The Silk Roads free essay sample

The Silk Road was an important trade network that established cross-cultural trade; people from Han China all the way to the Roman Empire were involved. The Roads came around at about 200 B. C. E, and persisted for another 1,700 years. Luxury goods, religions, diseases, food, and ideas have emerged within that time. The Silk Road and its trade remain constant even though its patterns of interaction have been altered through the plague and Islam, Christianity, and Buddhism. Over time, the Silk Roads’ routes spread all throughout Eurasia. Empires that were large and wealthy often traded goods, for this was very good for their economy. Unmistakably, trade comes with the dispersion of disease. Rats that lived on boats started the Bubonic Plague; ships carrying the disease would spread it at various stops, infecting more people. The Mongols contributed to the spread of the Black Death. Changes occurred when millions of people were killed during the Middle Ages. We will write a custom essay sample on The Silk Roads or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Furthermore, when the Roman Empire fell in the mid-5th century, trade was reduced along the Silk Roads. The plague was one of many factors that changed over interaction along the Silk Roads. Religion was a monumental change that resulted through communication of merchants and travelers. Buddhism, Islam, and Christianity arose and made its way across the Roads. After time, these religions became the most prominent in Eurasia. Among many changes lie a few continuities. The purpose of the Silk Road itself along with the goods traded remained the same for 1,650 years. Goods such as silk, spices, and currency were exchanged and developed. Ideas, technology, and innovation were also shared in the process. The purpose of the Roads was to make trade easier while satisfying the economy. Overall, change ended up being a positive result for nations that traded along the Silk Roads. From 200 B. C. E to 1450 C. E, people throughout Eurasia were providing and obtaining materials that sped up the development of human interaction. Despite changes in infections and religion, the original function and products of the Roads endured.

Examining The Accuracy Of Plymouth Plantation Religion Essay Example

Examining The Accuracy Of Plymouth Plantation Religion Essay Example Examining The Accuracy Of Plymouth Plantation Religion Essay Examining The Accuracy Of Plymouth Plantation Religion Essay Bradford s Plymouth Plantation, contains records of the Pilgrim s colony in the New World. This papers represents the history of one of the first settlements in New England that founded our states faith, civilization, and history. Some historiographers wonder if Bradford s certification of the Plymouth colony is accurate. Even though Bradford s personal positions and prejudices are apparent throughout the transition there is still a batch of factual grounds that would be lost with out this manuscript. Bradford has been an inspirational author to many, such as Cotton Mather, William Hubbard, Thomas Prince, and Thomas Hutchinson. Of Plymouth Plantation, is separated into two books dating from 1620 to 1650. Bradford, seemingly wrote the first book in 1630 ( Shuffleton ) , and goes into item of the Separatist motion. The chief points of the book include: the Separatists afraid of spiritual persecution, flying from England to Holland, settling in Leiden, their ocean trip on the Mayflower, and their experiences in New England. Bradford orders his stuff non merely chronologically but teleologically, into chapters that are organized locally every bit good as in footings of sequences of events, and he indicates in legion ways that his history is plotted and traveling toward a peculiar result ( Read ) . The manner in which Bradford wrote this book is why it has been so influential. It is easy to follow and a timeline is apparent throughout. He goes into item on cases that he finds of import. For illustration, in what he called the First Encounter, an Indian onslaught occurred and he went into punctilious item o f how the Indians looked, sounded, and how they interacted with the pilgrims. But about midnight they heard horrid and great cryaˆÂ ¦they concluded it was a company of wolves or such like wild animals ( Perkins 56 ) . This text gives insight to how the Indians responded to the Pilgrims invasion. The 2nd book was written between 1646 and 1650, and is a signifier of annals dating from 1630 to 1650, which tells of the Pilgrim s twenty-four hours to twenty-four hours life. His usage of annals proved accurate when compared to colony records that would hold been available to him at that clip. Bradford writes most of history out of nostalgia ( Wenska ) . This means that he has a longing for the past and uses bible poetries to compare to what s go oning in the settlement. This is seen when Bradford compares the Plymouth colonists to the Israelites of the old testament, when their clip of roving is over, religious rules are settled, and now the Pilgrims must confront the religious uncertainnesss of history as they strive to construct their ain Canaan ( Shuffleton ) . In the bible, the Israelites were God s chosen people, and God granted them the power to rule Canaan. Everything was made abundant to them, until they started to transgress. Once they started to withstand God s word, God took away the heritage he had given them. Bradford says this in hopes that his Separatists can get the better of their iniquitous nature and remain faithful to God, and in return keep New England, the land God has granted them. His ain personal beliefs and positions were decidedly apparent throughout the text. He regarded himself as an instrument of God ( Perkins 49 ) . He believed that God helped people overcome obstructions through religion, aˆÂ ¦but they cried unto the Lord and he heard their voice and looked on their hardship ( Shuffleton ) . On the Mayflower there was a immature adult male who thought extremely of himself and cursed the sick. But it pleased God before they came half seas over, to smite this immature adult male with a dangerous disease, of which he died in a despairing mode, and so was himself the first that was thrown overboard. Thus his expletives visible radiation on his ain caput, and it was an amazement to all his chaps for they noted it to be the merely manus of God upon him ( Perkins 51 ) . This text shows Bradford s belief that God has a manus in everything was shared by the Separatists. In his description of Plymouth, there were two instead aggressively divided grou ps -the saints, or members of the Separatist church, and the strangers, or Non-separatistsaˆÂ ¦ Obviously Bradford held the saints in much higher regard so he did the strangers, who were frequently riotous of the peace of the settlement ( Westbrook ) . His favouritism can besides be seen when he omits most of the facts refering incidents when the Separatists are being unpatriotic to God. For illustration when they fight amongst themselves in Amsterdam, or butcher the Indians at Wessagusset. But, in Plymouth in 1642, when there were eruptions of burglary, criminal conversation, and fornification ( Westbrook ) , he did nt prehend to go forth out any inside informations of their evil. After Bradford discusses the eruption of crying wickedness he ends his narrative with the headers, Anno 1647, and Anno 1648, go forthing them space. Peter Gays says, Bradford ends his history in silence ( Shuffleton ) . One can besides state he s partial to the Separatists by his word p ictures of characters. He differentiates between admiral characters who, are members of the Separatist fold and the ugly 1s, who are either unchurched or have Anglican understandings ( Westbrook ) . When he speaks of William Brewster whom he admires and considers a male parent figure, he speaks merely of his strengths. When speech production of person he dislikes he explains their failings, and why they are non trusty. His inclination seems to be toward imitation and ridicule in picturing individuals whom he disliked, such as Lyford, Weston, Thomas Morton, and Oldham ( Westbrook ) . Many historiographers have used Plymouth Plantation as a resource in composing their books, due to the truth and elaborate history of the early colony. This full transition has been treated as an early reading of the American landscape and an illustration of English prepossessions about that landscape as wilderness ( Read ) . Nathaniel Morton, Bradford s nephew, had copied big parts from Plymouth Plantation and was considered really of import when his uncle s original plants had been lost. Increase Mather used it as a beginning for his history of Indian Wars. Increase s boy, Cotton, subsequently used it for his ain history of the Plymouth Colony. William Hubbard used it in his authorship of the General History of New England from the Discovery to MDCLXXX. Thomas Prince quoted and paraphrased many transitions in his Chronological History of New England in the signifier Annals in 1736. It has been influential because of how Bradford handled clip relationships, characterized p ersons and groups, and focused on events that he thought were of import. Bradford helped to show the workings of Godhead Providence for the sophistication of future coevalss ( Gould ) . This papers has saved past history that would hold otherwise been lost. The old ages since these early literary historiographers wrote has neither dulled nor lessened our esteem for Bradford as either historian or adult male of letters ( Wenska ) . It will go on to lend to the American civilization for coevalss to come. Bradford s Of Plymouth Plantation can non be classified as nonsubjective history, because he incorporated excessively much of his ain personal beliefs and values. Alternatively it can be used as a history book for the foundation of New England. Early writers saw its importance and incorporated it into their ain Hagiographas. It has helped determine our differing faiths, civilization, and literature that can be found in today s epoch.

FIN unit 5 IP Essay Example | Topics and Well Written Essays - 1000 words

FIN unit 5 IP - Essay Example By establishing production facilities in other countries especially where the cost of production is low, the firm starts to import its products back to home. Vernon’s product life-cycle theory was initially developed in US due to the fact that the most of new products were initiated in the US market. As more regions became developed, the theory was emulated by other countries such as China and Japan among other countries. One of the notable strengths of the Vernon’s product life-cycle theory is that it clearly explains the historical development of foreign domestic investment (Moffett et al, 2009). Nevertheless, based on the complexity in the production process globally, Vernon’s product life-cycle theory cannot neatly hold. For instance, as many countries initiate production systems, new products are being introduced at the same time in addition to establishment of production facilities in many countries simultaneously. Based on stiff competition that is been ex perienced in the current business atmosphere, many countries are focused at supporting their local companies by offering incentives such as tax subsidies and training of their work force. One of the major reasons as to why host countries, resist cross-border acquisitions is that they view them as foreign companies who are aimed at taking over their local firms without creating employment opportunities. On the other hand, host countries, view green field investments as economic drivers that are focused at establishing new production facilities that acts as major sources of employment for the local residents (Wang, 2005). Additionally, some host companies are viewed as competitors whose aim is to create products that are similar to those of the host companies. As a result, the local firms are faced with fewer sales leading to reduced amount of tax paid to the government thus resulting to slow development of the host countries. As local companies adopt foreign domestic investment, they are faced with various risks that range from currency risk to political risks. Based on the need to produce a budget that entails all the assets and liabilities that firms have at a certain date, it is imperative to incorporate the risks so as to provide fair position of the companies’ financial position. Political risks entail the complications that local and foreign businesses may face due to a political change. Beside macroeconomic factors, political risks can be caused by social policies as well as changes in investment, labour and changes in development among others. Political risks can be divided into macro political risks and macro political risks. While micro political risks are specifically related to a project, macro political risks affect all sectors of a country. During capital budgeting, firms should incorporate political risks in various ways. First, an organization can adjust the cost of capital upwards in order to indicate the impact of political risk. This i s followed by discounting the expected cash flows at an increased rate. Secondly, a firm can deduct insurance premiums associated with political risks from the future cash flows. This is followed by using the normal cost of capital which is adopted by the domestic capital budgeting. The need for expansion in foreign countries has forced many firms to emulate various strategies in order to expand their tangible and intangible assets. Two notable

HR Issues in the Organisations Essay Example | Topics and Well Written Essays - 1000 words

HR Issues in the Organisations - Essay Example Such a degree of centralisation is leading to employees’ frustration and disengagement (Vosburgh, 2007). There is a totally flawed reward system (Secord, 2003) working in the organisation, which again is designed by the ministry of defence. This design is not pragmatic (Pilbeam, S. & Corbridge, 2010) when it comes to dealing with civilian workers. Apparently, most of the work in these organisations is done in teams, but the reward system in place is not suited to this form of working. Moreover, this type of a reward system is anti teamwork and leads to a rift created between employees (Ulrich & Smallwood, 2005). With employees not receiving their deserved recognition and line mangers being helpless in this regard, organisational motivation is falling exponentially (Yeung & Brockbank, 1994). This entire problem is being caused by the â€Å"Cluster Panel†, which is totally callous to the working environment and is responsible for making appraisal decisions. The group has a defective method in place to assess an employee. The entire appraisal system (Yeung, Woolcock, & Sullivan, 1996) is dependent upon the line manager’s recommendation of an employee and that too is further conditional on his writing effectiveness. Even if a manager effectively encodes an employee’s accomplishment on the appraisal form, there is still no guarantee that this would secure an appraisal for the employee. This deficiency has two folded repercussions, one has to do with the line manager’s motivation level and the other has to do with an employee’s alienation with the organisational procedures (Newman & Hodgetts, 1998). One aspect that needs special attention over here is that of the military staff. Since they form a part of the total workforce of these organisations, they deserve to be treated like any other employee. On the contrary they are considered as alien to the organisational setting when they receive their compensation from the defence ministry. This sort of handling of the military personals is leading to a confusion arising in their midst with regards to their role, both in the military and in these organisations. Another important draw back in these organisations has to do with the absence of a motivator. Since employees consider performance bonuses as some sort of a lottery rather than a form of recognition, and manager’s acclamations as shallow, there exists a serious deficiency of a driving force (Miner & Crane, 1995). In these organisations mangers are the ones who are occupying the most pitiful position. They have no power what so every to express their viewpoint. They are mere spectators who are just watching the show, having no power what so ever to exert influence on any level of the bureaucracy (Losey, Mesinger, & Ulrich, 2005). Recommendations for Changes: In these circumstances in which the employees are feeling totally dejected with the organisational procedures, and mangers rather than being inspirational are showing a sorry picture it is important to come up with more effective Human Resource policies (Kramar, Mcgrew, & Schuler, 1997). It is inevitable that organisational productivity will fall and the purpose for which these organisations are in place will suffer a deep blow. In order to prevent such damaging consequences, change management needs to be implemented on an emergency basis. In this change management program,

Balancing Test in UK Law

Balancing Test in UK Law The Ultimate Balancing Test This chapter will consider how the UK courts must find a balance between the competing Convention rights of Article 8 and Article 10. In the context of their relationship between the privacy of such individuals and the press, as these two essential and fundamental rights frequently come into conflict and must be analysed and balanced against each other. Whilst referring to the ultimate balance as recognised in Strasbourg courts and how it has aided in developing the ultimate balance in UK courts. As such, both rights start off as equal, this can be reflected, for example, in Resolution 1165 of the Parliamentary Assembly of the Council of Europe 1998, where paragraph 11 specifically mentions that, The Assembly reaffirms the importance of every persons right to privacy, and the right to freedom of expression, as fundamental to a democratic society. These rights are neither absolute nor in any hierarchical order, since they are of equal value in a democratic society.[1] The conflicting rights As can be seen by the evidence presented in the previous chapters, the balance between the right to privacy and freedom of expression is one which has influenced much debate, in Strasbourg and in the UK, and as such, they are often found competing against one another, even though they are of equal value. Incorporated within the debate is the view that both rights are completely contradicting, as privacy is strongly founded upon secrecy whilst expression most always involves exposure, thus this is when friction will almost always be formed between the two Convention rights. Consequently, the friction created by these rights are central to the conflict the courts have been facing, following the incorporation of the HRA and ECHR, much of this friction was formed with the conflicting rights of Article 8 and 10 at the very core. These rights at first glance appear to stand independent, although the expectation of these rights can however become apparent, thus creating the issue of why the right to privacy and freedom of expression are often in conflict. Furthermore, these two rights have arguably been fought most by two parties, the first party, uses Article 8 which gives a person right to respect for his private and family life, his home and his correspondence.[2] Phillipson identifies that any individual has a right as a human being to have control over what information a person chooses to disclose to another, and that when the government or the media acquire information without your consent, and publish the information, it violates a persons fundamental right to control such information about themselves.[3] Therefore, it makes sense that the second party whom fights for their rights conveyed in Article 10 are most commonly the media, this right states that Everyone has the right to freedom of expression.[ 4] This right includes the freedom to receive and communicate information, thus it would make sense that the second party that fights for their rights are the media as the media focus highly on communicating information to the public, as such, they are quite commonly known as being the public watch dog. [5] Hence, it could be said that the media are therefore obligated to publish what they believe the public want to know, and it is there that the conflict between the right to privacy and freedom of expression arise; when the media publish information that a person or persons wanted to keep private. [6] Harris has expressed the opinion that the balance between the two rights is a grey area in law, and that there will always be tension between the two, however, it needs to remain that way to differentiate between definitively private information and information that some may see as private, but instead may be important to be covered by freedom of expression.[7] It has been stated by Lord Goff that freedom of expression has existed in this country perhaps as long, if not longer, than it has existed in any other country in the world as such, this statement was maintained by Lord Hoffman when he mentioned that A right of privacy may be a legitimate exception to freedom of speech (but) there is no question of balancing freedom of speech against other interests. It is a trump card which always wins.[8] These statements highlight that there once was a strong preference in the courts in favour of freedom of expression. While there is no contrary public interest recognised and protected by the law, the press are free to publish anything they like. Although, when freedom of expression comes into conflict with another interest protected by law, the question of whether there is a sufficient public interest in the publication to justify limitation of the conflicting right comes into play. However, there is, and will always be a strong desire to know the truth, with many agreeing that freedom of expression is fundamental towards a healthy democracy. Although, this freedom can be essential, it can however, come with responsibilities that the media will often disregard. Thus, the right to freedom of expression stops when it infringes on the privacy of those involved unless, by keeping such things private, would cause a concern for society, as such public interest. Yet, the issues of which stories are of public interest is a rather grey area in the UK, partly because the divergence between what the public has a right to know and what the public desires to know. In theory, it can be said that everyone is entitled to both right; right to privacy and right to freedom of expression, as far as they do not infringe on anyone elses rights. Though, this is quite frankly impossible, and as such can only be done by balancing the two rights. The balancing of the two competing rights English courts have been influenced by the balance recognised in the Strasbourg courts, and have attempted to reconcile the fundamental underlying values advanced by the right to privacy and freedom of expression through such legal frameworks, as such the balancing of these two competing rights are clearly demonstrated in countless cases. In executing the ultimate balancing test, the courts consider the claimants right to privacy as expressed in Article 8 of the ECHR, which provides that everyone has the right to respect for his private and family life, his home and his correspondence.[9] Equally, the content of the publishers freedom of expressions rights is established from Article 10 of the ECHR, which safeguards the freedom to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers.[10] With both rights being qualified, they may be restricted under paragraph two, provided that the interference is prescribe d by the law, and pursues a legitimate aim and what should be well known by now, is that it is necessary in a democratic society and is proportionate response to the aim pursued. The balance as recognised in Strasbourg Privacy actions involve the conflict of two rights, most commonly, freedom of expression. The Article 10 jurisprudence discloses that, even though freedom of expression constitutes once of the essential foundations of a democratic society, a hierarchy of various types of expression have been developed by the ECtHR, which can be recognised in the previous chapter. These can be political speech, artistic expression and commercial expression,[11] as such this is where the conflict begins. The conflict could begin with Article 8, in regards that the State has failed to appropriately protect the applicants right to privacy or it could begin with Article 10, in regards to whether the State has infringed the applicants right to freedom of expression by imposing sanctions aimed at protecting a persons right to privacy.[12] Thus, courts must consider the conflicting rights on the presumption that both Articles are of equal value, rather than considering that the conflicting right is an excep tion to the principal right, as such the Convention ensures that any restriction that is places on either right is closely scrutinised and a balance is achieved between them. The cases before Von Hannover did not endorse the methods of balancing Article 8 and 10, however, following on from this caseit can be recognised that neither Article takes precedence over one another. In the first Von Hannover case, as stated in the previous chapter the court had held that Princess Carolines Article 8 rights had been infringed by the publication of photographs showing her with her children and with her husband. She brought several actions in Germany for an injunction to prevent further publications of the various photographs that were taken, the court however stated that the matter was an event in contemporary society and of general interest to the public. Princess Caroline argued that none of the photographs, regardless of the articles that followed with them debated to such public interest in a democratic society, but were there only to satisfy the curiosity of such a reader. As such, this is important as an individual will be more easily able to establish a reasonable expectation of privacy than say an individual in the public eye. Although, in Von Hannover (No.2)[13]this case involved the publication of a photograph of Princess Caroline and her husband during a skiing holiday, to illustrate the ill health of her father, Monacos Head of State. The Court maintained the position that whilst a private individual unknown to the public may claim particular protection of his or her right to private life, the same is not true of public figures[14] Although, they did modify it definition of public figures to also include persons whom could just be simply well known to the public. Consequently, in line with the courts findings, the press could legitimately report on how the Princes children prepared to accept family duties during the time of the Princes illness, such as going on skiing holiday. In the view of the court, the photos in question, considered in the light of the accompanying articles, did contribute, at least to some degree, to a debate of general interest.[15] Additionally, the photographs themselves were n ot offensive to the extent that their prohibition was justified.[16] The court in this case, emphasised that both Articles are of equal value and the margin of appreciation should be the same in both cases, and as such, they saw fit to develop criteria which other states should follow when considering how to develop a balance between the two rights, these being: Whether the information contributes to a debate of general interest How well known the person concerned is and the subject matter of the report The prior conduct of the individual concerned Content, form and consequences of the publication; and The circumstances in which the photos were taken When applying, the criteria set out above, in the second case, the Court had found that Germany has changed its approach to privacy considering the first Von Hannover judgement, in regards to mentioning that a public interest in being entertained generally was less important than an individuals right to privacy. As such, the courts attempted to narrow the focus when attempting to balance the two equal but competing rights of privacy and freedom of expression. The balancing test as recognised by UK courts Decisions are necessarily fact or case sensitive, given that the Court is required to balance the fundamental rights (right to privacy and freedom of expression) which are often in conflict, the general approach which should be adopted and the principles which apply to these competing rights are now well-established. This main reason for this is that the law is Strasbourg-led. Although the rights do have conflicting aims, their aim was not to confuse the courts in making their rulings but to create a difference between everyones right to privacy whilst allowing them certain freedoms. The approach towards balancing these competing rights will be clearly demonstrated in countless cases. Firstly, it should be mentioned that, Section 12(4) of the HRA enjoins domestic courts to have particular regard to the importance of the Convention right to freedom of expression when they are considering whether to grant relief. Which may indicate that Article 10 is given priority when balancing it against others rights, such as privacy, however, the courts understand that such an interpretation would result in a conflict between Article 8 and 10, thus lacking with the consistency with the Convention rights. Consequently, the case of Douglas v Hello! Ltd,[17] Lord Justice Sedley, recognised that in order to achieve such compatibility with the Convention, when balance the two rights, courts would have to treat the two rights as having equal value, The European Court of Human Rights has always recognised the high importance of free media of communication in a democracy, but its jurisprudence does not and could not consistently with the Convention itself give Article 10(1) the presumptive priority which is given. [à ¢Ã¢â€š ¬Ã‚ ¦] Everything will ultimately depend on the proper balance between privacy and publicity in the situation facing the court.[18] The Campbell case refined this balancing test, as the House of Lords were face with conflict between privacy and freedom of expression when a tabloid took and published photographs of a supermodel as she exited a Narcotics Anonymous meeting the house was divided in the result with a narrow 3 -2 majority deciding that her privacy rights ought to prevail over freedom of expression in the circumstances of this case. The House of Lords considered what type of information was regarded as confidential and stated that there must be some interest of a private nature that a claimant wished to protect and that the test is whether a person place in similar circumstances would find the disclosure offensive. [19] Fenwick and Phillipson have termed this approach to proportionality, the parallel analysis as it requires the court to consider whether the justifications in favour of protecting speech support the limit on privacy and then to consider, whether the justification in favour of privacy sup port the limit proposed on freedom of expression.[20] Without this parallel analysis, there is a danger that one right would prevail. However, the courts have been conducting various tests to determine the privacy of such certain information, long before Campbell founded the balancing exercise which the UK courts now use. Formerly, a limited right of privacy was established in the case of Coco v AN Clark Engineers Ltd[21] which came under the already established right of breach of confidence. The above approach in Campbell has subsequently been endorsed, and as such, it has been established in the UK that not one Article is supposed to take superiority over the other, as Lord Steyn summarised in the case of Re S (A Child),[22] First, neither article has precedence as such over the other. Secondly the values under the two articles are in conflict, an intense focus on the comparative importance of the specific rights being claimed in the individual case is necessary. Thirdly, the justification for interfering with each right must be taken into account. Finally, the proportionality test must be applied to each. For convenience I will call this the ultimate balancing test.[23] The approach towards balancing these competing rights can be clearly demonstrated in countless cases in the UK courts and through Strasbourg, which become more apparent when the extent of which public interest exists for the disclosure of private information. The case law produced after the introduction of the HRA is ever expanding, with recent concerns coming to light over the issue that the courts have developed a law of privacy and made the necessary balance between the two rights in each case, rather than the Parliament. [24] Thus, these following cases explore the progressively divergent approaches the courts have taken in interpreting and applying the legal tests that have been established. How the courts use the balancing test The decisions made in the cases of Campbell, Douglas and Von Hannover are considered landmark with the considerations that have occurred in the area of privacy over the years. As these cases strengthened the recognition of privacy and re-defined the notion of public interest to exclude mere curiosity and unhealthy interest in individuals lives.[25] It is however, what was decided in these cases that have influenced the way court approach cases that concern balancing the right to privacy with freedom of expression. Consequently, the courts must now balance the two conflicting interests by applying the principles mentioned above to the facts of the case, whilst considering the legitimacy of the expectation of privacy, the level of intrusion and the importance of any public interest in publication. Which allows for the UK courts to mirror the principles that have been laid down by the ECHR and ensure that any interference with privacy and freedom of expression are necessary and proporti onate.[26] Prior to the introduction of the HRA, the right to privacy was relatively underdeveloped, however, much has changed as it can be said that the protection of private lives and private information is one of the fastest-developing areas of the law as judges use the Human Rights Act [27] An early case of the balancing act after the introduction of the HRA was in A v B[28], where the Court held that a claimants public profile generates legitimate public interest in his or her personal life, which strengthens the medias freedom of expression claims. As such, A v B defined public figures as all those who play a role in public life, surrounding all persons in the political, social, economic and artistic world.[29] The Court held that the media have elevated freedom of expression claims when reporting on public figures, the court further mentioned that; A public figure is entitled to a private life. The individual, however, should recognise that because of his public position he must expect and accept that his actions will be more closely scrutinised by the media. Even trivial facts relating to a public figure can be of great interest to readers and other observers of the media.[30] This case suggested that the public interest in such publications extends to private information about various public figures to which can be of curiosity to the public interest. Though, the courts can have very different views on the approach to the balancing of competing rights. For example, in the case of Mosley v News Group Newspapers[31], where the court determined that the right of the claimant was protected by Article 8. In this case, the defendant published a story with the title F1 BOSS HAS SICK NAZI ORGY WITH 5 HOOKERS which was accompanied with pictures, and had been made available on their website with an added video, which concerned Mosley and five other women engaged in sadomasochistic sexual activities and role play.[32] The article involved suggested that these sessions had a Nazi theme and that the role playing had mocked the way that Holocaust victims had been treated whilst in concentration camps. The footage of the session was recorded by one of the women by a hid den camera that was supplied by NGN. As mentioned earlier, when these two rights are in conflict, the court will not give an automatic trump statute on one right over the other. Therefore, the court had the difficult task of balancing the interests of Mosleys right to privacy with the interests of NGNs right to freedom of expression. The court decided that since they could not find evidence to suggest that he mocked victims of the holocaust, there was no interest to the public. However, the court stated that if they had published the story without the photographs and video, they would have allowed for freedom of expression to prevail over right to privacy. Thus, this case confirms that the courts are willing to protect an individuals right to privacy when freedom of expression is not justifiable. The court of Appeal in the case of Murray v Express Newspapers[33]followed in the steps of Von Hannover in holding that routine activities carried out in public could arguably attract a reasonable expectation of privacy. Whilst holding that leisure activities, such as a cafà © expedition could be characterised as part a persons private recreation time.[34] Although the Court failed to define what types of activities would qualify as recreation time and instead stated that the enquiry is highly contextual. As such, the Court further stated given that the publicity of such activities would adversely affect family recreation time in the future, the Court held that the claimant had a reasonable expectation of privacy. The way this case was approached by the Courts signals that a potential separation from the decision that was laid out in Campbell, where it was held that privacy law did not protect innocuous public activities.[35] In the case of Weller, Judge Dingemans did not expressly address the strain between the Von Hannover and A v B plc, which offered little to clarification if the UK courts approach to public figures under the misuse of private information. However, in approaching the balancing test, Judge Dingemans adopted the Von Hannover conception of a debate of general interest,[36] he considered that the photographs did not contribute to a debate of public interest, despite the considerable public profile of the childrens parents. As such, given that the photographs would have satisfied the public interest definition in A v B, given that there is a strong curiosity in Wellers family life, and as such Weller employed a more confined definition of general interest in line with the ECtHR. Although, Dingemans concern for the consequences of prohibiting the publication on the newspaper industry, suggests that the Court doesnt fully adopt the approach set out in Von Hannover. However, Dingemans stated that the photographs in question should be given freedom of expression weight as the is a public interest in having a thriving and vigorous newspaper industry [37] and the ability to publish such things due to public interest was considered important to the commercial wellbeing of the media, as previously stated the medias role is to act as a public watchdog. However, despite acknowledging the distinction in this argument, Dingemans considered that the medias interest did not outweigh the childrens right to privacy in the Wellers case.[38] The recent case and much anticipated case of PJS[39]where a famous figure won the right not to be publicly named in England and Wales over an alleged marital threesome, also known as a super injunction, despite his identity being known elsewhere.At first, the interim injunction was refused, however, the Court of Appeal allowed an appeal and restrained publication of the relevant names and such details.[40] Despite steps taken by PJSs solicitors to remove the story from the internet, despite their best endeavours, the court concluded that there remains a significant body of internet material identifying those involved by name.[41] Thus, NGN applied to Court of Appeal to then set aside the injunction as the information was already in the public domain and the injunction was no longer fulfilling its purpose, and interfered unjustly with their Article 10 rights of freedom of expression.[42] However, the Supreme Court reinstated the injunction saying that without a proven public interest in the content, there is no free-standing public interest in publication. The court cant sanction for one media outlet what it believes, on balance, will be deemed unlawful at trial, even if others have published the material already. As such, Mance mentioned; For present purposes, any public interest in publishing such criticism [of PJS] must, in the absence of any other, legally recognised, public interest, be effectively disregarded in any balancing exercise and is incapable by itself of outweighing such article 8 privacy rights as the appellant [PJS] enjoys. (Emphasis added)[43] Rea argues that this case points out the dilemma courts face daily, especially in the digital age, as such media on the interest cannot be controlled as largely as print or television media.As such these cases illustrate the balancing test in action, and how to courts use that to prevent one right from prevailing the other. References Thompson K, Balancing Privacy and Free Speech: A Critique Of English Privacy Law Under The Human Rights Act (MJur, Durham Law School 2013) http://etheses.dur.ac.uk/9398/> Horsey K and Rackley E, Kidners Casebook Of Torts (12th edn, Oxford University Press 2015) British Broadcasting Corporation, The Public Interest, The Media And Privacy (BBC 2002) accessed 16 February 2017 Harris C, Charlotte Harris: Freedom Of Speech And Privacy Are Naturally At Odds With Each Other. Can You Balance Freedom Of Speech And Privacy? (Mishcon Graduates, 2017) accessed 23 February 2017 Tibbetts G, Max Mosley Admits Passion For Sadomasochistic Sex (Telegraph.co.uk, 2008) accessed 26 February 2017 Phillipson G, Why Should We Have A Right To Privacy? (BBC Religion Ethics, 2013) accessed 21 February 2017 Dyer C, Celebrities To Clarify Privacy Law (the Guardian, 2006) accessed 24 February 2017 [1] Kirsty Horsey and Ericka Rackley, Kidners Casebook Of Torts (12th edn, Oxford University Press 2015) at para 138. [2] The Human Rights Act 1998, art. 8 (1). [3] Gavin Phillipson, Why Should We Have A Right To Privacy? (BBC Religion Ethics, 2013) accessed 21 February 2017. [4] The Human Rights Act 1998, art. 10 (1). [5] Thorgeirson v Iceland [1992]14 EHRR 843 at para 63. [6] British Broadcasting Corporation, The Public Interest, The Media And Privacy (BBC 2002) 19-20 accessed 16 February 2017. [7] Charlotte Harris, Charlotte Harris: Freedom Of Speech And Privacy Are Naturally At Odds With Each Other. Can You Balance Freedom Of Speech And Privacy? (Mishcon Graduates, 2017) accessed 23 February 2017. [8] R v Central Independent Television plc [1994] Fam 192 at 203. [9] The Human Rights Act 1998, art. 8 (1). [10] The Human Rights Act 1998, art. 10 (1).

Comparing Heart of Darkness and Apocalypse Now :: Movie Film comparison compare contrast

Heart of Darkness and Apocalypse Now Heart of Darkness, a novel by Joseph Conrad, and Apocalypse Now, a movie by Francis Ford Coppola can be compared and contrasted in many ways. By focusing on their endings and on the character of Kurtz, contrasting the meanings of the horror in each media emerges. In the novel the horror reflects Kurtz tragedy of transforming into a ruthless animal whereas in the film the horror has more of a definite meaning, reflecting the war and all the barbaric fighting that is going on. Conrad's Heart of Darkness, deals with the account of Marlow, a narrator of a journey up the Congo River into the heart of Africa, into the jungle, his ultimate destination. Marlow is commissioned as an ivory agent and is sent to ivory stations along the river. Marlow is told that when he arrives at the inner station he is to bring back information about Kurtz, the basis of this comparison and contrast in this paper, who is the great ivory agent, and who is said to be sick. As Marlow proceeds away to the inner station "to the heart of the mighty big river.... resembling an immense snake uncoiled, with its head in the sea, its body at rest curving afar over a vast country and its tail lost in the depths of the land" (Dorall 303), he hears rumors of Kurtz's unusual behavior of killing the Africans. The behavior fascinates him, especially when he sees it first hand: "and there it was black, dried, sunken, with closed eyelids- a head that seemed to sleep at the top of that pole, and with the shrunken dry lips showing a narrow white line of the teeth, was smiling too, smiling continuously at some endless and jocose dream of that eternal slumber"(Conrad 57). These heads that Marlow sees are first hand evidence of Kurtz's unusual behavior. The novel ends with Kurtz "gradually engulfing the atrocities of the other agents in his own immense horror"(Dorall 303). At his dying moment, Kurtz utters "The Horror! The Horror!', which for the novel are words reflecting the tragedy of Kurtz, and his transformation into an animal. Apocalypse Now is a movie that is similarly structured to the book but has many different meanings.

Are we too dependent on computers? Essay

When we talk about computers, people often relate computers with modern technologies. Computer is a tool that helps us make things in our life easier. People use computers in business, public services, educations, even entertainment. Our daily activities are more and more based closely on the working of computer. Almost everything we do is affected by modern technology and computers. I would say that I agree that people nowadays depend on computers too much. Firstly, computers controlled cars, planes, ships and other vehicles, so that we can travel safely. Computer is the backbone of most institutions and colleges nowadays. Computer is a popular device among college students. Students get their assignments done using computer. It is convenient for them to search for information using computer or through online library rather than going to library. They save their files in the computer and use computer to make their presentation. Lecturers and students prefer to use computer to work on assignments if it relates to paper work. Moreover, there are plenty students use their computer to take courses and study online. Computer is a convenient device for students. Speaking of health systems, many hospitals and medical offices use computer to store all the patients’ data. It is easy to keep track and is accessible. Medical officer also store important works that are needed to be recorded and stored for health purpose in the computers. The use of computers is very important even in medical field. More and more hospitals use computers to store patients’ data instead of using paper. It will be messy and a lot of paperwork needed to be done if hospitals didn’t use computers. It will also pollute the environments that so many paper works needed to be stored. All the mental work that we need to do can be done by computer or calculator. It would be almost impossible to calculate a huge statistic data w ithout using a calculator. Computers play an important role in human life. Computers allow office workers to work from home too. Computers help us to keep in touch with friends or families that live too far away to visit. We are also exposed to information and knowledge. We can release our stress by playing the computer games when we come home from work or school. People have increasingly relied on computers nowadays. Moreover, people tend to become lazy to think with presence of computer and technology. Most people rely on computers too much will make them forget their own strengths. People are concerned that vital skills can be lost by next generations as computer technology slowly replaces the traditional ways of working. However, computer affects human health if human spend most of their time facing the computer. When we are asked whether we face the computer most of the time, most of us choose to deny or ignore it because we are scared to admit it. Denial or ignorance is a type of resistance. In a research, people are highly exposed to health risks as they spend most of their time sitting in front of the computers to get their work done. We will have eye pain and backache if we face the computer over a long period. We will also face tired eyes, dizziness and other symptoms. This will also affect other parts of our body, such as brain, neck and fingers. We should not deny or ignore these health symptoms as it could affect our life. Let’s imagine if one day, your computer breakdown, will your life in a mess? People work and do their jobs using computers. People save all their documents in their computers as they think that computer is the safest place to keep documents. Entrepreneurs run their business using computers. However, there is a possibility that the computer will breakdown. A serious chaos will happen. Once the computer system fails to operate, people really can’t do anything. People will just sit down and wait for the engineer to repair it. The business will also be affected. In serious scenario, the entrepreneurs will lose millions of business and money. Although it is said that people fall into the fallacy of slippery slope, break down of computer systems really happen in real life. For example in May 15, 2011, Kuala Lumpur Stock Exchange (KLSE) experienced a breakdown in computer systems. The stock exchange came to a standstill for about 5 hours. Most of us also have the misconception that we are in control. Actually we are not. Nobody knows what is going to happen in the future. We can’t really control the computer systems but we can try our best to make sure that computer systems work smoothly. As far as I concerned, computer is a great invention and it is useful to human life. It should be impossible to live without computer as we get too much used of computers nowadays. However, we should use it wisely. We know the fact that the more we rely on computer, the more we will lose in our life. So, we should also find ways to make our dependence on computers less dangerous to us, so that we will not rely on computer completely.