Impact of video games on children Essay

Video games have been available to consumers for the last 30 years. They are a unique form of entertainment, because they encourage players to become a part of the game’s script. Today’s sophisticated video games require players to pay constant attention to the game, rather than passively watching a movie. This has both positive and negative impacts on players. Several studies have been published that explore these impacts on today’s children. Most people this day and age grow up with technology. But now days what people see in the media about children being obese or not social. The media and physical fitness experts always express, the youth this day never go out and play and get about sixty minutes of play a day. This means exercise. I for one think video games isn’t the problem. With children being overweight, video games aren’t always filled with violet’s, there are games that teach you to work as a team with someone you’ve never meet. Even learning sportsmanship which I believe should be learned at a young age. Because facing the realities that you can’t always win there are going to be some people that are better and that you should encourage yourself to become better not just at video games life in general. Within the media they say kids need to go out and play. I think that’s true so what they need to do now a days with games is make it so kids get tired of the games after a while. That way they should try to lean toward making children wanting to go outside. When I was growing up in the 1980s video games where just starting to catch on. All the kids had to have the latest games or â€Å"Gameboys† ext. I remember we would try to find ways to make our parents let use stay inside and play. I believe it hindered me once I got older and wanted to play sports. I was so out of shape then it all came back to me I was hardly active when I was younger. Right now Approximately 17% (or 12. 5 million) of children and adolescents aged 2—19 years are obese. The studies show by kids not eating healthy or even from going outside to play. There are just so many reasons why children are so badly obese. I know video game’s is one of the biggest reason for are youth to being so heavy. Kids rather stay inside being on their video game consoles. I know it’s crazy to say but I believe that it has to do with the area kids are raised. Let’s say you are in a bad neighborhood. Where you know it’s not safe to be outside I know I would want my child to stay indoors so I know that he or she is safe. But I know my child would want to be entertained lots of people know young kids lose their interest in things after time. Which is understandable.

Black Asthetics and Toni Morrison

The black arts, or the black aesthetic, movement was born among the black artist as a response to the ideologies of the black power in the 1960’s. The movement was a continuation of the 1920’s and 1930’s Harlem Renaissance that had begun the tradititon of rediscovering the roots os black culture and heritage,dating back to slavery. Some of the major literary figures of the Harlem era included authors James Weldon Johnson, Langston Hughes and Nella Larsen. The Black arts emerged to promote art that illustrated African-American music, languages, heritage, and beauty. In order to be substantial, art had to have a proudly black subject matter and style; be it sculpture, a piece of music, a novel or a poem. Empowered by the concepts of the black power, the movement inspired the emergence of the black theatre groups, magazines, and printing presses. Literature influenced by the black arts concepts struggled to abandon W. E. B. Du Bois’ idea of double consciousness, which meant blacks were constantly struggling towards the white culture’s ideals, even though the dominant society disabled them for reaching the Eurocentric goals. Mirroring themselves against the value structure of the oppressive white society was depriving the blacks of their empowerment. Black writers wanted to concentrate on solving the problems of the African-American community from the inside, developing awareness of the rich black heritage and gearing the co mmunity to realize it worth. The Black Arts movement brought the time for blacks to stop internalizing the image of being the inferior in the society as a whole. The black population had to find strength, beauty and self esteem within the black community. The black arts, characterized by acute awareness, produced writers like Toni Morrison, Ishmael Reed, and Alice Walker. Toni Morrison undeniably is an author who internalizes the main concerns of the black aesthetic. She writes about black oppression, consciousness and tradition. Her major characters’ are black and they are in constant search for their ethnic identity. The first African American writer to win the Nobel Prize for literature in 1993, Toni Morrison is a leading voice in current debates about the construction of race and black marginality in literature and culture. As a prominent writer of the age she refuses to allow race to be marginalized in literary discourse. Throughout her writing Morrison uses narrative forms to express African Americans' dislocated, oral tradition, and culture, and reclaim African American's historical experiences. She profoundly uses the fictive narratives to transfigure the old south; the bedrock of black dehumanization, degradation and sorrow into an archetypal black homeland, a cultural womb that lays claim to history's orphaned, defamed and disclaimed African children. In her novels Morrison humanizes black characters in fictions that strive to overcome and excavate enforced invisibility of African Americans' social reality. Morrison critiques the mainstream thinking and acclaims that black writers and black characters are the relative means by which text demonstrates to be human and superior. Imagination is possible in the presence of black characters and black contents. At the same time talking African discourse is inferior and submissive tends to impoverish cultural interpretation of reality. Morrison questions the validity and vulnerability of a set of assumptions conventionally accepted and taken for granted among literary historians and critics. Africanist presence, in a constitutive part in the entire history has been rejected. Morrison in Playing in the Dark: Whiteness and Literary Imagination proposes, â€Å"[t] he contemplating of this black presence in central to any understanding of our national literature and should not be permitted to hover at the margins of the literary imagination† (5). Morrison argues that American culture is built on, and is premised by, and always includes, the presence if blacks', as slaves, as outsiders. She likens the unwillingness of academics in a racist society to see the place of Africanism in literature and to the centuries of unwillingness to see a favorite discourse, concerns and identity. She posits whiteness as the ‘Other' of blackness, a dialectical pair, each term both creates and excludes the other: no freedom without slavery, no white without black. The major themes of Toni Morrison's writing is to redefine the notion of white American canonical texts and their idea of African American writing as being non-canonical or inferior. She demonstrates the idea of racial superiority and hegemonic culture in her writings. Morrison, in the preface of her critical work Playing in the Dark: Whiteness and Literary Imagination says she is â€Å"struggling with and through a language that can powerfully evoke and enforce hidden signs of racial superiority, cultural hegemony and dismissive ‘Othering' of people and language which by no means marginal or already and completely known and knowable in my work† (XI). It is clear that Morrison's writing is different from that of mainstream white discourse, which always bserves that African American literature is subsidiary product. Her intention, thorough her writing , is to reinterpret and redefine the hidden, dislocated and alienated Afro-American presence in American mainstream discourse and claim that Afro-Americans are no more inferior human beings. Toni Morrison's fiction demonstrates a central interest in the issues of boundary, attachment, and separation. Her characters experience themselves as wounded, or imprisoned by racial and economic divisions within American culture. The boundaries that circumscribe black people are not only the prejudices and restrictions that bar their entry into the mainstream but the psychological ones they internalize as they develop in a social structure that historically has excluded them. Toni Morrison draws from a rich store of black oral tradition as well as from her own imaginative angle of vision to illuminate the potentialities for both annihilation and transcendence within black experience. Black lore, black music, black language and all the myths and rituals of black culture are the most prominent elements in Toni Morrison's writing. She feels a strong connection to ancestors because they were the culture bearers. She thinks that it is the responsibility of African American writers to dig out that annihilated history and secure the importance of it in the making of American civilization. Toni Morrison ranks among the most highly regarded and widely read fiction writers and cultural critics in America. As a critic she refuses to allow race to be relegated to the margins of literary discourse. She focuses on the importance of African American's oral and musical culture and to reclaim black historical experiences. Morrison says that African American have rediscovered texts that have long been suppressed or ignored, have sought to make places for African American writing within the canon, and have developed ways of interpreting these works.Works CitedMorrison, Toni.  Playing in the Dark: Whiteness and the Literary Imagination. Cambridge, MA: Harvard UP, 1992. Print â€Å"Toni Morrison.†Ã‚  Wikipedia, the Free Encyclopedia. 21 May 2011. Web. 23 May 2011. .Welcome to Black Aesthetics Institute. Web. 23 May 2011. .

Future of Canadian Force

FUTURE OF CANADIAN FORCEHarmonizing to research Canadian Forces can be defined as armed forces set up by Canada and is made of ; the Air Force, Land force and Canadian Navy. Canadian Air Force has 13 bases around Canada, Nova Scotia, Quebec, Manitoba, Saskatchewan, Alberta, British Columbia, Labrador and Newfoundland being the major air bases. The bid control and administrative installations are in North Bay and Winnipeg severally. NATO Air Based is based in Geilenkirchen. Canadian Land Force can besides be referred as the Canadian Army whereas Canadian Navy is referred as Maritime Command and a descendent of Royal Navy. The Maritime Command has 33 pigboats and war vessels at the Esquimalt Royal Navy Dockyard on the west seashore of the Pacific and at Canadian Dockyard on the east seashore of the Atlantic. Canadian Command was created in 2006 to better clip response to natural catastrophes and domestic terrorist act commanded by committee officer. Harmonizing to Jayson Myers President of Canadian Manufacturers and Exports, economical challenges and unprecedented market volatility are a fact that Canada is populating in planetary economic crisis.What should the hereafter of Canadian defense mechanism force be?In the close hereafter the Canadian authorities will hold to happen off to keep the military personnels in Afghanistan, , if they withdraw the war, the troops outgo will be the best program to salvage the authorities from shortages. The budget will be cut if they do n't set about their missions ; therefore turning their economic system. Most recent UN missions have successfully proven at enforcing peace ; missions were conducted by armed military. ( National Post Magazine ) Canadian Defence Force requires the reshaping and reorganization of its armed forces. In the past the authorities argued that the traditional arrangement of the Royal Navy, Canadian Army and the Air Force service head and commanding officer might non run into the challenges presented to them in the hereafter. After World War I Canada began to incorporate defense mechanism activities which did n't last long, it was ended earlier World War II, but when the war was over the British Commonwealth existed through the traditional administration. Canadian politicians are non and ne'er have been interested in defense mechanism ; Canadian populace can non get away a portion of the incrimination. Too many of our people think that all we enjoy was ever at that place, was non fought for, will merely go on, without our personal attending. We are no longer doing any attempts in international personal businesss. While some sensible grade of freedom still remains for us under our signifier of authorities, we must confront the fact that this freedom will shortly vanish unless we exercise our rights sagely. Canada must take major strivings to guarantee that we are good plenty informed on the pick of wise leaders – possibly, great leaders. I quote ; Rear Admiral Jeffrey Brock, DSO, DSC, CD, RCN, was functioning as Vice Chief of Naval Staff in Ottawa in the early sixtiess. Canadian authorities needs a traditional peacekeeping even after the undertaking backdown in Kandahar, either under the United Nations regional authorization or NATO. The authorities should guarantee that the picks she is doing are a better benefit to the Canadians civilians and military therefore they need to be really first-class in peacekeeping. The Chief of Defence Staff spoke on the Canadian conflict of inundations, fires and ice storms all over the state and the political agitation across the universe. The extended reforms and the strong battle decrease on the budget and became transparent on the populace they serve. Other types of international securities are likely to come up in the hereafter to contend non-traditional panics like cyber-terrorism and terrorist act. Human rights issues such as nutrient entree, clean H2O entree, energy, ecological debasement and infective diseases. Security along the boundary lines is no longer an entirely measured in geographic boundary line, therefore keeping and procuring a boundary line requires impact on economic figures, so as pandemics such as swine grippe, HIV/AIDS, clime alteration and struggles between the provinces can non be easy prevented. Defense mechanism policy has to find a manner to avoid its permeableness to money crisis, migration, engineering and diseases. Canada has improved on how to react in struggles created by different ethnics and faith. Besides non-Canadians who have entree to unsafe arms used in guerilla warfare needs a force that can analyse and make up one's mind between the terrorist act. Assorted provinces that are willing to lend their military personnels and constabularies will hold to accept and hold to the challenges that awaits them in peacekeeping, therefore traveling from the traditional peacekeeping which is maintained by CF personals. The duologue between the province members helps in casualties and costs. CF experience in Afghanistan has a large value in polishing usage of advanced engineering in struggle state of affairss. Police and military personnels who have no experience therefore preparation and back uping them can help in the UN mission. An identified and a functional bid and communicating system is important in peacekeeping. A major dissension has been on civil military coordination and civil military cooperation at the tactical and operational degrees.What are the major menaces to Canadian security today?The Canadian Security Intelligence Service is an internal security of the Canadian Government which is responsible for analysing coverage and roll uping information needed on menaces to Canada National Security. The Canadian security Intelligence Service was established following the McDonald Commission if Inquiry in 1984. The service is responsible for early warnings to the authorities and bureaus on the suspected activities that threatens the state ‘s security. Due to the rise of terrorist act and the death of the Cold War, Canada Security Intelligence Service has put across a public safety precedence. This can be seen in the high proportion of resources devoted to counter-terrorism.Some of the activities that menace CanadaSabotageThese are activities conducted in order to jeopardize the safety, security, public or private belongings, and make fear to the Canadian people.EspionageThese are conducted for the intent of desiring to get improper agencies of informations or sensitive political assets, economical plus, military arms and besides unauthorised foreign communicating to other organisation.TerrorismThis is the menace or usage of force to seek and oblige the Canadian ‘s authorities to move or follow with their demands. Some of these activities may take to decease to people, devastation of public and private belongingss. Character assassinations, bomb menaces, surety pickings are merely illustrations of some of those activities tha t endanger the day-to-day live of Canadians.The actions may be to coerce a given political response.CorruptionThese are intended to other throw the authorities by force and usage of force. Corruption seeks to destruct the electoral, legislative, administrative and judicial procedures of the state. Harmonizing to the CBC intelligence the National Security Policy was talked in parliament 2004, they outlined a wide range security, and public safety to protect the people of Canada. The authorities set aside about $ 690 million for the action program and model. ( CBC News Online | April 27, 2004 ) The Deputy Prime Minister and Public Safety ; Minister Anne McLellan ; said the program titled Procuring an Open Society: the policy is based on three national security involvements: First ; protecting Canada and her people place and abroad. Second ; lending to international security. Third ; guaranting Canada is non a base for menaces. In the address made to W.P.D. Elcock Director of the Canadian Security Intelligence Service to the Vancouver Board of Trade, it was said that the Al-Qaeda still remains the most unsafe organisation of international range. It still continues to have its support from the terrorist groups like Sunni or persons across the universe.What Does the Security and Intelligence Do?The service contributes safety and security to its people, therefore the service must judge the growing of menaces supplying good advice to political leaders and what steps of bar they can take. The work of the service is ; supplying the authorities with advice on specific menaces to the state. Supplying the intelligence that is used by the authorities for its day-to-day usage and for long term scope development in determination devising. The service entree major issues and events impacting her involvements. They investigate assess menaces to the security on her people.CANADIAN ALLIANCEThis was a party that was in betw een 2000 and 2003, the party was a replacement to Reform Party of Canada and made a interruption through and was positioned as the Official Opposition. It supported all the policies and seeked decrease of the authorities disbursement and decrease of revenue enhancements. The confederation of Canadian Dietetic Regulatory Bodies consists of 10 equal and independent dietary regulative organic structures. Its intent is to protect public. It is besides responsible for reflecting current dietary pattern and model The function of regulative in the populace have authorized and is responsible for executing these ; construing dietary Scopess of patterns, such as restricted activities. Establishing, implementing and keeping the criterions for the ethnics, behavior and go oning competency. Protecting professional rubrics and appellations into distinguishing regulate and unregulated nutrition. Ensuring dietary instruction and preparation plans meet their demands for enrollments. Assessing and registering qualified appliers in their provincial legal powers. Investigating and deciding ailments about a dietician ‘s pattern, and fit pattern. Some of the aims of the Alliance are ; developing common model to set up criterions for entry to pattern and go oning competence. Facilitating labour mobility for dietetics. Communicating with the external groups on affairs related to the ordinances of the dieticians in the state. International Migrants ‘ Alliance Harmonizing to Asian Pacific Mission for Migrants adult females are the most exploited people in the universe. Those who are oppressed largely are migratory ‘s workers and immigrants whom are non-documented. These conditions have increased due to the failure of non-neo-liberal globalization and that has lead to many prejudiced policies posed by the authorities. The policy is a national confirmation strategy of Thailand which is to put phases for monolithic crackdowns on foreign workers and migrators. Queerly some states in the part where barbarous onslaughts have occurred besides are willing to shortly come up with the rights of adult females and immature kids. International of Canada and the Public Service Alliance of Canada was held in 2010, April. The party agreed on the major outstanding points presented, these are ; paid vacations, torments, holidaies, staffing processs, suspension and subject, and layoff callback.Industrial AllianceIndustrial Alliance Insurance and Financial Service was founded in 1892 which is a life and wellness insurance company which offers a big assortment of life and wellness insurance merchandises. It is besides the 4th largest insurance company in Canada.

Current performance of Islamic bank around the world Dissertation

Current performance of Islamic bank around the world - Dissertation Example However, some countries such as Indonesia, Bangladesh, Egypt, Malaysia and Jordan are offering the services of Islamic banking through traditional banking services. In some countries like Pakistan, there are banks that are operating in accordance with the Islamic laws and at the same time there are some banks that are practicing conventional banking and at the same time some of their branches are offering Islamic banking services. Not only there has been an increasing trend of Muslim majority countries practicing Islamic banking products but certain Western countries including United Kingdom, United States and Australia have been also observing an increasing trend in regard to the Islamic banking. Although the industry of Islamic banking is still growing and an emerging industry, but in different parts of the world this industry has been achieving very high profits unlike United Kingdom. However in countries like Pakistan, Bangladesh, Bahrain this industry has been growing. In Pakistan, Islamic banks have reported a profit of 5.7 PKR which is approximately 59% of the total market share in the year 2011 (The News, 2012).). In Bahrain, Islamic banking industry is also one of the fasted growing industries of the countries and still there are several opportunities in the countries (Laxman, 2011). In addition to this, Islamic banking industry is showing good progress and is giving tough time to traditional banks in several other western countries. Financial performance of Islamic financial institutions in UK United Kingdom and particularly London has been considered as an important market place by investors and in this part of the world; both Islamic and non-Islamic banks have inve sted. Initially Islamic banks started their services in London by offering simple products like house financing however with the passage of time the quality of products as well as the complexities involved increased (Ainley, Mashayekhi, Hicks, Rahman, and Ravalia, 2007). after analysing different opportunities for profits and growth, number of Islamic banks invested in United Kingdom and tried to capitalise on these opportunities. Some of the most prominent names of Islamic banks in UK are: Islamic Bank of Britain HSBC Amanah Lloyds TSB The products and services offered by Islamic banks are not only for Muslims but for non-Muslims as well and this is one of the reasons why it has become highly famous in UK despite of the challenges it faces. However recently the performance of the Islamic bank has not been satisfactory and the opportunities that every one identified had not been capitalised by these Islamic banks. This is one of the reasons why one of the leading Islamic banks, Isla mic bank of Britain had to be bailed out in the year 2010 by Qatar after several successive years of losses. After the financial crisis, the Islamic banks in United Kingdom have suffered a lot. Lloyds Islamic bank also removed its investment from United Kingdom as they did not see bright future in the country (Goodway, 2010). Islamic Bank of Britain which has been able to make a name in the United kingdom is also losing its customers. in 2009, the Islamic bank had lost almost 50,000 customers as the total loss of the bank increased to ?9.5 million from ?5.9 million. Considering the situation of the bank, IBB had to raise additional capital of 2009. Then

Trainspotting Movie Review Example | Topics and Well Written Essays - 1750 words

Trainspotting - Movie Review Example Renton, Spud, Sick Boy, Tommy and the violent Begbie were all friends, lived in Scotland and hated it. They hated the dull life of Scotland. The story of the film revolves around Renton and his attempts to give up the heroin-addiction and to come out of the negative influence of his friends Tommy, Spud, and Sick Boy. The story also follows Tommy, Spud, Sick Boy and Begbie; their stories are beautifully projected in the film and their characters have displayed different aspects of the contemporary society of Scotland. It is said that Trainspotting is not a British film at all; rather, it is a Scottish film which strongly asserts uniqueness of Scotland and does not associate itself with the general tourist-version package of Scotland. The film establishes the fact that Scotland also has a distinctive and healthy school of cinema. Trainspotting can be considered as a milestone of a ‘new Scottish cinema,’ which is quite different from all the stereotype movies made in Scotla nd in the past. It denies the Tartary and kailyardism which was imposed by outside filmmakers and by embracing contemporary and urban Scotland; it has became a milestone of Scottish film industry. Trainspotting: An evaluation The story of the movie is narrated by shifting narrators. ... The alienation of Renton has been beautifully highlighted in the night-club sequence in Edinburgh when his friends were dancing and he was shown standing alone in a corner of a room. Renton has lost his sex drive due to his drug addiction which is returned in a vengeance and the days and memories of impotency and the days after that has been remarkably shown in the movie and Renton’s desperation, his lustful mind and his happiness after regaining potency make the audience laugh but at the same time raise serious notes. The movie Trainspotting seems to lack a defined time frame which sometimes becomes confusing. For instance, the duration of fibula is not known, the duration of Renton’s stay in London is not clear, or the time taken by Tommy for his experiments with heroin and his death. The film has a couple of flashbacks and a couple of flash-forwards and it appears like different episodes of soap. The director of the film is basically a director of soap-serials which is quite visible in the movie. â€Å"Trainspotting also cuts across genres mixing realism with fantasy, offering the characters. The redemption of material impoverishment through aesthetic transformation. The film depicts poverty realistically, but in a way that encompasses the possibility of escape as well as entrapment, and in exploiting the aesthetics of film draws ‘a kind of vitality from grinding poverty† (Smith). Scotland is considered a beautiful tourist spot of Britain which has a lot of scenic beauties but Trainspotting has failed to represent Scotland in an ostentatious way; on the contrary, it has been displayed in a banal manner. The depiction of Scotland is quite dull and dark whereas London has been portrayed as bright, warm and colorful and it clearly highlights

Corporate Planning Essay Example | Topics and Well Written Essays - 4000 words - 1

Corporate Planning - Essay Example In the 1930s, after the Great Depression, quality of life management became the most modern phase of CSR where issues of improving societal gain in areas of lifestyle enhancement became the objective of business, government and corporate leadership. As time progresses, economies and specific international regions are recognising new trends in social attitude and consumer behaviour which are driving new and innovative practices for ensuring positive corporate reputation and also satisfying social beliefs on moral and ethical business practices. The historical phases of CSR maintain both strengths and weaknesses, which will be identified in this paper along with discussion of how these historical phases have developed into new CSR objectives in modern society. Additionally, recommendations on implementing effective corporate social responsibility activities in Hong Kong will be identified and discussed. The concepts of social responsibility were largely generated from the American perspective, since this region was essentially a launching pad for industrialism and growth in the late 1800s. â€Å"America in the 19th century was a society of economic scarcity where economic growth and the accumulation of aggregate wealth were primary national goals† (Hay and Gray, 1974, p.136). It was during this period where the business system was considered to be a quality tool for reducing this scarcity, thus the focus of leadership in the corporate environment was to ensure maximisation of profits in order to enhance total economic growth within a region. One weakness of this historical phase is that it did not involve governmental influence when dictating what were acceptable social responsibility policies at the business level, therefore there was no regulatory body to oversee business activities at the internal level. Because of this lack of regulation and legislation, companies were allowed to exploit child labour and provide unsafe working conditions for

Compare and contrast Essay Example | Topics and Well Written Essays - 250 words

Compare and contrast - Essay Example This essay aims to provide the similarities and differences of school library and Internet on the role they play on the life of a student. Both the Internet and the library are great sources of information that provides students with relevant information for their studies. The difference is that the library can store only a limited number of books, information, and materials necessary for research and learning while almost everything you need to know and wanted to find out can be access online. But in terms of reliability and accuracy, the library still tops as the leading source of information. Information over the Internet can easily be altered and edited anonymously and anyone can make a claim or assertion on it, while books and several materials in the library are in print sources that makes editing and alteration too way impossible thus assuring researchers for accurate and reliable information (Fleming). The emergence and widespread use of Internet by students for their educational and research needs has replaced the role school libraries play in the life of a student. Because the Internet works faster and way more convenient than libraries, students depend on this technology for quicker and accessible research. Despite their differences, both are significant tools in providing students access to relevant information and supports the development of their research skills (â€Å"The Role

Unit 3-IP- Theory & Policy Essay Example | Topics and Well Written Essays - 500 words

Unit 3-IP- Theory & Policy - Essay Example The evolution of criminal profiling can be debated through varying opinions or points of view. The FBI‘s Behavioral Sciences Unit (BSU) is endorsed with the enhancement of criminal profiling. One should consider that the actual act of accessing a criminal’s mind can be traced back in history. In the past 30 years, it has become increasingly reliable and has gained high opinion from the media, society and professionals alike. During the late 1970s and early 1980s, John E.Douglas was among the most prominent criminal profilers of 20th century, and was among the very first to introduce this science of criminal profiling to the FBI (Turvey, 2011). John Douglas has been recognized with developing the present day art of criminal profiling. This was after his work with major criminals such as Edmund Kemper (Coed Killer), known for the murder of ten people, Richard Speck, who murdered eight nurses, and Charles Manson, a feared mass murderer. His work led to the opening of Behavioral Sciences Unit (BSU) of the FBI, which was vested with the responsibility of criminal profiling. Now retired, Douglas and his team were the first to introduce criminal profiling to the US justice system. Edgar Allen Poe is another person, who contributed immensely to the development of criminal profiling (Turvey, 2011). Important issues dealing with criminal profiling are seen in his literary works like â€Å"The Telltale Heart.† This is probably one of his most famous works. The Telltale Heart is the story of a murderer who keeps the body of his victim beneath the floorboard of his house, and after searching, the police find nothing. The murderer then slowly loses his sanity, because he kept hearing the heartbeats of his victim. Eventually, he turns himself in. Poe must have analyzed and understood the criminal mind, since the story is told from the murderer’s point of view. The final case study is that of Jack the Ripper, who was among the most infamous serial killers

MGT Week 9 SA Research Paper Example | Topics and Well Written Essays - 250 words

MGT Week 9 SA - Research Paper Example When a particular question has to be answered, as in the case study of Florida State University, triangulation methods are suitable. The mixed approach study revealed how different methodologies can be combined to enhance research results’ validity. Qualitative researches are more suitable for exploring broad matters whether it is a perspective or a particular question while quantitative researches are more useful for results that can be measured or calculated. Observation is a key tool that is used in qualitative researches for getting the required information. Personal observation in qualitative research methodology adds reliability to the results because minor details are taken into account that are normally missed out in quantitative methodology. When a mixed approach is used to carry out the research, benefits of both qualitative and quantitative research methodologies are combined which enhance the research. For example, use of observation and interviews in addition to surveys helps the researchers uncover more facts to draw the conclusions

Pick one of the topic on the attachment Essay Example | Topics and Well Written Essays - 1000 words

Pick one of the topic on the attachment - Essay Example It is the responsibility of the project manager to ensure that the organization selects the right project. For the survival of the project, adequate resources are vital which will ensure its sustenance to the final stage. The projects requires being in line with the organizational goals. Periodical review of the program is necessary for the achievement of its set goals. In case, the planned outcome and the actual outcomes are not in unity, the management team conducts a review on the entire project regarding the allocation of resources and carries out necessary changes to ensure the achievement of major objectives (Brennan, 2011). The team company assists in the formulation and the enforcement of different policies and standards that govern the implementation of the program. For example, the team comes up with some strategic goals, such as those related to the IT area and be able to weight the project basing on the outcome. The reason for weighting the outcome is to determine if the project is significant enough and hence worth undertaking. The team company monitors the projects progress and reports to the project management team for necessary actions. The step is thus subject to consider as being among the best practices in project management due to the active monitoring of the projects. The issue here is that companies come up with projects but fail in implementing them due to lack of adequate management of company strategies. In this regard, project portfolio management becomes an essential tool for the success of a project. The team company engages in outlining the resource requirements for the completion of the projects followed by seeking necessary funds to finance the expenses. Every stage of the project lifecycle is important for its success. The processes begin from the conception of the project, planning, implementation,

Is rape a product of sexual desire, or the exercise of power Essay

Is rape a product of sexual desire, or the exercise of power - Essay Example Having this in mind, this paper examines the issue with a view of examining the motivation of rapists as either sexually aroused or as men or women who have decided to exercise their perceived powers over their victims through intimacy. It will also look in into the matter of a continuously broadening side of criminality and violence within sexual relationships. The aim is to examine the various elements that come into play when handling matters dealing with rape in the society today. Rape can be generally defined as the use of violent means or threatening words to lead someone into submitting to sexual intercourse (Smart 1995). This act can therefore result into serious violation of the victim’s dignity as well as loss of self confidence among other physiological side effects (Kelly 1998). There are various theories that have been proposed to explain this inhuman act. One of these theories will be discussed in the section that follows. One of the long found theories of sexual assault was based on the belief that rapists were mentally ill or had some biological imbalances in their body that contributed to inability for any proper control of their impulses. This theory is referred to as the psychopathology model. It proposes that rapists were medically unfit individuals that were acting in an inhuman manner because of their bodily imbalances (Terry et al 2010). This theory thought that rape was a rare occurrence and hence could be effectively handled by medically proven means like hormonal injection, psychotherapy or even castration. When looked at in the view of the two divides that are being examined by this paper, the theory supports the view that rape may be as a result of sexual desire or the inability to control such desires. However, this model may only apply to a few cases of rape that has been a growing concern in the moral foundations of the society we live in today. The

Business Studies - Marketing Mix Essay Example for Free

Business Studies Marketing Mix Essay All businesses offer some form of service as part of the product that they supply to customers. This is true of businesses supplying manufactured goods, as well as those that only supply services. By meeting (or exceeding) customers expectations, businesses can improve their image and establish a reputation for supplying products with high -quality characteristics. The features of quality service include: * Making sure the customer is safe This is crucial for a high profile business like IKEA otherwise the media will be straight on to them issuing bad press against them, potentially giving IKEA a bad name, furthermore the customer may wish to take legal action if he/she feels mistreated by IKEA. Again causing problems for IKEA. * Delivering good customer service Decisive for IKEA to maintain the good name they have, customers in this day and age will not accept poor service, otherwise its likely they will look elsewhere. * Improving the quality of the product Its important IKEA continue improving the quality of there products otherwise customers will begin to lose interest in the company due to its lack of creation and continued progress; customers want to see new/improved products on each visit they make to IKEA. * Making sure the customer is not kept waiting If IKEA let customers wait for there service, its likely they will simply leave the store and go else where, so its important there staff are motivated and wanting to give IKEA a good name. * Demonstrating good after sales care Once the sale is done its easy to take the money and thats it, but with IKEA if a problem arises they will want to help the customer in any way possible. Its vital for them to retain customers and not lose them to a competitor, and clearly IKEA are doing a good job at this as there profits continue to increase meaning the customers are happy with how they are treated both before and after sales. To see how business offer service in practice, lets look at some real examples. IKEA sells their products ready to be fitted, meaning the products they sell have to match customers precise requirements and also come with good instructions to help them build it at home. Otherwise people will see it as a hassle, meaning they re less likely to purchase from IKEA again. IKEA has bought it self a good name due to fact they offer good after sale services so if needed to contact a member of staff its possible, they give you a good instructional manual, if thats not enough you can phone them, email them or even talk 1 to 1 with a member of staff on their website via their web chat facility. It is this combination of products together with a range of services that is important in shaping and determining Ikeas reputation, the distinct characteristics of its products and the companys competitiveness. IKEAs website is also a key part in generating sales for there products, its important they describe the product clearly, and give the customer as much information about the product as possible, its less likely that someone will make a visit to IKEA for a product they arent given much information about on their website. The above picture is the basic layout for all IKEA products on there website, it has a clear picture of the product, price, special features, measurements, whether it requires assembly, care instructions, material made out of. It also gives the customer the option to see whether they have that product in stock at your local IKEA store, which from personal experience is very useful and practical. IKEA do give a lot of information which reassures the customer that this is the product they want, giving them a buzz and actually wanting to get down to IKEA as soon as possible to purchase the product. B) Price is the amount charged by a business for its products. The factors determining the price of a product can be summarised as the three Cs: Cost, Competition and Customer value. * The cost of producing the product: If a business is to make a profit, then it clearly needs to charge a price that covers the cost of making and selling the product. * The price charged by competitors: A business might want to charge a price at or below that of its competitors. However, if the product is sufficiently unique and superior, then the business might feel it is acceptable to charge a price above that of its competitors. IKEA excels here, in the sense that it offers prices cheaper then its competitors, putting them ahead of the game. * The price customers are willing to pay: This is determined by the value of the product to the target market. If consumers in the target market believe that they can gain significant benefits from the product, then they will be willing to pay a high price. However, if the product provides few benefits, consumers will only be prepared to pay a low price, for example, the price someone is willing to pay for a house will depend on its location, the number of rooms and other factors such as the size of the garden. A business will consider all these factors before deciding on a price for each of its products. In certain situations, it may be appropriate to set a relatively high price. For example, Ikea may set a premium price on a high quality piece of furniture that is widely recognised as being superior to other similar products made by competitors. In other situations a business may opt to set relatively low prices. For example, a new company operating in a very competitive market may set low prices relative to its competitors in an attempt to win business and build a customer base. IKEA are renowned for their cheap prices and high quality products. This has helped them build a huge reputation, and ultimately there cheap prices are a unique selling point, when people think, where can I get good, yet cheap furniture from? Instantly in most cases they think IKEA. IKEA is renowned for being value for money. c) Promotion is a series of marketing activated designed to make consumers aware of products. The ultimate aim, of course, is to persuade them to buy those products. Promotion is an important part of the marketing mix, and business can use a variety of different types of promotion. One of the methods is advertising, advertising is a means by which businesses pay for communication with actual and potential customers through newspapers, television, radio, the internet and other media. It can be expensive, but advertising is often highly successful in influencing consumers purchasing decisions. Advertising can be informative, by setting out to increase consumer awareness of a product. This type of advertising is based on facts rather then images. On the other hand, persuasive advertising attempts to convince consumers to purchase a certain product. Persuasive advertising aims to persuade that the advertised product is better than the competition. Sales promotion is any activity that provides a financial incentive to purchase a product. For instance Ikea may hand out free samples of food in their newly built restaurant or perhaps have demonstrations of how to put together some of their products to show customers thats its easy, and can be done by anyone. IKEA advertising in the UK is intended to raise awareness of the IKEA brand and drive traffic to the stores. Some people love IKEAs unique style of retail advertising, some hate it, but everyone who sees there advertising has a strong opinion and subsequently it provokes conversation and debate. Despite having some of the most controversial television advertising campaigns in the UK this includes criticising the taste of the British public, invisible furniture, an exaggerated homosexual man advertising for IKEA. IKEA have raised awareness of there brand, let people know they are different to other home furnishing companies and most importantly increased sales. The advertising department includes all aspects of advertising and brand communication from television advertising and sponsorship to magazine and radio promotions. Advertising is used to support many different areas of the business including brand awareness, store themes, catalogue drops and store openings. The term merchandising covers a range of tactics used by businesses at the point of sale (the location at which the products are actually purchased) to achieve higher sales figures. For example, a business might offer retailers special display stands or point-of-sale adverts to encourage them to place the businesss products in a more favourable and prominent position withen stores. Merchandising can be important when: * Consumers make decisions at the point of sale. This includes a lot of information about the product, making it bright, clear and attractive. * Competitors make extensive use of merchandising. * A variety of rival products are on display in stores. * Rival products have only minor differences. Businesses seek good publicity, and public relations (PR) is designed to improve businesses standings in the eyes of consumers and other interested groups,. Larger organisations have their own PR staff. Ikea engage in a variety of PR activity including: * Making donations to charities IKEA support unicef to help young children in less fortunate countries around the world. * Sponsoring sporting and cultural activates, and IKEA support the local community by donating products to schools which dont sell in stores, this is very popular in the community, and keeps the public happy, which creates good press for IKEA. * Allowing the public to visit the business Makes the customer feel more welcome, and at home with IKEA if they feel involved by learning more about the company. Public relations can be a very expensive form of promotion, and it can be difficult for businesses to assess the effect of public relations on sales. Catalogues are a huge part of advertisement for IKEA, its relatively cheap when compared to TV adverts, and its fairly easy to get to the customer, IKEA print 131 million copies of there catalogue making it the most widely distributed commercial publication in the world. Having picked up a couple of the latest IKEA catalogues and handbooks, its clear that IKEA thrive on simplicity. The IKEA text is the same font on all brochures, with the traditional blue and yellow logo on the bottom hand side of the page this creates continuity which means people recognise it straight away when they see it again, the traditional yellow and blue logo is based on the colours of there home country Sweden. The background images are warm, cosy, family pictures, one containing a large sofa with numerous pillows, the other an aqua blue kitchen. This gets the message across to the reader that there is a large range of products available, furthermore on the front cover they get the message about there prices, Pay less, enjoy more and your 100 page guide to making an affordable, inspired choice. This encourages the public to go through the IKEA catalogue. Furthermore the catalogue brings the IKEA store into your home, its the best way to prepare for a visit to IKEA. d)Place is another term for distribution. It covers the range of activities necessary to ensure that goods and services are available to customers. Deciding on the right place involves a range of decisions. A business needs to consider the most cost-effective way of getting its products and service to the customers. It needs to look at the implications for its profit margins of each means of distribution. The growth in use of the internet has encouraged even small businesses to use websites to sell their products to what can be a global market. This can be highly cost effective means of reaching a wide target audience, but is not suitable for all business and all products. Businesses seek to design marketing mixes that are complementary and work together to benefit the business and to maximise sales. For example, Ikea promotes itself to its target audience on the basis that it offers the lowest possible prices. Place is important to Ikea, and the company locates stores in areas where it costs less to set up, eg on the outskirts of major cities. Which targets both high income earners and low. IKEAs transport methods are highly effective, large volumes in combination with flat packages are important in helping IKEA to transport products economically from the supplier via the stores to the customers. Flat packs mean that IKEA do not have to pay for transporting or storing unnecessary air and that not only means lower warehousing and distribution costs, but also less impact on the environment. At present 20 % of all IKEA goods are transported by rail. 6) It makes sense for Ikea to target a wide range of customers. This is referred to as mass marketing. But theres the other side of it where in some situations they will target small sections of the market. Taken to the limit, this might involve catering for a small select group of customers a target market that has very specific needs. I.E childrens section. In mass marketing, Ikea would aim their products at most of the available market and normally try to sell a range of similar products to all customers. Mass marketing is possible if the products are popular and purchased by many different types of people. For example Ikeas furniture products are well suited to being sold in mass markets. Businesses must be able to produce on a large scale if they are to sell successfully in a mass market. A company may have to invest heavily in resources such as buildings, machinery and vehicles. Usually, firms also have to be very price competitive to flourish in mass markets. By contrast, niche marketing involves companies identifying and meeting the needs of relatively small areas of the market. The aim is to cater for the needs of customers that have not been met sufficiently by other business, and niche marketing is one way in which small businesses can operate profitably in markets that are dominated by large firms. An example would be Ikea and their play pen for younger children. Market research helps businesses to identify whether they should adopt a mass or niche marketing strategy. In general, this would depend on: * Whether the needs of customers within all parts of the market are being met. * The extent to which a business can provide specialist products capable of meeting the needs of select groups of customers. This gives IKEA good idea whether there is a need for a unique product on the market, or a product aimed at a special selection of customers, doing this research could potentially uncover new opportunities for them. * The degree to which competitors are currently meeting the needs of all customers within the market. 7) Market research is the systematic collection and analysis of data to enable a business to take better quality marketing decisions. In simple terms, market research allows businesses to find out what customers want. There are a number of reasons why businesses invest in market research. To determine whether IKEA should focus on mass marketing or niche marketing, they can use market research. Most products are only likely to be mainly purchased by particular groups of customers: the market of young working-class males, for example, is very different to that of middle aged wealthy couples. Market research can assist a firm in identifying which parts of the market are most likely to buy its products. It is vital for a business to know who its customers are. This allows the business to: * Design products to best meet the needs of these customers This makes it more efficient at what it does as it specifically meets the needs of IKEAs customers, meaning its something which grabs there attention, or they can relate to and want to purchase. * Target advertising, promotions and special offers at these groups People like a bargain, once they see a discount on a product they are looking for they are likely to purchase it from IKEA. * Conduct further in-depth research with specific groups of customers to uncover their needs as fully as possible. 5) Businesses need to know whats happening in the market. To be able to plan its product and marketing effectively, a business like Ikea needs to address three important questions. What is the size of the market? A way of measuring the size of the market is to consider the volume of sales made by all businesses selling furniture. What is the structure of the market? This means discovering the number and size of businesses that make up a market. Are there, for example a few large firms, or many small firms? Or a mixture of large and small firms? If a business is in competition with large firms, it may decide to avoid competing on price terms as larger firms may be able to produce their products more cheaply. Is the market growing or shrinking? Market research can reveal what is happening to sales in market over a period of time. A business may feel more confident about entering a market which is growing, as it should be easier to win sales when some customers are not yet loyal to particular brands or manufactures. The market for DIY furniture has kept growing recently mainly due to Ikeas success. If IKEA are planning on releasing a new product, its likely they will do research into other products in a similar field to see whether the market for them specific products are increasing or decreasing. This will give them a good idea whether it is worth a full-scale launch of the product they have in mind. 9) Total Quality Control is the most necessary inspection control of all in cases where, despite statistical quality control techniques or quality improvements implemented, sales decrease.The major problem which leads to a decrease in sales was that the specifications did not include the most important factor, What the customer required. To maintain their quality and standards is vital to IKEA, the quality and reliability and workmanship of their products is crucial to there brand. Both to keep their customers and to be legally correct. * Marketing had to carry out their work properly and define the customers specifications. * Management had to confirm all operators are equal to the work imposed on them and holidays, celebrations and disputes did not affect any of the quality levels. * Inspections and tests were carried out, and all components and materials, bought in or otherwise, conformed to the specifications, and the measuring equipment was accurate, this is the responsibility of the QA/QC department. * Any complaints received from the customers were timorously and satisfactorily dealt with. This will help keep IKEA a favourites with the customers. To conclude, the above forms the basis from which the philosophy of Quality Assurance has evolved, and the achievement of quality or the fitness-for-purpose is Quality Awareness throughout the company. IKEA hire highly trained quality control workmen, to check that the products in the warehouse are looked after sensiblely and that they are delivered to the customer effeciantly. Quality control is to check that there product meets customer demands and possibly look for ways to improve it. Its important for a business like IKEA to have regulary quality control checks to make sure that the products they sell are always up to standards, making sure the high IKEA standards dont drop without them being aware. To make sure of this IKEA have a test lab in Almhult which tests both textiles and furniture, around 50,000 tests are carried out in accordance with current standards each year. For several years in succession the IKEA Test Lab has been accredited for it quality system and test methods in accordance with the international standards. All these tests have been developed to correspond to many years of regular use in a domestic enviroment in the areas for which the product is intended. IKEA not only test products during development, but also selects random samples from among the products on sale in the stores. As IKEA say It is our customers that we want to come back not our products This makes sure that IKEAs customers get there full value for money and a long lasting product.

Getting it Right for Every Child (GIRFEC) policy

Getting it Right for Every Child (GIRFEC) policy Social Work as a profession is heavily influenced by political rhetoric and ideology albeit there has been a shift in governmental philosophy from the beginnings of the profession. Due to Neo-Liberal ideas commonly adopted by the main political parties in the United Kingdom, social work services are beginning to be based on free market principles. Social work and social care services have seen an increase in privatised quasi markets. The role of the social worker in all of this is one that can be contested and is certainly not static; it is a profession that I believe should attempt to be diverse and fluid. The aim of this essay is, to discuss too what extent there is a social work role beyond ‘the rationing of scarce services and managing of poor people’ (Ferguson and Lavalette 2013:108) This will be achieved by looking the Getting it Right for Every Child (GIRFEC) policy and what it means for social workers in a statutory children’s and families team before draw ing a conclusion. I intend to highlight the importance of early intervention as laid out in GIRFEC and what this means for social workers. GIRFEC also emphasises the importance of joint up working and I intend to highlight some of the failings of this and the tensions this creates for social workers on the front line. Finally, I will look at how GIRFEC is being put into practice by drawing on research from the Institute of Research and Innovation in Social Services (IRISS); Changing how we work: a case study in East Lothian. Firstly, however it is important to briefly explore the beginnings of policy implementation and how todays austerity measures effect policy being put into practice. Social work services go back over one hundred and fifty years but it was during the late 1960s that it became apparent that a framework of legislation was needed. This resulted in the Social Work (Scotland) Act 1968. The Kilbrandon report 1964 was a major driver in this act along with the white paper Social Work and the Community 1966. The Kilbrandon report called for the introduction of children’s hearings and ‘introduced a new way of dealing with what were described as children who were in need of compulsory care’. (Fabb and Guthrie 2007:150) Smith and White (2008:21) add that ‘the thinking of the Kilbrandon Committee was strongly educational, reflecting longstanding views that social wellbeing and social cohesion through education should be the ambition of the system.’ The Kilbrandon report is still one of the most significant policies in relation to social work practice. Ferguson and Lavalette (2013) highlight how austerity measures and welfare reform mixed with the marketization of social work services is impacting on the social work task. Neoliberalism is an ideology now adopted by the main political parties in the United Kingdom and is a take on classic liberal beliefs such as ‘free trade and the free market’ (Hoffman and Graham 2009:) Neo-liberal theorists believe that the role of welfare should not lie with the state and they ‘question the need for the majority of publically funded, state delivered, or state regulated institutions that, taken together, comprise a welfare state.’ (Ellison 2012:) This can be seen in society today in many ways, for example, with the introduction of universal credit and benefit capping both making an attempt to reduce welfare costs. This could also explain the ever growing involvement and use of the voluntary or third sector in social work services. GIRFEC: The aims of the policy GIRFEC was introduced by the Scottish Government in 2008 in an attempt to improve the way in which work is undertaken by professionals working with children and their families. The policy was developed after a string of recommendations and reports surrounding child protection, one of which being It’s everyone’s job to make sure I’m alright Report of the Child Protection Audit and Review(2002: 1) which highlighted the importance of ‘a Scotland in which every child matters’. Another significant report was my turn to talk? (Scottish Executive 2006:), which highlighted that ‘child-related professionals and decision makers across Scotland have both moral and legal obligations to encourage and support children’s participation.’ I believe that this push for child participation will in turn promote active citizenship for children. From these reports and others it was clear that new policy guidance was necessary and so GIRFEC was adopted. GIRFEC aims to co-ordinate the services’ children receive as well as managing the consistency in the delivery of these services. The Scottish Governments guide to getting it right for every child (2012:6) states that ‘it is the bedrock for all children’s services’. Putting the child at the centre of the services they receive is high on the agenda throughout and the policy puts a high emphasis on multi-agency working and the importance of early intervention. The policy was created in respect to ten core components and has a strong set of values that were developed from the Children’s Charter 2004 which ‘reflects the voice of children and young people and what they feel they need, and should be able to expect, when they have problems or are in difficulty and need to be protected.’ (Scottish Government 2004) The wellbeing wheel, my world triangle and resilience matrix, together known as the National practice model, are assessment tools used within GIRFEC to effectively manage and analyse the information required for a child’s plan. The wellbeing wheel consists of eight indicators of wellbeing that ‘are the basic requirements for all children and young people to grow and develop’ (Scottish Government 2012:10). These are: Safe, Healthy, Achieving, Nurtured, Active, Respected, Responsible and Included. (SHANARRI). Deep rooted in this, is the four competences from the Curriculum of Excellence: a successful learner, a confident individual, a responsible citizen and an effective contributor. I consider the combination of well-being and the curriculum for excellence to be a strong indicator for the push for multi-agency work that is evident throughout the policy. GIRFEC: A drive for early intervention and multi-agency working and the tensions these bring. Early intervention is one of the key themes running throughout the policy. The Changing Lives Report of the 21st Century Social Worker Review illustrates a four tiered approach to early intervention, incorporating the social workers role. (Scottish Government 2006:31). It stresses how social workers are involved in the early stages of intervention and how as crisis situations develop, other universal services step back. I wonder how involved we really are at tiers 1 and 2 and believe this will vary between local authorities. The Scottish Government(2006:31) state that, ‘social workers have a significant contribution to make at tiers 1 and 2, supporting and informing the delivery of services both within social work and across partner agencies.’ However, McGhee and Waterhouse (2011:1097) contradict this by arguing that: ‘for social work, early intervention has taken on a different meaning from that at tiers 1 and 2 †¦ early intervention begins at tier 3 and concerns individuals who already present significant vulnerability and risk and who are beyond the remit and capacity of universal services.’ This points out that early intervention may frequently be the responsibility of health professionals and education. However, early intervention at tiers 1 and 2 is perhaps what social work should be about it with its professional values pushing towards social justice. The Highland ‘s children services practice guidance (2013:11) ‘emphasises the critical part played by health and education services in supporting the development of all children. Difficulties or concerns are identified at an early stage and steps taken to ensure that additional help is available when needed. Help is given as quickly as possible and in consultation with children and their families.’ This backs up what McGhee and Waterhouse argue early intervention is like for social workers; their idea that social workers are not involved at tier 1 and 2. Another Key theme to shape GIRFEC is that of the importance of multi-agency working. Although GIRFEC calls for a push towards a better system of multi-agency working it is not something that is new to the literature. (Wilson et al 2011) Multi-agency became high on the political agenda after the death of Victoria Climbie who ‘was slowly tortured to death despite the involvement of four social service departments, three police child protection teams, health agencies and voluntary agencies.’ (Marinetto 2011:1164) An inquiry into Victoria’s death highlighted the breakdown between professional organisations and called for better co-ordination between services and organisations. With the importance of professionals working together and sharing information stressed here it is no wonder that it is such a key feature in policy documents. The principle behind multi-agency working sounds simple; ‘professionals with different backgrounds, from different intellectual dis ciplines and with different roles work together to provide care and support to service users and people around them.’ (Payne 2007:146) However, for social workers there are tensions to be considered. Atkinson et al (2005) looks at research carried out into multi-agency working and highlights eight challenges; fiscal resources, roles and responsibilities, competing priorities, non-fiscal resources, communication, professional and agency cultures, management and training opportunities. Some of the problems identified within these areas were that there was no financial support and many workers did not know what was being asked of their individual role between them and the rest of the multi-agency team. There were often different primacies amongst the different professions leading to conflict. As a social worker it is imperative that I aim to overcome these tensions and difficulties. In regards to GIRFEC, I expect that the introduction of the named person will help coordinate the multi-agency approach although lack of funding and resources is something that is always going to be a threat to the smooth running of a statu tory children and families team attempting to work alongside other professionals under the GIRFEC framework. The Audit Commission (2009:3) states that ‘Effective joint workingneeds active leadership and purposeful relationship management.’ The report highlights how working together in multi-agency teams is not without risk and that difficulties can arise if the agencies have not developed effective relationships. Strong leadership seems to be a key theme throughout the literature. The Scottish Government (2010) states that ‘Partnership working requires leadership at all levels and across services. In order to make partnership working effective, leadership needs to be the responsibility of everyone.’ If this is adopted and everyone is clear on what their roles and responsibilities are it should enable an effective way of working. How can we implement GIRFEC into practice? In October 2012, IRISS worked alongside East Lothian Council to enable them to implement GIRFEC. The sub group working together involved social workers, police, child protection, the third sector, education and health. Collins (2013:) states that she had ‘initially conceptualised this project as a means to help an organisation reflect on and improve their use of evidence, however, as the project progressed it became evident that the lessons really centred around how a multi-disciplinary team can learn to work together well and change the way they work.’ So here we have a positive example promoting the practice of multi-agency working, however, arriving at this conclusion was not easy. The study points out that in the beginnings people were reluctant to the prospect of the group – ‘We don’t even have the same beliefs.’ (Collins 2013:5) The next problem to address was that when it came down to it, people didn’t fully understand the best way to comprehend GIRFEC- ‘The problem is interpretation of GIRFEC. Some people are putting ‘safe’ at the top of the pyramid. But safe is not the only thing. It doesn’t have to be the most important.’ (Collins 2013:7) These difficulties are only to name a few, but as the group moved onward planning strategies were implemented, based comprehensively on reflection which the group named ‘the action research cycle’ (Collins 2013:16), with successful results. Conclusion Going back to Ferguson and Lavalettes quote, it would be ethically undermining to say that social work is about rationing limited resources and welfare management and that the GIRFEC policy aims to tackle every aspect of a child’s well-being with a multi-agency approach. Although as previously highlighted, the importance of multi-agency working is not new to the literature, within GIRFEC there is a drive for a more effective method in which universal services can work together in partnership with a thrust towards early intervention, although it may be argued that social workers are being locked of this. To an extent, I agree with this and believe that austerity measures are influencing this and together with welfare reforms and an ever growing number of families living in poverty then at present social workers roles may be changing but I am uncertain at present as to say to what extent. What I am certain of is that the service users within a statutory children’s and fam ilies team will be effected whether it be through the ever increasing cost of living and proportion of them relying on low income wages or through local authorities having to cut funding to specialised services and protects.

Gender Differences in Multitasking: Texting During Lectures

Gender Differences in Multitasking: Texting During Lectures Today, the communication technology has been growing widely to the extent that we can communicate with each other anytime and anywhere. As long as there is Wi-Fi or network coverage, our smartphones, tablets or computers can be used as a communication tool or a gadgets for us to receive new information in the world. Consequently, this function is so easily accessed by all, we are able to receive text messages, phone calls, emails and social network notifications throughout the whole day. However, this can be either a blessing or a curse. As we are exposed to all these information and entertainments, these can be a distraction in our daily tasks. To be specific, students in college are able to access to all these functions most of the time, it has pushed students to multitask more often in their daily lives. These might interfere with their studies as multitasking involves in switching tasks from one and another as well as the attention (Judd, 2013). In a study done by Wilkes University, 95% of the students bring their phones to college every day and 91% of the students admitted to using their cellphones during lectures (Harris, 2013). This has shown that most students tend to multitask in class as they listen to the lecture and use their phone at the same time for either text messaging, social networking or any other purposes. However, research on multitasking have proven that the human has no ability to perform more than one overlapping task at the same time due to the interference occurs in human information processing system (Levy Paschler, 2001; Wood et al., 2012). In other words, students can hardly concentrate in class if they are using their phone at the same moment. This explanation is consistent to the findings of Bowman, Levine, Waite Gendron (2010) that students who instant message while reading take longer time to finish the task. For generations, the stereotype of women are better at multitasking is debated across the world. Although scientist in University of Pennsylvania has supported this statement by discovering females’ brains are connected from left to right, while men has more intense movement in certain part of the brain (Spencer, 2013), many research done on multitasking has rejected the idea. Buser and Peter (2011) reported that women suffer as much as men while multitasking and have no significant differences in productivity of tasks. Not only that, even Conner, Laws, O’Connor and Stoet (2013) found that women outperform men in multitasking, they pointed out that their results cannot be generalized as the empirical studies on gender differences in multitasking is insufficient. Theoretical Framework Living in this world where we are overwhelmed by all perceptual information, our human information processing system can detect, recognize and identify chunks of stimuli at the same time (Hedge, 2013). As so, in this context, attention has given the model a function to either enhance or inhibit information, in other words, our attention chooses which certain information for further processing or ignore (McClelland, 2007). However, when two information are presented and are asked to process at the same time, the ability to attend both fully will be impaired as there are insufficient capacities in the information processing system; this attempt of trying to focus on multiple stimuli at one time is also known as divided attention (McClelland, 2007). One of the example of divided attention is multitasking, which can be defined as performing more than one task simultaneously or switching from one task to another back and forth (APA, 2006). In the human mind, multitasking is managed by a process called executive control; and to decide which cognitive processes and when it is performed, the executive control system will go through two stages – the goal shifting (decision of what to do) and role activation (action of switching task) (Meyer, Evans Rubinstein, 2001). Hence, people tend to repeatedly switch between tasks to achieve two things at a time without constant awareness; although it might seems productive and efficient, it is explained that multitasking leads to more mistakes and more time consumed as there will be brief mental blocks during switching of tasks (Meyer, Evans Rubinstein, 2001). Past Research Many past research have shown that multitasking in class can lead to poor academic performance. Junco (2012) conducted a research examining the relationship between in-class multitasking and academic performance, by giving out survey forms to a large number of students (N = 1,839) measuring their technology usage in class and internet skill to be compared to their grade point average (GPA). He then reported that constant multitasking in class (which include surfing social networking website, chatting and text messaging) has a significant negative correlation with students’ over semester GPA (Junco, 2012). Additionally, Carrier, Cheevar, Lim and Rosen (2011) did an experimental study on the frequency of text messaging interruption during a lecture has found that students in High texting group (16 messages or more) scored significantly lower than the Moderate texting group (8 to 15 messages) and No or Low texting group (0 to 7 messages) in the quiz after a 30 minute videotaped l ecture. Through the cross-cultural analysis of surveys results on mobile phone etiquette and multitasking in class, it showed that Americans and Chinese students both believe using cellphone in class will not interfere their learning but Americans students find it more appropriate to text in class than the Chinese; additionally, no gender significant difference is found (Rosenfeld, 2014). Many other research have furthered this study by doing an experimental study on multitasking in class with the awareness of cellphone distraction. Even many students did not believe that using their smartphones in class is a distraction from their learning, the scores of the short quiz given after the same lecture between students who use cellphones in class and students who listen to lecture without cellphones have a significant difference where students who anticipate in communication technology have a lower score (Elder, 2013). This result is consistent to the findings of a mixed experimental study on th e relationship between self-regulation, attention and cognition learning ability in classroom learning, which reported that college students who constantly self-regulate tend to have a better cognition learning by sustaining their attention during lecture as they text less (Klausner, Wei Wang, 2012). Besides, during an accounting principle lecture in Columbus State University, the half of 62 students who are allowed to multitask in class in the form of communicating with each other through texting did worse in the exam than the other half of students who are not allowed to use their cellphones during lecture (Ellis, Daniels Jauregui, 2010). Although in this study they did a comparison between male and female, they found that gender has no significant impact on learning ability without taking account of whether they multitask or not (Ellis, Daniels Jauregui, 2010). This research is similar to a recent experimental study which both groups of psychology students, who are asked to text and to switch off their phones during a short 20-minute lecture, are then given a short quiz to test their learning ability; the researchers concluded that texting in class is a strong distraction during lecture like other past research, but no gender comparison is done (Dietz Henrich, 2014). Howeve r, in the research of gender difference on multitasking have shown that women suffer as much as men in divided attention while completing multiple task at the same time and choose to avoid multitasking upon free will (Buser Peter, 2011; Strayer, Ward Watson, 2013). Description of Study Although many research has done on student multitasking capabilities in class (Carrier, Cheever, Lim Rosen, 2011; Ellis, Daniels Jauregui, 2010; Gingerich Lineweaver, 2013) and gender differences in multitasking (Buser Peter, 2011; Conner, Laws, O’Connor Stoet, 2013), there are limited research that compared male and female students’ academic performance if they multitask in class. In this study, we will be examining the gender difference in multitasking during a lecture. The aim of this experimental study is to see whether male or female students can multitask better while learning. All participants recruited for the study will be separated to different groups based on gender and will undergo one experiment each, either texting during lecture or no texting during lecture. As all participants will have to attend a half an hour English Literature class, the no texting group will not be allowed to access to their cellphone. However, for the texting group, each participant will receive a text message every 5 minutes and is required to reply. At the end of the experiments, all four groups of participants will be given a quiz to test their understanding of the lecture. Based on Carpenter et al. (2012) and Ellis, Daniels and Jauregui (2010), we hypothesize that texting in class will lead to a poorer performance in the quiz. Then, based on Buser and Peter (2011) and Strayer, Ward and Watson (2013) on gender differences in multitasking, we hypothesize that there will be no differences in both gender on performance in quiz for texting during lecture. Method Design The independent variable of this study is gender differences in multitasking, with two levels, male and female; the dependent variable is quiz scores. This is a between subject design as the participants will be separated to different groups and only go through one experiment either texting during lecture or no texting during lecture. Participants Approximately 80 male participants and 80 female participants, from all races, will be recruited from different private colleges in Penang for the experiment. This is because all the past research used participants less than this amount. A total of 62 participants of both gender are tested on the study by Ellis, Daniels and Jauregui (2010); and a total of 67 participants are used in the study of Gingerich and Lineweaver (2013). The age of the participants will be 18 to 25 (M = 21.25), which most people in this age attend college. The participants are recruited through purposive sampling where they have to meet the 2 following criteria, enrolling in an undergraduate program and is able to understand English perfectly. The students will be participating the experiment voluntarily. Materials A half an hour lecture of English Literature Studies will be given to all participants. As the participants recruited are from variety of courses, this is to ensure that the students have not been to the lecture before and have no prior knowledge in it. At the end of the experiment, a 20 multiple choice question quiz based on the lecture will be given to the participants to answer. As for the treatment group, a total of 6 text messages will be send to the participants which consists of basic conversation questions, such as â€Å"What is your hobby?† Procedure This experimental study will be done in a big lecturer hall with a clear projector screen and perfect sound system. Before the experiment is conducted, all the participants will be asked to sign the inform consent form. After that, they will be divided into four groups, the male control group, the female control group, the male texting group and the female texting group. The students will be told whether or not they are receiving text messages. For all four groups of experiment (the female control group, the male control group, the female texting group and the male texting group), the lecturer and the English Literature lectures given will be same. However, on the treatment group for both genders, each participant will receive a text message every 5 minutes and they are required to reply the message before the next message comes. After the 30 minutes lecture is finished, all participants will be asked to take a short multiple choice questions quiz based on the class conducted. Once the students have finished the quiz, they are allowed to leave. Statistical Analysis As this experimental study only consist of one independent variable and one dependent variable, the data will be analyzed using SPSS with independent one-way ANOVA; and to see if there is significant differences between two means of independent groups. History: The Act Of God Defence History: The Act Of God Defence The Law of Tort is a developing and ever dynamic field and is a conception evolving through centuries. This field is used with principles under which tortuous liability can be demanded. Simultaneously, certain other principles are used, to oppose these claims for compensation. These counter claims, or defences are used to evict those innocent citizens from tortious liability who have been unfairly implicated with claims imposed on them. These defences were framed from time to time to keep up with the very basis of imposition of tortious liability on an individual- i.e, creating a sense of deterrence while keeping up with the basic values of justice. One such defence which will be discussed elaborately with cases subsequently is ACT OF GOD. MEANING Act of God means an event which happens independently of human action such as death from natural causes (Actus dei nemini facit injuriam), storm, earthquake, tides, volcanic eruptions etc., which no human foresight or skill could reasonably be expected to anticipate. For example, damage from a tornado or a lightning strike would be considered an act of God. Damage would not be considered an act of God if it is caused by the property owner. Vis is a Latin word meaning any kind of force, violence or disturbance to person or property. Vis major is an act of God. The doctrine states that a person is absolved of liability if it was directly caused by vis major. LEGAL DEFINITION Act of God was first judicially defined in Tennet v. Earl of Glosgow Lord Westbury, was first recognised by Blackburn J. in Rylands v. Fletcher and was first applied in Nichols v. Marsland and many other cases. Blacks Law Dictionary defines an act of God as An act occasioned exclusively by violence of nature without the interference of any human agency. A natural necessity proceeding from physical causes alone without the intervention of man. It is an accident which could not have been occasioned by human agency but proceeded from physical causes alone. Vis major is similarly defined, as A greater or superior force; an irresistible force. A loss that results immediately from a natural cause without the intervention of man, and could not have been prevented by the exercise of prudence, diligence, and care. According to Salmond act of God includes those acts which a man cannot avoid even by taking reasonable care. Such accidents are are the result of natural forces and are incoherent with the agency of man. Thus it is an act which is due to natural causes directly and exclusively without human intervention, and that it could not have been prevented by any amount of foresight and pains and care reasonably to have been expected from him i.e. the defendant . Accor ding to Lord Mansfield, it is something in opposition to the act of man. Conclusion: It has been said that it would be probably never be capable of complete, exact unassailable definition. But it has also been said that this untheological expression is well understood by lawyers. It is such a direct, violent , sudden act of nature that no man could forsee and if he can, he cant prevent it. ELEMENTS NATURAL CAUSES An act of God is an uncommon, extraordinary and unforeseen manifestation of the forces of nature, or a misfortune or accident arising from inevitable necessity. An act of god cannot be prevented by reasonable human foresight and care. The effect of ordinary natural causes may be foreseen and avoided by the exercise of human care. For example, the fact that rain will leak through a defective roof is foreseeable. In case of foreseeable causes, failure to take the necessary precautions constitutes negligence, and the party injured in the accident may be entitled to damages. An act of God, however, is so extraordinary and devoid of human agency that reasonable care would not avoid the consequences. Therefore in such cases the injured party has no right to damages. Acts of god are generally attributable to forces of nature. They are generally in the nature of accidents caused by tornadoes, perils of the sea, extraordinary floods, and severe ice storms. Snowstorms of great violence have been held to be acts of God. Whether freezes are acts of God depend on the locality and season of the year in which they occur, i.e., their foreseeability is affected to a greater extent than other natural occurrences by these factors. Catastrophic earthquakes and volcanic eruptions should be defined as acts of God since they measure up to the accepted definitions of act of God in every respect. However, fires are generally not considered acts of god unless they are caused by lightning. Whether or not a particular natural event warrants such an adjective is a function of such things as the intensity of the event, characteristics of the area, and climatic history. UNUSUAL VIOLENCE- BOTH SUDDEN AND IRRESISTIBLE AN OCCURRENCE NOT REASONABLY FORSEEABLE The basic and prime element of an act of god is the happening of an unforeseeable event. For this, if the harm or loss was caused by a foreseeable accident that could have been prevented, the party who suffered the injury has the right to compensation. However, the damage caused by an unforeseen and uncontrollable natural event is not compensable as it could not have been prevented or avoided by foresight or prudence of man. Moreover, courts are of the opinion that the act of God defence exists only if the event is so exceptional and could not have been anticipated or expected by the long history of climate variations in the locality. It is constructed by only the memory of man i.e. recorded history. The courts may even demand expert testimonies to prove that an event was unforeseeable. IMPOSSIBLE TO PREVENT BY ANY REASONABLE PRECAUTIONS AND ABSENCE OF HUMAN AGENCY CAUSING THE ALLEGED DAMAGE It means practically impossible to resist. Negligence constitutes failure to take the necessary precautions. In an incident where a human factor was present, even though the harm could not be prevented, the fact that the human factor exercised reasonable care and precautions to prevent the harm has to be proved if the defence of act of God has to prevail. If negligence is alleged and proved, the defence of act of God will fail. If a home owner was negligent in properly maintaining a tree that fell on a passerby, he cannot be exempted from liability by act of God principle. In Clark v. Multnomah, the Court made a decision that the flooding of a house was not an act of God where it was caused by the breakage of a pipe fitting in the house. The cause of harm was evidenced by the fact that a repairman had worked with the part that broke just hours earlier. ESSENTIALS There must be operation of natural forces like exceptional rainfall, storms, tempests etc. without any human intervention. The incident must be extraordinary and not which could be anticipated and reasonably be guarded. ORIGIN HISTORICAL EVOLUTION The term act of God occurs and is described in holy texts dating back to the 13th century, specifically referring to acts that God has undertaken. The act of God referred is that which is used in legal and insurance circles when discussing any act which is outside human control and governance and therefore not the responsibility of any individual or corporation. The term was first used in this way in the mid-19th century. Peter Simmonds Dictionary of Trade Products, 1858, uses the term: Force-majeure, a French commercial term for unavoidable accidents in the transport of goods, from superior force, the act of God, etc. In July 1803, The Times included this legal ruling given in a court case by Lord Ellenborough, which is in terms that we are now familiar with from our own household insurance policies: By Common Law, Carriers are insurers against every loss of property entrusted to their care, except losses arising from the Act of God, or the Kings enemies. Earthquakes, floods, hurricanes, tornadoes, wildfires, drought and a deadly tsunami are a long series of natural calamities of seemingly large proportions have been witnessed by us . Lives are lost, properties destroyed , and emotions shattered when these forces of nature tragically strike. The natures blow may be so intense that it may come as a total shock and baffle both to the direct victims of the disaster and, subsequently, to the accused tortfeasors Defendants are quick to claim act of God as a defence to these lawsuits. For three centuries, the act of God defence has been accepted in negligence and strict liability cases. Act of God, as a legal concept shows up not only as a defence, but also in discussions of duty and causation. At first glance, the act of God defence seems a simple, direct concept with few gradations or intricacies. Consequently, all too often, many lawyers have misused the phrase act of God to mean any unfortunate act of nature. In a sixteenth century opin ion, in the Shellys Case best known for the famous property law doctrine, the court wrote in terms of performance becoming impossible by an act of God, which was the death of one of the parties. In an attempt to give life to this notion of fairness, the courts in Shelleys Case and other early decisions drew lines between those acts which were natural and those which were caused by man, so as to forgive man for those acts that were beyond his anticipation or control. The court stated: It would be unreasonable that those things which are inevitable by the Act of God, which no industry can avoid, nor policy prevent should be construed to the prejudice of any person in whom there was no laches. No further explanation of the phrase, Act of God, was provided by the court. The phrase again appeared in the 1702 case of Coggs v. Bernard, which invoked liability for a bailment by a common carrier. Justice Powell opined that a bailee shall answer accidents, as if the goods were stolen; but not such accidents and casualties as happen by the act of God, as fire, tempest for the bailee is not bound, upon any undertaking against the act of God. The act of God defence expanded from common carriers into other areas of strict liability. The Courts then extended the act of God defence to cases of negligence. The act of God defence received prominence in decisions construing the common-law liability of common carriers who were treated as insurers of the goods they carried. In 1785, Lord Mansfield delivered a unanimous opinion in Forwardv. Pittard which involved an accidental fire for which the carrier was in no way at fault. The court clearly established a rule of strict liability for common carriers: It appears from all the cases for 100 years back, that there are events for which the carrier is liable independent of his contract. Again, in Forward, the English courts limited the act of God defence by excluding acts of man. In addition, the burden of proof was shifted from the plaintiff to the defendant to establish the existence of the act of God defence. Although the courts subsequently split on the liability issue for common carriers whose delay subjected its freight to damage from an act of God, there was a consensus that liability would result if the common carriers knew that the force of nature was coming. CASE LAW: In Nichols v. Marsland(1875)( Discussed in judicial cases section) APPLICATION Act of God is often a difficult defence to establish. It requires both the exclusion of human agency and unforeseeability to establish an act of God. For an event to be a legal act of God, the natural event must have been the sole and immediate cause of the injury, with no co-operation of man, or any admixture of human means. Generally speaking, then, the vis major defence can apply to a case involving damage or harm by a natural force, but only in circumstances in which that force is strong enough to overcome and nullify any potential contributory cause by a human agency. The issue is whether the magnitude of force is reasonably foreseeable such that a defendant should have taken precautions to avoid personal injury or property damage resulting from it. For example, a 55-mile-per-hour wind gust, though rare, is reasonably foreseeable in Wisconsin. However, a 200-mile-per-hour tornadic wind is probably not; the vis major defence would apply to personal injury or property damage caused by such a force, even if a human agency (for example, a product such as a window or door) was involved. With respect to rain: An hourly rainfall of three inches, while heavy, is not unforeseeable in Wisconsin; an eight-inch hourly rainfall probably is. A basement collapse would probably implicate the vis major defence in favour of a basement contractor in the latter circumstance but not in the former circumstance. When property damage or personal injury is caused in part by a natural force and in part by a human instrumentality, the plaintiff should argue that the natural force was foreseeable and should have been anticipated in a manner that would have avoided the damage. The defendant then has the burden to establish that the natural-force component of the cause was so huge and so monumental that it was not reasonably foreseeable. The point is that the occurrence of natural phenomenon need not be unique, nor need it be one that happens for the first time; it is enough that it is extraordinary or exceptional and so as it could not be reasonably anticipated and also it must be free from human conduct. The word vis major imports something abnormal and with reference to the context means that the property by the act of God has been rendered useless, for the time being i.e. it was rendered incapable of any enjoyment. Vis Major to afford a defence must be the immediate cause, the causa causans, and not merely a causa sine qua non of the damage complained of. The mere fact that vis major co-existed or followed on the negligence is no adequate defence. Before an act of God may be admitted as an excuse the defendant must himself have done all he is bound to do. The legal maxim Actus dei nemini facit injuriam means the Law holds no man responsible for the act of God. The important thing in regard to vis major is not the positive intervention of natural forces but a process of nature not due to the act of man and it is this negative side which deserves emphasis. It is thus a negation of liability. Complete exclusion of human cause is a difficult standard for a defendant to overcome, which likely explains why the defence is not commonly argued or upheld. As a result, modern courts sometimes characterize acts of God as unavoidable accidents because, although the terms often are synonymous, unavoidable accidents need not be free from human agency. ACT OF GOD AND INEVITABLE ACCIDENT DISTINGUISHED Every act of God is an inevitable accident but not vice versa. An Act of God is discrete and distinct from inevitable accident. In order that an accident may be an act of God it must have followed directly from natural causes without human intervention. In Nugent v. Smith, Cockburn, C.J. said All causes of inevitable accident, casus fortuitous meaning an uncontrollable accident, may be divided into two classes: Those which are occurred by elementary forces of nature not connected with the agency of man or other cause [Act of God] Those which arises either wholly or in part by agency of man. [Inevitable Accident] Example- 1. If a ship is pushed ashore by a violent storm, this is the Act of God; but if it is run ashore during a fog by mistake, however unavoidable on the part of captain, this is the act of man. If a building is set on fire by lightning, this is an act of God; but not so if it is done by human through falling of a lamp even though this was due to no negligence. INEVITABLE ACCIDENT ACT OF GOD Could not be prevented by the exercise of ordinary care, caution and skill A direct violent, sudden and irresistible act of nature as could not, by any amount of human care and skill have been resisted is Act of God. May be controlled by human beings 2. Not controlled by human beings. 3. Strict liability can be imposed on the tortious liability occurred due to inevitable accidents 3. Even strict liability can also not be Imposed in cases of torts arising out of acts of Gods 4. The courts have discretionary power in determining the defendants tortuous liability 4. No discretionary power Conclusion : The defence of inevitable accident is a more general defence and is distinct from the act of God in so far as it is dependent on human agency and not on natural forces and in the degree of unexpectability. ACT OF GOD NEGLIGENCE Negligence, in law, especially tort law, is the breach of an obligation (duty) to act with care, or the failure to act as a reasonable and prudent person would under similar circumstances. Both these defences (act of God Negligence) are based on reasonable foreseeability. In terms of foreseeability, the question is not whether a similar event has occurred before, but whether the risk that this particular mishap may occur is foreseeable. Thus, a flood, earthquake, hurricane, or other natural force need not have previously struck a particular location for negligence to exist. Liability may still exist if reasonable design, construction, operation, inspection, or maintenance. For a plaintiff to recover damages, this action or failure must be the proximate cause of an injury, and actual loss must occur. In cases of joint causation, where both human negligence and act of God have a role to play, the traditional sine qua non (but for), substantial factor, or legal causation tests apply. If the act of God is so overwhelming that its own force produces the injury independent of the defendants negligence, then the defendant will not be liable. If the damages suffered are incurred solely due to natural causes without any known fault, there is no liability because of the act of God. There are two ways of viewing this situation. The act of God either supersedes the defendants negligence, or the defendants negligent act is not a cause in fact of the injury. In either case, the defendants act did not cause the damage since the injury would have occurred anyway. The party injured in the accident may be entitled to damages. An act of God, however, is so extraordinary and devoid of human agency that reasonable care would not avoid the consequences; hence, the injured party has no right to damages. Accidents caused by tornadoes, perils of the sea, extraordinary floods, and severe ice storms are usually considered acts of God, but fires are not so considered unless they are caused by lightning. JUDICIAL CASES Nichols v. Marsland  [1]   In this case, The defendant had constructed certain artificial lakes on her land by damming up a natural stream at appoint higher up than the defendants land. An extraordinary rainfall, greater and more violent than any within the memory of witnesses, caused the stream and lakes to swell to such an extent that the artificial banks burst and the escaping water rushed on to the plaintiffs land and carried away four county bridges. Nichols, the plaintiff brought an action for damages on the plea that the defendant was liable under the rule in Rylands v. Fletcher  [2]  . HELD: The contention was rejected and the defendant was held not liable. The Court of Exchequer Chamber held that she ought not to be liable for an extraordinary act of nature which she could not reasonably foresee. It was said that one is only bound to provide against the ordinary operations of nature, but not against her miracles. Greenock Corpn. V. Caledonian Railway Co.  [3]   The facts were that the corporation in laying out a park constructed a pool for children in the bed of a stream and there altere its course and obstructed its natural flow. Owing to rainfall of extraordinary intensity, the stream overflowed at the pond and great volume of water poured down a streetand flooded down the property of a railway company. HELD: It was held that this was not damnum fatale and the Corp. was liable. Nichols case was distinguished on the ground that in that case it was the storing of water in a reservoir and not with interference with the course of natural stream and that anyone who does interfere with it must provide against even an extraordinary rainfall. State of Mysore v. Ramachandra  [4]   In this case, the State had constructed a reservoir for the supply of drinking water for the villagers of Nipani. But the construction was not completed and the over-flow channel linked with reservoir was partially constructed. Land and crops were damaged due to flow of water resulted from rain. The plaintiff filed the suit for damages. HELD: The State resisted the suit that it was the act of God. But, the court rejected the defence and observed Assuming an act of God such as flood wholly unprecedented, the damage in such a case results not from the act of man in that he failed to provide a channel sufficient to meet the contingency of the act of God. But for the act of man there would have been no damage from the act of God. T. Gajayalakshmi v. Secretary, PWD, Govt. of T.N.  [5]   The deceased, a cyclist, who was going on his way was electrocuted by the falling of an overhead electric wire. HELD: The court rejected the contention of Electricity board that it was an unexpected event due to rain and wind and that the snapping of the electric wire was an act of God. It also rejected the plea that the death took place due to the negligence of the deceased in his leaving the home that day in rain and wind. Mahindra Nath Mukherjee v. Mathuradas Chaturbhuj  [6]  . A cinema advertising board was placed on the roof of the defendant which fell down and injured the plaintiff. Plaintiff brought a suit against the defendant and contended that the board fell due to storm of unusual severity. But, it was observed that during the season of monsoon a storm of this magnitude is not uncommon. The defendant had not ensured or foresee that the fixing of banner on such a height is strong enough to face the pressure of storm during monsoon season. The Calcutta High Court held that such a storm cannot be said to be so unexpected that no human foresight could reasonably be expected to anticipate it and cannot be regarded as vis major or act of God. Hence, the suit was allowed and the defendant was found negligent. Before the act of God can be admitted the defendant could have taken reasonable care and done all that what he was bound to do. Kallulal v. Hemchand  [7]   The defendant constructed a building and it was collapsed and as a result of it, two sons of the plaintiff were dead. Before the day the building collapsed there was a heavy rain. The defendant pleaded the rain as an act of God HELD: The court observed that the Acts of God must be apparent on the face of the records. They must be known and affect largely to entire public. The defendant was held liable. The act of God or vis major can also be explained mathematically as follows: (i) Unprecedented + Unforeseen + Irresistible = Act of God (As it has been discussed in this Chapter in the cases Nichols v. Marsland; Mahindranath v. Mathura Dass) (ii) Unprecedented + Foreseen + Irresistible + Act of God (Nichols v. Marsland case) (iii) Precedented + Unforeseen + Irresistible = Act of God (Greenock Corporation case) (iv) Precedented + Foreseen + Irresistible = Act of God (Greenock Corporation and Mahindranath cases) EXAMINING ACT OF GOD PRESENT SITUATION Vis Major as a defence depends on two ; lack of predictability and lack of control. If either criteria is missing, the defence fails. Both were solidly based for centuries on the lack of scientific knowledge. Man not only lacked the ability to predict the forces of nature, but also the ability to guard against, control, or otherwise minimize their impacts. In the words of the ancient mime writer Publilius, it is vain to look for a defence against lightning. Today, foreseeability is based not only upon the past, but also upon that which modern technology and science allow us to project into the future. Science has advanced to the point where we can understand many forces of nature, such as precipitation and flooding. Historically, we know which areas have been subjected to specific forces of nature. Scientifically, we can predict the areas which may be subjected to such forces. At first glance, the act of God defence should continue to play a role in strict liability cases. Part of th e underlying purpose of the act of God doctrine was to ameliorate strict liability. In strict liability a number of exceptions have evolved. Whether a particular occurrence amounts to an Act of God is a question of fact, but the ambit of this defence is somewhat restricted. Increased knowledge seems to limit the unpredictable. Natural hazards are no longer a mystery to us. Hence, the applicability of the act of God defence has shrunk in inverse proportion to rapidly expanding concepts of foreseeability. Conversely, environmental changes at the global level have left some scope for Vis Major as a defence. Unforeseen disasters like the July 26, 2005 floods in Mumbai or the devastating Tsunami on 26 December 2004, which was the result of severe earthquake with its epicentre at Indonesia can still be attributed to acts of God. These disasters were completely unforeseen and any prior intimation about the same would not have helped bring the situation under control. Such natural catastrop he has left some scope for the use of Act of God as a defence. Flaws in The Common Laws Approach to The Act Of God Defence 1. The Problem of Increasing Event Foreseeability In terms of Event Foreseeability, there are two independent trends which suggest a strong possibility that climatic events which historically qualified as Acts of God may become increasingly foreseeable: improved meteorological techniques and the effects of climate change. It is undeniable that there is increased data available and increased forecasting powers inherent in the continuing development of meteorological science. This trend has two impacts on the foreseeability of such climatic events for purposes of the Act of God defence: (1) defendants can increasingly know that the hurricane or storm is coming with time to take some precautionary steps in response because they will be warned of it (so that it will be more difficult to say that the event was unexpected or unanticipated); and (2) climatic data of past storms will continue to accumulate (so as to support conclusions that the event is not unusual for the location at that time of year). In short, the climatic events which historically may have been considered Acts of God will be more foreseeable in the future and thus less likely to support the defence simply because we will know more and more about the weather. In short, as climatic change increases the frequency and intensity of hurricanes, heavy storms, and the flooding associated with such climatic events, it appears that it will be harder for defendants to claim that the events themselves or the consequences of those events were not foreseeable. Thus, the defence is likely to be diminished in its utility simply because it will be harder to satisfy the legal requirements relating to the Event Foreseeability necessary to invoke the defence 2. The Problem of Response Forseeability As the climatic events themselves become more foreseeable, Response Forseeability becomes more critical to the Act of God defence because the burden is on the defendant to show that it took reasonable precautions in light of the foreseeable risk. It is here that foreseeability in the context of the Act of God defence really breaks down because of the inability of the defendant to foresee what the adequate response is before the climatic event occurs. To illustrate the problem, consider a fact pattern taken from the Act of God case law: a warehouseman holding goods for a customer in a Gulf Coast state in which a hurricane could strike. Given that a significant climatic event (i.e. a hurricane in the Gulf) is foreseeable, the court will have to analyze whether the defendants actions were reasonable in light of the foreseeable risk. CONCLUSION Although the act of God defence that a defendant is insulated from liability for personal injury or property damages caused by a natural cause is rarely used, it may become more common and general in the future if predictions of disastrous weather events caused by global warming prove true. One prediction related to global warming is that catastrophic weather events such as hurricanes, tornados, and torrential rains will occur more often. All of these have the potential for causing extensive personal injury and property damage and consequently mental trauma. Therein lie the core for more frequent, common and general use of the vis major defence. Is it still viable? How might it apply as a defence to tort? The act of God defence is as common today as ever. Though, it is still not relied on very often, likely because of the difficulty of proving that human elements played no role in causing an injury. The potential application of vis major will expand if meteorological predictions concerning climate change through global warming come to accomplishment and realization. However, as these events become more common, the standard of what constitutes a reasonably foreseeable natural force will doubtless itself expand. This again would confine application of the vis major defence insofar as defendants become obligated to anticipate and account for effects of more extreme and dangerous natural phenomena, especially those associated with the weather. However, in the era of global climate change, courts can hardly pretend that causation can be determined to be natural or human. Storm patterns and frequencies are changing. Growing seasons are shifting. Glaciers are melting and seas rising. Global climate change will present courts with the kinds of difficult factual situations that make it impossible to pretend the old act of God divide should stand untouched. Even though a particular defendant in a given case may not have been demonstrably at fault, the act of God doctrine remains analytically flawed because it requires that nature be the sole cause of a phenomenon to the exclusion of all human action