Educational leadership Research Paper Example | Topics and Well Written Essays - 500 words

Educational leadership - Research Paper Example School Based Management (SBM) is a model of instructional leadership which sets out clear guidelines for decentralised school administration and is successfully introduced in several countries (Dr. Pushpanadham 2006 p.41). Decentralised educational planning requires organised participation to substantiate the efforts of educational reforms. Past entities that functioned towards decentralised education such as Parents Teachers Association, Village Planning Committees and School Development Committees did not have an organised plan or statutory recognition that clearly pointer out powers and responsibilities. Community participation is considered as the central facilitating criteria to ensure quality education that is par with the principal’s initiative, professionalism of teachers, organisational flexibility, teacher collegiality, accountability and pedagogical flexibility. Similarly the cycle of disempowerment prevalent in marginal communities can be broken only if there is a criteria for evaluating and monitoring school performance that includes accountability to local administration in the region. Research indicates that effective decentralisation of management depends on an effective leadership. In school management an effective principal must offer leadership in promulgating change in school policies and programs. An effective leader can successfully resolve disciplinary issues and advice and direct teachers to abide by policies that can create a positive impact on the performance of the school and institutional climate. There is also a positive correlation between teacher’s job satisfaction and school climate. School Based Model encourages principals, students, teachers and parents to exhibit more control over the educational policies by offering the responsibility to decide about the personnel, budget

Case study discussion Essay Example | Topics and Well Written Essays - 2750 words

Case study discussion - Essay Example In this regard, the assets, interests, and rights of the project are basically held as the secondary security or act as the collateral. Therefore, in any case the forecasted cash flow from the project does not sustain the project, there is high risk exposure to debt risks though the failure of the projects may be attributed to many factors like the interest rates, business risks, economic situation like inflation and the type of the shareholders (Gatti, 2013). In the case of Autopistas del Centro, the financial recession hit the project quite since most of the projected cash flow had been forecasted prior to the great financial crisis of 2008 (Lubian, 2015). Therefore, the only option it to sell the project to new owners since the shareholders are reluctant to go into their pockets and revive the project once. Therefore, it is imperative to identify some of the factors that must be considered when pricing the project so as to make sure both the buyers and sellers are satisfied. Besides, the head of the projects is deeply concerned about the best approach that can be used to make sure that the shareholders are satisfied with the handing over of the project to the new owners. Inflation is one of the critical issues that must be looked into when pricing a project to the new owners. The implication is that inflation has the potential to increase the original estimates of the construction costs (Esty, 2014). Usually, the inflation rates are put into consideration when the project is at the design stage but future changes in the inflation rates may affect the original estimated construction costs and this will have a huge effect on the final pricing of the project (Gatti, 2013). Therefore, when pricing the project, it would be important to look at the inflation rates in Spain, as well as Europe in general. In 2009, the CFO of AC, Martinez saw the need to revise the status of the project finance under different circumstances under which the

Role of Education in Society Essay Example for Free

Role of Education in Society Essay Society has certain requirements which must be met if it’s to survive; hence the role of education in society is examined in terms of how it helps to meet those needs. Firstly, society needs a certain degree of social solidarity or unity. People must feel a sense of belonging to society and a sense of loyalty to the social group. Common norms and values provide this. Secondly, every society requires a system for socializing new members. In an industrial society in which occupational status is largely achieved, young people must learn to value individual achievement. Thirdly, every society requires a system for placing people in roles best suited to their talents and abilities. This is particularly true in industrial society with a specialised division of labour. The right people must be matched with the right jobs. Lastly, for society to operate efficiently and effectively, its members must possess the necessary skills to perform essential tasks. (Harambos et al, 1986) Education attempts to develop the personality of the pupil and prepare him for membership into society. This function corresponds to the double role a person has to play in life, both as an individual and as a member of society. Schools in western societies emphasize individual achievement. The student achieves his/ her status based on their ability, talent, determination and effort. Achievement is measured by the student’s performance in examinations. Education can be seen as a system for sifting, sorting and grading people in terms of their ability. Students leave school having been thoroughly tested. In theory, the most talented will achieve the highest qualifications; the least talented will come away with little or nothing to show for their efforts (Harambos et al, 1986) The vision for the Ministry of Education, Science, Vocation Training and Early Education (MESVTEE) is â€Å"to guide the provision of education for all Zambians so that they are able to pursue knowledge and skills, manifest excellence in performance and moral uprightness, defend democratic ideals and accept and value other persons on the basis of their personal worth and dignity, irrespective of gender, religion, ethnic or any other discriminatory characteristic (Ministry of Education, 2000) The Ministry of Education emphasizes that the child is placed at the center of the entire education process which exists solely for the sake of the learner. It also recognizes that each child is unique. This contributes a rich diversity to the whole education system. The aim of school education is to promote the full and ell rounded development of the physical, intellectual, social, effective, moral and spiritual qualities of all pupils so that each can in turn develop into a complete person, for his/ her personal fulfilment and the good of society (Ministry of Education, 1996) The education system in Zambia is divided into four major parts. These parts include lower and middle basic school; upper basic school; high school; and higher education. The education system for the lower and middle basic levels is concerned with the pupils’ complete needs: those of the body, mind, affective, social; moral and spiritual needs. The system at this stage allows for adaptation of some aspects of the curriculum to match local needs and circumstances. This stage provides pupils with a substantial and recognizable preparation for life. Ministry of Education, 1996) The upper basic system builds on the foundation laid at the lower levels, though the programme of activities is just broadened and balanced to allow for treatment at an in-depth appropriate for the level of education, age and experience of the pupils. Education at this level includes issues like Education for democracy, which allows these young Zambians to acquire an understanding of the values that have shaped society and the practices that have preserved it; literacy and numeracy which allows them to read and write correctly, clearly and confidently in both their Zambian language and in English, and to acquire basic numeracy and problem solving skills for them to function effectively in society; science and technology helps the pupils develop processes of scientific thinking. This ability to think scientifically and understand scientific processes has become a condition for survival in society; practical and technical subjects provide compensation for traditional knowledge and practical skills that students would have acquired if they had not been attending school. They also provide a way of experiencing and dealing with the physical world. (Ministry of Education, 1996) Since upper basic education may be the only formal education the majority of pupils will likely get, the basic education system should adequately prepare the pupils for life after school; hence issues such as health and personal well being, Sexuality and personal relationships are tackled at this level. This is coupled with helping the students to develop socially acceptable habits. In these studies, effort is complemented by the home, community and society at large. This enables the pupils shape for themselves their own personal philosophy of life, by internalizing and adopting their own set of values and attitudes which would direct their own lives. (Ottaway, 1962) Performing and creative arts helps the pupils develop knowledge of and a deeper appreciation for Zambia’s rich cultural heritage and thereby contribute to the preservation and development of this heritage. Co-curricular activities also help pupils develop life skills which equip them with positive social behaviour and coping with negative pressure. High school builds on the foundation laid in upper basic school. High school aims at the integrated and comprehensive development of each pupil’s potential, enabling the pupil adopt adult life and make a useful contribution to society. It also develops the intellectual skills and qualities, foster creativity, imagination resourcefulness and innovativeness and provide occasion for their practical exercise. It also promotes extensive knowledge, exact skills and accurate understanding of areas of study. (Ministry of Education, 1996) When progressing from one level of the education system to the next, evaluation and assessments are conducted. This is in order to determine whether the education system is achieving its objectives, and that it is producing the right caliber of graduates expected by society. Society’s interest is on the public exams that mark the end of one stage of education and serve as a selection instrument for the next stage. (Ministry of Education, 1977) In conclusion, the education system in Zambia is inclined towards the new sociology of education because emphasis is placed on the individual development of the pupil’s potential. Throughout the whole progression from lower basic to high school, focus is placed on the development of the pupil’s skills individually. Pupils therefore develop knowledge of and a deeper appreciation for Zambia’s rich cultural heritage and thereby contribute to the preservation and development of this heritage throughout the whole education system.

Analysis of Prest v Petrodel Resources Ltd

Analysis of Prest v Petrodel Resources Ltd The relatively short and significant judgment in the Supreme Court case of Prest v Petrodel Resources Ltd has gathered vociferous interest from academics and practitioners. It was of key interest as it was a legal cross over between family law and company law. The legal team representing Prest stated that the decision is of major importance not only for family law and divorcing couples, but also for company law, and it is the most important reviews since Victorian times on the law regarding piercing the corporate veil.[2] The principles of lifting the corporate veil for the past eight decades seemed to have never been wholly established as judges always contradicted each other and never reached a unanimous decision. There has been extensive discussion as to whether a court can ignore the principle of separate legal personality and treat a companys property, rights and obligations as belonging to a person who owns and controls the company.[3] The critical points which would be analyse d in this essay would be whether Prest has brought us closer to what the principle of lifting the corporate veil can be defined as, what it entails or whether the whole doctrine should be set aside. It will be argued that the law should not be given its quietus as it seems that judges are somewhat getting closer to an answer. Prest narrowed the circumstances in which the doctrine may apply thus, this could show that decision makers are near the end of a long marathon. On the contrary, it seems that even if the doctrine is set aside, the principles would still be applied unknowingly by judges, it would perhaps not be defined as piercing the veil doctrine. It would possibly be applied in conjunction with other laws which would have the same effect and outcome as piercing the corporate veil. Lifting the corporate veil has been viewed narrowly to be the process used by the courts to either determine what exactly is going on behind the shell of incorporation. The whole concept of lifting the veil was derived from Salomon v Salomon[4] where corporate veil was established. It was held that a limited company was viewed like any other independent person with its right and liabilities appropriate to itself[5] The Salomon principle has been the foundation on which company law and business corporations have thrived on for years.[6] When taking into consideration how the law has developed in this area, Cheung describes that it is evident the House of Lords decision in Woolfson [7] came to be source for guidance in subsequent cases. More importantly, the HL emphasised that it is only appropriate to pierce the corporate veil where the circumstances indicate that the company is merely a faà §ade concealing true facts. However, despite this important distinction, the courts have alwa ys been wary that there must be some limit to the protection afforded by limited liability to ensure that business dealings remain honest. As Lazarus[8] explained no court will allow a person to keep an advantage which had been obtained by fraud[9] This principle underpinned all of the early attempts to pierce the veil meaning that the court will not allow a corporate personality to be used to protect individuals from wrongdoing. Similarly, Lord Sumption explains piercing the corporate veil means disregarding the separate personality of the company[10] Moreover, as per Lord Keith in Woolfson,[11] he states it is appropriate to pierce the corporate veil only where special circumstances exist[12] Consequently, right from the onset, there were conflicting views. The reception which the doctrine received forty years ago is still echoed to this day in Prest. The court reaffirmed in Prest the well-established judicial conservatism approach that the corporate veil could only be pierced in very rare cases[13] Therefore, despite the doctrine not being clear, it is well established that the doctrine is not be considered in all corporate cases but, ought to be considered only rare ones. On the other hand,it can be argued, that the strictness of the approach led to the doctrine existing more as a matter of legal theory than as a feature of legal practice. Prior to Prest, in Lipman,[14]the only way to lift the veil was if the company was regarded as a sham or mere faà §ade. In Smallbone,[15]Sir Morritt brought forward the argument that it is uncertain as to which circumstances a company can be considered as a sham or whether the company need to do something illegal for immorality to suffice.[16] Hence, this suggests that there is no clear structure to be followed. This could create further confusion as to what the doctrine of piercing the corporate veil originally intended to do. Could this perhaps suggest that it is better to abandon the doctrine as a whole rather than to try and figure out what the principle actually proposes to do. This could perhaps create more clarity in the sense that decision makers would know what is not meant to be included in the doctrine. Furthermore, this can be mirrored in Prest where Lady Hale and Lord Wilson doubted whether it is possible to classify all cases neatly into cases of either concealment or evasion[17] Therefore, even to this day there are a lot of question marks as to when and how the doctrine is applied; there are still a lot of unanswered questions which have not been dealt with. It seems that the judges only deal with these when and how it comes. It can be contended that the doctrine is there but, no one has yet connected the dots to see the full picture of what it entails. The fact that none of these questions seem to provide a clear picture further creates problems today as for a doctrine to develop or adapt to the new changes, the reasonings behind the past decision needs to be understood thus, if one cannot do that then how can the doctrine be established. Notwithstanding, since Prest, it is no longer sufficient for a company to show that it is a mere faà §ade or a sham;[18] one must show that control of the company by the wrongdoer was used as a device to conceal the wrongdoing.[19] A new provision on how the doctrine should be established was brought in Prest. Over the past eighty years, there has been many interpretations. Most recently, analysed by Lord Sumption where he identified the concealment and evasion principle. In Prest, Lord Sumption argued for a narrower and clearer approach by restricting the circumstances in which the veil may be pierced. This was because references to a faà §ade or sham beg too many questions to provide a satisfactory answer[20] He attempted to give an explanation; He stated that the veil would be restricted to two principles: the concealment principle and the evasion principle.[21] The concealment principles is the interposition of a company or perhaps several companies so as to conceal the real ac tors[22] But, he noted that this does not actually involve piercing the veil; the court is simply looking behind the faà §ade to discover the true facts.[23] Contrarily, the evasion principle applies where a person is under an existing legal obligation which he deliberately evades by interposing a company under his control.[24] However, despite the two approaches being somewhat clear; Lord Alcock observes that care must be taken because none of the other six justices of the Supreme Court agreed with Lord Sumption without some qualifications[25] He also points out that there is substantial uncertainty surrounding the operation of the evasion principle.[26] Most significantly, Neuberger also found that in cases where piercing the veil was considered, it either did not apply in the facts, or it was applied on the facts but the results could have been arrived at on some other legal basis.[27] On these grounds, this could show that the doctrine does not necessarily need to exist as the same outcome can be arrived on some other legal basis. It can be indicated that the doctrine could perhaps only exist to give reassurance to corporate businesses in order to ensure them that they have a sense of security in case something goes wrong, but in reality, it does not exist and is rarely applied. Undoubtedly, Lord Neuberger drew different conclusions regarding the application of the principle. He argued that there is not much support for the doctrine.[28] He observed that there is no English case which unequivocally underpinned a power to lift the veil[29]; however, recognition is given to a limited power as a valuable judicial tool to undo wrongdoing in cases where no other solution exist[30] It gives the impression that every judge will come up with a new principle every now and again which would be relied upon but then a couple of years after, a new judge will find criticism in the doctrine. It seems that it is going around in a vicious circle without reaching an end-po int. Additionally, Lord Sumptions principle brought further opposition. Lord Mance argued that It is dangerous to seek to foreclose all possible future situations which may arise and I would not wish to do so[31] Furthermore, it should be considered that Prest only dealt with one specific class of asset which were held by those of corporate entities. The decision shows that an application of company law principles is required when determining the ownership of those assets.[32] Henceforth, this shows that Prest only narrowed only one specific factor in piercing the corporate veil, a factor which cannot be used in all cases. This further shows that we are no closer to an answer of lifting the corporate veil. Contrarily to the above, despite there not being a set doctrine, it seems that the Lordships all agree on one aspect. In Prest, they all accepted the existence of a general common law veil piercing as being limited to rare and exceptional circumstances.[33] Lord Clarke argued that Sumptions distinction the circumstances in which the doctrine apply are rare[34] This similar reaction has been echoed in the past. It can be thus shown, that not much has changed and the decision makers are still unsure as to when the doctrine can be applied. In 2017, it is very difficult to predict what the future path for the doctrine will take as there are many conflicts on this topic even from the Supreme Court judges. As stated above, Lord Neuberger, Lord Clarke and Lady Hale were not entirely convinced on the validity of the doctrine and seeing it as merely a metaphor which was unclear and inchoherent. This was contrasted with Lord Mance and Lord Walker who are very much in favour of keeping the doct rine. On the other hand, Lord Neuberger who had initially been in favour of giving the doctrine its quietus because it had been misapplied in the eighty years indicates that the obiter by Lord Sumption is very influential and could prove to be important in future cases. Hence, this further indicates that there are still many uncertainties within the doctrine itself. It can be indicated that if Prest was successful in providing a set answer as to what piercing the corporate veil entails then there would have been many cases which would have pierced the veil post Prest. For some the most helpful case is the decision in Pennyfeathers limited v Pennyfeathers property company limited.[35] It is said to be a better example of facts for giving rise to the principle of piercing the veil. Provided that the principle was to be properly established then there is one thing that all decision makers would agree upon which would be that the company was used in an attempt to immunise himself from the liability of wrongdoing[36] This is consistent in DHN[37] just as much as it is in Gramsci.[38] It seems that in every case that involves piercing the veil, the defendants always argue that there is no such thing as piercing the corporate veil[39] thus, could it be that many wrongdoers have been able to escape liabilities simply because the doctrine was not well es tablished. The new approach found in VTB[40]and Prest significantly restrictive approach to piercing the corporate veil which in effect has relegated the doctrine to a principle of last resort.[41] Post Prest cases such as R v McDowell[42] and R v Singh[43] shows that the superior courts exercising restraint in disturbing the principle in Salomon.[44] It therefore appears that where litigants can show that the relevant tests are satisfied, the courts will allow them to obtain judgement against assets that were intentionally placed out of their reach. However, these cases are and will remain exceptional. More recently, in Akzo Nobel[45] in its arguments had suggested that the Competition Commission had tried to attribute the activities of the subsidiaries to Akzo Nobel which was in effect piercing the corporate veil.[46] It could be considered that an alternative approach would be to put the doctrine on a statutory basis so that the courts would have a guide to follow instead of consistently establishing conflicting views between themselves. However, this could prevent flexibility of the courts whilst it faces complex issues which cannot be foreseen by statute. On the other side of the coin, it would be less harmful than having ambiguous rules. Furthermore, there could be an extension which established distinct body rules for corporate groups such as in Germany. The interest of the whole group both financial and non- financial matters would be recognised. Moreover, another approach could be piercing the veil by removing limited liability towards involuntary creditors, notably tort victims. In Chandler v Cape,[47] it introduced some basis for this approach whilst imposing liability on a parent company by suggesting that the parent company has a duty to the employees of its subsidiary company. To conclude, it has been suggested by academic commentary that the decision reflects a progressive trend of restricting the doctrine.[48] However, it can be contemplated that slightly narrowing a doctrine which Supreme Court judges do not agree with does not mean that it is progressive.[49] If one keeps on rebutting every proposal that is brought forward then that is not progressive, it does not feel like any decision makers has tried to find a solution for this problem. It can be disputed that this is a never ending vicious circle.  It seems as if it is an entertaining ground for judges to see what new solution can be made this time around. Prest brings a new kind of uncertainty.[50] However, Prest does confirm that the veil would only be pierced in exceptional circumstances. There is one basis which all judges approve which is that the veil is only to be pierced in exceptional circumstances. This could perhaps be a starting point of a well-established doctrine. It can be contende d that, even if the doctrine is given is quietus, judges would still apply the principles of piercing the veil unknowingly. This decision can be derived from another legal basis but, it will have the same outcome. Thus, even if it is given its quietus, the doctrine would still be there transparently. It seems that we are at a halt with the long marathon until, a case can fully apply the two provisions in Prest. Bibliography Practitioners Textbooks Palmers Company Law Books A Digman A, John Lowry, Company Law (8th edn OUP Oxford) Birds J, Boyle Clark B et al, company Law (9th edn, Jordan Publishing) Dr Wilde C, Smith and Keenans Company Law ( 17th edn Pearson) Lowry J, and Arad Reisberg, Company Law Corporate Finance (4th Edn, Pearson Journals Akansha Dubey et al, Family Law (2014) 3(1) A Alcock piercing the veil- A dodo of a Doctrine (2013) 25 denning LJ 241,243 A Bowden Concealment, Evasion and Piercing the corporate veil: Prest v Peterodel Resources Ltd [2013], Greens Business law, April 2014 Bull S, piercing the corporate veil in England and Singapore [2014] Heinonline C Hare, Piercing the corporate veil in the supreme court (again)- The Cambridge Law Journal, 72 [2013] 511-515 Chrysthis N Papacleovoulou, lifting or piercing, the corporate veil in Cyprus: a doctrine under challenge- an analysis of English and Cyprus case Law analysis (2016) 27 (4) ICCLR D Lightman, Petrodel Resources Ltd v Prest: Where are we now? Trust Trustees (2013) 19 (9):877 J McDonagh, Piercing the corporate veil in the family division: Prest the latest from the court of appeal- Trust and Trustees (2013) 19 (2) 137 J Payne Lifting the corporate veil: A reassessment of the fraud exception Cambridge law Journal, 56 (2) July 1997 Mujih E, Piercing the corporate veil as a remedy after Prest V Petrodel resources Ltd: Inching towards Abolition [2016] Westlaw 17,17 Pey Woan Lee, The Enigma of Veil- Piercing (2015) 26 (1) ICCLR 28, 30 Spears, Expert analysis of the Prest Judgement (Spears ,11 June 2013) Tan Cheng-Han, Veil piecing- a fresh start (2015) 1 JBL Online Articles Spears, Expert analysis of the Prest Judgement (Spears ,11 June 2013) http:///www.spearswms.com/expert-analysis-of-the-Prest-judgment/> accessed 8th March 2017 Simon Mcleod- The Corporate Veil And Its Piercing As Clear As? http://gdknowledge.co.uk/the-corporate-veil-and-its-piercing-as-clear-as/ >accessed 20th February 2017 Cases Akzo Nobel NV v Competition Commission [2013] CAT 13 Antonio Gramsci Shipping Corp ors v Aivars Lembergs [2013] EWCA Civ 730 DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852 Lazarus Estates Ltd v Beasley [1956] 1 QB 702 Prest v Petrodel Resources Ltd UKSC 34, [2013] R v McDowell [2015] EWCA Crim 173 R v Singh [2015] EWCA Crim 173 Salomon v Salomon [1896] UKHL 1 Trustor AB v Smallbone (No 2) [2001] EWHC 703 VTB Capital plc v Nutritek International Corp [2013] UKSC 5 Woolfson v Strathclyde Regional Council [1978] UKHL 5 [1] Prest v Petrodel Resources Ltd UKSC 34, [2013] [2] Spears, Expert analysis of the Prest Judgement (Spears ,11 June 2013) http:///www.spearswms.com/expert-analysis-of-the-Prest-judgment/> accessed 8th March 2017 [3] French D, Mayson S Ryan C, Company law (31st edn, OUP) 127 [4] Salomon v Salomon [1896] UKHL 1 [5] Lord Halsbury Salomon v Salomon [98] [6] Lowry J, and Arad Reisberg, Company Law Corporate Finance (4th Edn, Pearson) 35 [7] Woolfson v Strathclyde Regional Council [1978] UKHL 5 [8] Lazarus Estates Ltd v Beasley [1956] 1 QB 702 [9] Ibid [10] Prest Lord Sumption [16] [11] Woolfson v Strathclyde Regional Council [1978] UKHL 5 [12] Paragraph 90 lord Ketih [13] Prest [103] Lord Clarke [14] Jones v Lipman [15] Trustor AB v Smallbone (No 2) [2001] EWHC 703 [16] Ibid [17] Ibid [92] Lady Hale [18] Jones v Lipman [44] [19] Birds J, Boyle Clark B et al, company Law (9th edn, Jordan Publishing) 60 [20] Prest [28] (lord Sumption) [21] Pret [28] Lord Sumption [22] Ibid [23] Ibid [24] Ibid [35] [25] Alistair Alcock piercing the veil- A dodo of a Doctrine (2013) 25 denning LJ 241,243 [26] Pey Woan Lee, The Enigma of Veil- Piercing (2015) 26 (1) ICCLR 28, 30 [27] Prest [74] Lord Neuberger [28] Prest [69] (lord Neuberger) Alistar Alcock (n 18) 250 [29] Ibid [30] Ibid [31] Ibid [100] Lord Mance [32] Piercing the corporate veil in the family division: Prest the latest from the court of appeal- Trust and Trustees (2013) 19 (2) 137 [33] Piercing the corporate veil in the supreme court (again)- The Cambridge Law Journal, 72 [2013] 511-515 [34] Ibid [103] Lord Clarke [35] Pennyfeathers limited v Pennyfeathers property company limited [2013] EWHC 3530 (Ch) [36] Gramsci. Burton J [101] [37] DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852 [38] Antonio Gramsci Shipping Corp ors v Aivars Lembergs [2013] EWCA Civ 730 [39] Ibid [40] VTB Capital plc v Nutritek International Corp [2013] UKSC 5 [41] Bull S, piercing the corporate veil in England and Singapore [2014] Heinonline 39,39 [42] R v Singh [2015] EWCA Crim 173 [43] R v McDowell [2015] EWCA Crim 173 [44] Mujih E, Piercing the corporate veil as a remedy after Prest V Petrodel resources Ltd: Inching towards Abolition [2016] Westlaw 17,17 [45] Akzo Nobel NV v Competition Commission [2013] CAT 13 [46] Simon McLeod- The Corporate Veil And Its Piercing As Clear As? http://gdknowledge.co.uk/the-corporate-veil-and-its-piercing-as-clear-as/ accessed 20th February 2017 [47] Chandler v Cape plc [2012] EWCA Civ 525 [48] Akansha Dubey et al, Family Law (2014) 3(1) 214,217 [49] Tan Cheng-Han, Veil piecing- a fresh start (2015) 1 JBL 20,21 [50] Chrysthis N Papacleovoulou, lifting or piercing, the corporate veil in Cyprus: a doctrine under challenge- an analysis of English and Cyprus case Law analysis (2016) 27 (4) ICCLR 129,130

Essay on Millays poem, I, being born a woman and distressed and Yellow Wallpaper :: Yellow Wallpaper essays

Millay's poem, I, being born a woman and distressed and Gilman's The Yellow Wallpaper Two Works Cited In the early nineteenth century, the issue of whether women should be granted certain privileges, such as voting, arose in America. Two female writers during this time are Edna St. Vincent Millay and Charlotte Perkins Gilman. Both women were living in a period of history where women's writings created an impact on literature. Most women were supposed to stay at home and take care of the children and many women were not highly educated; therefore, there were few women writers. Therefore, these writers caught people's attention and made them think about women's issues. Millay's poem, "I, being born a woman and distressed" and Gilman's short story, "The Yellow Wallpaper" share more than their time in history. Both pieces of literature have the common theme of closeness and distance. Women during this time were pushed out by society. They could not have a part in the rest of societal roles and became distant. The women wanted to be close with the rest of society, in ord er to feel equal, and spoke out for their needs. The poem, "I, being born a woman and distressed" was written in 1923 by Edna St. Vincent Millay. This was only three years after the Nineteenth Amendment, granting women's voting rights, was adopted. Millay was best known for her lyrical poetry. In this poem she speaks of her feelings toward her lover and how they make her feel. She characterizes herself for her audience as ". . .being born a woman and distressed By all the needs and notions of my kind. . ." By using the words "woman" and "my kind" the reader gets the feeling as if she needed to express her gender. This time in history may have influenced Millay to explain this. Today men and women are more equal, whereas in the 1920s they were discriminated against. Charlotte Perkins Gilman, another twentieth century American writer, lived during this period of radical reform for women. She was a very independent woman of their time who supported herself until she married at the age of twenty-four. After she had her first child, she became clinically depressed and this experience inspired "The Yellow Wallpaper" ,written in 1913. This story describes a woman who is forced to remain in bed without thinking or writing. Essay on Millay's poem, I, being born a woman and distressed and Yellow Wallpaper :: Yellow Wallpaper essays Millay's poem, I, being born a woman and distressed and Gilman's The Yellow Wallpaper Two Works Cited In the early nineteenth century, the issue of whether women should be granted certain privileges, such as voting, arose in America. Two female writers during this time are Edna St. Vincent Millay and Charlotte Perkins Gilman. Both women were living in a period of history where women's writings created an impact on literature. Most women were supposed to stay at home and take care of the children and many women were not highly educated; therefore, there were few women writers. Therefore, these writers caught people's attention and made them think about women's issues. Millay's poem, "I, being born a woman and distressed" and Gilman's short story, "The Yellow Wallpaper" share more than their time in history. Both pieces of literature have the common theme of closeness and distance. Women during this time were pushed out by society. They could not have a part in the rest of societal roles and became distant. The women wanted to be close with the rest of society, in ord er to feel equal, and spoke out for their needs. The poem, "I, being born a woman and distressed" was written in 1923 by Edna St. Vincent Millay. This was only three years after the Nineteenth Amendment, granting women's voting rights, was adopted. Millay was best known for her lyrical poetry. In this poem she speaks of her feelings toward her lover and how they make her feel. She characterizes herself for her audience as ". . .being born a woman and distressed By all the needs and notions of my kind. . ." By using the words "woman" and "my kind" the reader gets the feeling as if she needed to express her gender. This time in history may have influenced Millay to explain this. Today men and women are more equal, whereas in the 1920s they were discriminated against. Charlotte Perkins Gilman, another twentieth century American writer, lived during this period of radical reform for women. She was a very independent woman of their time who supported herself until she married at the age of twenty-four. After she had her first child, she became clinically depressed and this experience inspired "The Yellow Wallpaper" ,written in 1913. This story describes a woman who is forced to remain in bed without thinking or writing.

Beowulf The Hero :: essays research papers

In Beowulf, the protagonist Beowulf is shown as a hero with extrodinary strength. This is not what makes him a hero. By definition, a hero is a man of exceptional quality. However this term does not do Beowulf justice. His self-imposed purpose in life is to help others, and eventually sacrifices his own life in doing so. Beowulf’s battle with the dragon serves as a critique of the notion that Beowulf is a hero. The Dragon section displays many of Beowulf’s heoric characteristics. Beowulf establishes himself as a hero by fighting the dragon, exemplifing strength and courage when fighting the dragon, and sacrificing himself so that others can live. Beowulf’s fight against the dragon shows Beowulf as a hero. Although Beowulf had previously defeated two other foes, he stands fast and fights his most formidable foe yet, the dragon. Dragons were notoriously difficult to kill, and the poem states that it was a great man, who could kill a dragon, even if it meant losing one's life. While others cower away Beowulf fights the dragon. Beowulf defeats the dragon but loses his life in the same instance. Like the classical hero Beowulf loses his special status in death. Beowulf sought no compensation for his services; the mere satisfaction of helping others was pay enough. Like his two previous battles Beowulf fights for those who could not fight for themselves. While fighting the Dragon Beowulf shows feats of strength and courage that define him as a hero. The classical hero displays a special quality that separates him from the rest of Moss 2 society. In Beowulf, Beowulf shows extraordinary courage and strength that gives him special status. This notion is shown, when Beowulf fights Grendel and Grendel’s mother, but it is especially noticeable when he fights the dragon. When Beowulf fought Grendel others had the courage to attempt to fight him. The same is true with Grendel’s mother. When Beowulf goes to fight the Dragon, the other warriors cower away into the woods. Beowulf shows his courage by fighting the Dragon. Even when Beowulf is fighting the Dragon and realizes that his sword can do no damage he continues to fight. After Beowulf is on the verge of death he shows a combination of courage and strength by delivering the death blow to the Dragon, and not just laying down to die. Beowulf’s strength is shown when he is able to actually do battle with the Dragon; any normal man would have fallen to the dragon immediately.

Trial balance

What is a Trial Balance? State its objectives and characteristics. Give some reasons for disagreement of the Trial Balance. A ‘Trial Balance' is a list of all the General ledger accounts (both revenue and capital) contained in the ledger of a business. This list will contain the name of the nominal ledger account and the value of that nominal ledger account. The value of the nominal ledger will hold either a debit balance value or a credit balance value.The debit balance values will be listed in the debit column of the trial balance and the redit value balance will be listed in the credit column. The profit and loss statement and balance sheet and other financial reports can then be produced using the ledger accounts listed on the trial balance. The following are the important objectives of trial balance: 1. To Check The Arithmetical Accuracy Trial balance is based on the double-entry principle of debit equals credit or credit equals debit. As a result, the debit and credit col umns of trial balance must always be equal.If they do, it is assumed that the recordings of financial transactions are ccurate. Conversely, if they do not, it is assumed that they are not arithmetically accurate. Therefore, one important purpose of preparing trial balance is to provide a check on the arithmetical accuracy of the recordings of the financial transactions. 2. To Help Locate Accounting Errors Since the trial balance indicates if there is any error committed in the Journal and the ledger, it helps the accountant to locate the error because the starting point of locating errors is trial balance itself. 3.To Summarize the Financial Transactions A business performs several numbers of financial transactions during a certain period of time. The transactions themselves cannot portray any picture of the financial affairs of the business. For that purpose, a summary of the transactions has to be drawn. The trial balance is prepared with a view to summarize all the financial tran sactions of the business. 4. To Provide the Basis for Preparing Final Accounts Final accounts are prepared to show profit and loss and the financial position of the business at the end of an accounting period.These accounts are prepared by using the debit and credit of all ledger accounts. Therefore, since the trial balance is a statement of the debit and credit balances of the ledger accounts, it provides the basis for the preparation of the final accounts. Characteristics of Trial Balance 1. It is a list of balances of all Ledger accounts and Cash Book 2. It is not a part of the double entry system of book-keeping. It is only a working paper. 3. It can be prepared on any date 4. It verifies the arithmetical accuracy of posting of entries from the Journal to the Ledger. 5.