though they breached their duty by reasoning with Warman International v Dwyer[24]. In Foster Bryant Surveying v Bryant[25], it was held that the defendant was not required to account his subsequent profit as the facts were different from the traditional cases. It was suggested that this case law would only be followed when there are same facts in the future. Based on the above, equity has been flexible to evolve to suit the needs of the society. Hence, it is tremendously complex as it was built centuries of laws, but the courts are free to generate new principles and to adapt or apply the old ones depending on the situation. As suggested by Alastair Hudson, equity forces us to consider the plight of the individual in this complex world and to save that individual from being caught up in the legal machine or exposed to irremediable suffering.[26] In conclusion, it could be submitted that equity is still useful even though it might be conceptually messy as shown above. However, this would be inevitable as equity has to be flexible but it would be also required to maintain some consistencies across the cases to prevent the law from being vague. (1650 words) Bibliography Books Gardner S, An introduction to the Law of Trusts (3rd edn OUP 2011) Hudson A, Equity and Trust, (8th edn, Routledge, Oxon, 2015) Hudson A, Great Debates in Equity and Trusts,(1st edn, Palgrave Macmillan 2014) Electronic Sources Alastair Hudson, The Fundamentals of Quistclose Trusts, http://www.alastairhudson.com/trustslaw/Quistclose.pdf accessed on 13rd February 2017 Table of Cases Barclays Bank Ltd v Quistclose Investments Ltd [1970] AC 567 Boardman v Phibbs [1967] 2 AC 46 Bray v Ford [1896] A.C. 44 Comiskey v Bowring-Hanbury [1905] A.C. 84 Foster Bryant Surveying Ltd v Bryant [2007] EWCA Civ 200 Hunter v Moss [1993] 1 WLR 934 Jones v Lock [1865] 1 Ch App 25 Keech v Sandford [1726] Sel. Cas.Ch.61 Knight v Knight [1840] 3 Beav 148 McPhail v Doulton [1971] AC 424 Murad v Al-Saraj [2005] EWCA Civ 959 Paul v Constance [1977] 1 All ER 195 Re Adams Kensington Vestry [1884] LR 27 ChD 394 Re Allen [1953] 1 All ER 308 Re Badens Trusts (No.2) [1973] Ch 9 Re EVTR [1987] BCLC 646 Re Farepak Food and Gifts Ltd (In Administration) [2008] BCC 22 Re Farepak Food and Gifts Ltd (In Administration) [2008] BCC 22, 34 Re Goldcorp Exchange Ltd (In Receivership) [1994] 3 WLR 199 Re Gulbenkians Settlements Trusts [1968] UKHL 5 Re London Wine Co (Shippers) Ltd [1986] PCC 121 Warman International v Dwyer [1994-5] 182 CLR 544 [1] Alastair Hudson, Great Debates in Equity and Trusts,(1st edn, Palgrave Macmillan 2014) [2] Knight v Knight [1840] 3 Beav 148 [3] Re Adams Kensington Vestry [1884] LR 27 ChD 394 [4] Comiskey v Bowring-Hanbury [1905] A.C. 84 [5] Paul v Constance [1977] 1 All ER 195 [6] Jones v Lock [1865] 1 Ch App 25 [7] Simon Gardner, An introduction to the Law of Trusts (3rd edn OUP 2011) 52-3 [8] Re London Wine Co (Shippers) Ltd [1986] PCC 121 [9] Re Goldcorp Exchange Ltd (In Receivership) [1994] 3 WLR 199 [10] Hunter v Moss [1993] 1 WLR 934 [11] Re Badens Trusts (No.2) [1973] Ch 9 [12] McPhail v Doulton [1971] AC 424 [13] Re Gulbenkians Settlements Trusts [1968] UKHL 5 [14] Re Allen [1953] 1 All ER 308 [15] Barclays Bank Ltd v Quistclose Investments Ltd [1970] AC 567 [16] Re EVTR [1987] BCLC 646 [17] http://www.alastairhudson.com/trustslaw/Quistclose.pdf, The Fundamentals of Quistclose Trusts, accessed on 13rd February 2017 [18] Re Farepak Food and Gifts Ltd (In Administration) [2008] BCC 22 [19] Re Farepak Food and Gifts Ltd (In Administration) [2008] BCC 22, 34 [20] Boardman v Phibbs [1967] 2 AC 46 [21] Keech v Sandford [1726] Sel. Cas.Ch.61 [22] Bray v Ford [1896] A.C. 44 [23] Murad v Al-Saraj [2005] EWCA Civ 959 [24] Warman International v Dwyer [1994-5] 182 CLR 544 [25] Foster Bryant Surveying Ltd v Bryant [2007] EWCA Civ 200 [26] Alastair Hudson, Equity and Trust, (8th edn, Routledge, Oxon, 2015)

Book Report on George Orwells Burmese Days Essay -- George Orwell Bur

Book Report on George Orwell's Burmese Days The book â€Å"Burmese Days† was written by George Orwell and published first in 1934. Orwell took the inspiration for this first novel of his from the experiences he gained during his service as an imperial police officer in Burma in the late 1920s. There he was confronted with extreme forms of imperialism, causing racism and also chauvinism. These are also the main topics of the novel and although they are wrapped up in the story of a single man’s fate, John Flory’s, these topics caused some problems with the publishing of the book. For that reason the book was first published in America, the English version wasn’t published until some changes – mainly name changes – were made which was nearly a year later. â€Å"Burmese Days† is set in 1920s Burma under British colonialism. It focuses on the imperialism of the British and its effects on the relationships between the British, the British and Indians, and between the Indians themselves. So negative is the portrayal by Orwell of imperialism that it can be seen as a novel without hope in terms of altering the imperialistic structure of the British rule in Burma. No character- British or Burmese- appears to be capable of escaping the destructive trap of imperialism. Orwell points out clearly his negative attitude on European politics at his times, for in his youth he was very much in favour of the Marxist ideology and so is the protagonist of the novel â€Å"Burmese Days†, John Flory. The novel concentrates on the town of Kyauktada in Upper Burma. Kyauktada is described as hot and sultry. It is a small town of about four thousand people. The overwhelming majority of the inhabitants are Burmese, but there are also a hundred Ind ians, two Eurasians, sixty Chinese, and Seven Europeans. Nevertheless, as in all imperialistic societies the small group of Europeans suppresses the great majority of the native people, who seem to accept perfectly the superiority of the white people. Orwell criticizes this feeling of inferiority the Europeans give the Burmans and especially the Eurasians, because for their existence the Europeans are even responsible. Although he seems very much in favour of the so-called inferior people, the novel gives a certain impression of the Asian character to the reader, which is not very likeable. The Asian people are described – and not only by the characters o... ... to talk to her reasonably. When he asks her if she would ever marry him after what has happened, not now but after a while when the whole thing was forgotten, she answers that she never would. Having heard this, Flory goes hom and shoots his dog Flo and himself. Ko S’La calls for the doctor who comes immediately and manages to pretend that it wasn’t suicide but an accident. Not that anybody in the town would believe in this but still it is at least the official version. After Flory has shot himself, everything changes again. Elizabeth, who appears to be the only one to be surprised by Flory’s suicide, marries Mr. McGregor after a while, who certainly for her is a better husband than Flory would have been, Dr. Veraswami, without a European protector, is easy to ruin for U Po Kyin now and has to leave Kyauktada, U Po Kyin becomes, as he had wished a member of the Club but dies too early to manage to build some pagodas or do anything to wash away the sins he had committed during his life, which makes his wife worry whether he will be reborn as an ugly animal. Ko S’La and Flory’s other servants try their luck on shop-keeping but fail and have to work as servants for another sahib.