The Summary of Professional Development 1, Chapter 5 – 7

To make sure the best solution will be generated once the problem is defined, guidance of idea generation techniques is significantly important in breaking down the barriers to generating. Mental blocks are mainly the hindrance on the progress toward a solution. Mental blocks can be divided into seven blocks, which are conceptual, perceptual, emotional, cultural, environmental, intellectual and expressive blocks. Goman’s blockbusters can be used to overcome these blocks. For example, Goman's Blockbusters Block| Blockbuster| 1. Negative Attitude| 1. Attitude Adjustment| 2. Fear of Failure| 2. Risk Taking| 3.Following the Rules| 3. Breaking the Rules| 4. Over-reliance on Logic| 4. Creative Internal Climate| 5. Belief That You Aren't Creative| 5. Creative Beliefs| After that, use brainstorming to generate solutions to the problem. Process of generating solutions is started with free association – that is, writing down all available suggestions without judgment of the feasi bility. Free association can be used to generate the initial set of ideas. When the flow of suggestions becomes low, triggers can be used to rejuvenate the rate of suggestions, which are vertical thinking, lateral thinking, TRIZ, cross-fertilization, and futuring.Vertical thinking can be used to build on previous ideas and generate new ideas. One of the vertical thinking techniques is Osborn’s checklist, to adapt, modify, magnify, minify, substitute, rearrange and combine. Lateral thinking is to use random stimulation and other people’s views when in a rut. Futuring is a blockbusting technique to remove all technical blocks to envision a solution in the future. The rules for futuring are relatively simple, try to imagine the ideal solution without regard to whether it is technically feasible.The fishbone diagram can be used in organizing brainstorming ideas. It can be very helpful in visualizing all the ideas which have been generated. Analogies and cross-fertilization are to bring ideas, phenomena, and knowledge from other disciplines to bear on the problem and lastly, TRIZ is to resolve contradictions. Once the real problems have been defined and some potential solutions have been generated, decision on which problem to address first and which actions should be taken to address this problem should be made.After that, the best solution from the possible alternatives should be selected. Lastly, decision on how to avoid additional problems as implementing the chosen solution would also be made. An organized process for making these decisions is the Kepner – Tregoe (K. T. ) approach. One of the unique features of each of the K. T. strategies is the way of displaying the data. In each case, situation appraisal problem analysis, decision analysis, and potential problem analysis would be used and lastly, analyzing the date listed in each table will help to reach a decision.Situation Appraisal Problems| Timing(H,M,L)| Trend(H,M,L)| Impact(H,M,L) | Next Process(PA,DA,PPA)| 1. 2. 3. | | | | | Problem Analysis | Is| Is Not| Distinction| Problem Cause| What| | | | | Where| | | | | When| | | | | Extent| | | | | Decision Analysis Potential Problems| Possible Causes| Preventive Actions| Contingent Plan| A. | 1. 2. | | | B. | 1. 2. | | | K. T. situation appraisal can be helpful when multiple problems are faced at the same time. Deciding the priority, evaluating criteria and deciding which action to take are to be done during situation appraisal.Each problem is measured against the criteria of timing, trend, and impact. These criteria are rated as warranting degree of concern, which are high (H), moderate (M), or low (L). Once the problem is known, decision analysis (DA) can be used. In the DA technique, the cause of the problem has been found and the decision at the present time is how to correct the problem. Once the decision is made, problem potential analysis (PPA) will ensure the success of the decision.

The Sociological Perspective

Know the assumptions of structural-functional, conflict, and symbolic interaction theories. Review the contributions of Augusta Comet, Herbert Spencer, Karl Marx, 6. Mile Drummers, Max Weber, Harriet Martinets, Jane Addams, and W. E. B. Dubos. Review the development of sociology in the United States. 8. Review the process of the three types of research discussed in the textbook. 9. Outline the steps in the scientific method of research. 10. Differentiate between the following concepts: variable, independent and dependent variables, and control variables. 11. 12. 13.Explain the importance of operational De Discuss what a sample is in survey research. Explain the advantages and disadvantages of controlled experiments, survey research, and participant observation. Do you every wonder why people in the Midwest drive pick-ups and the people in China want a bicycle? Do you ever think about why people were glued to their televisions when the World Trade Center Towers were destroyed by terro rists? Do you ever watch people at a ballgame or at a shopping mall? Have you ever wondered why these people behave as they do? Do you ask yourself why you make some of the decisions that you do?If you see influences from family, friends, co-workers, and the kind of economy hat we live in, then you are practicing sociology. Sociology is concerned with the groups, large and small, that we are a part of and how they influence our behavior. Sociology is one part of the social sciences. The social sciences are a related group of disciplines that study some aspect of human behavior. The differences are in the focuses. As examples, psychology focuses on such areas as the personality, the brain, and how we learn. History and political science study past events, government structures, and current affairs to understand our behavior.Economics includes areas such as supply and emend, government policies, and occupational trends. Anthropology focuses on cultures and how they determine certain b ehaviors. Sociology can be explained by the updated version of an old story titled: The Elephant Story. It goes as follows: It is said that in the recent past five wise men and women, all blindfolded, were led to an elephant. Each was asked to explain what they â€Å"saw†. The first, a psychologist, feeling the top of the head, said, â€Å"This is the only thing that counts. All feeling and thinking takes place inside here.To understand this beast, we need study only this. The second, an anthropologist, tenderly touching the trunk and the tusks, said, â€Å"This is really primitive. I feel very comfortable here. Concentrate on these. † The third, a political scientist, feeling the gigantic ears, said, â€Å"This is the power center. What goes in here controls the entire beast. Concentrate your studies here. † The fourth, an economist, feeling the mouth, said, this is what counts. What goes in here is distributed throughout the body. Concentrate your studies on this. Then came the sociologist (OF course! , who, feeling the entire body, said, You can't understand the beast by concentrating only one part. Each is but part of the whole. The head, the trunk and tusks, the ears, the mouth – all are important. And so are the parts of the beast that you haven't even mentioned. We must remove our blindfolds so we can see the larger picture. We have to see the larger picture. We have to see how everything works together to form the entire animal. Pausing for emphasis, the sociologist added, â€Å"And we also need to understand how this creature interacts with similar creatures, HOW does their life in groups influence their behaviors? I wish I could conclude this fable by saying that the psychologist, the anthropologist, the political scientist, and the economist, dazzled upon hearing the wisdom of the sociologist, amidst gasps of wonderment threw away their blindfolds, and joining together, began to examine the larger picture. But, alas, an d alack! Upon hearing this sage advice, each stubbornly bound their blindfolds even tighter to concentrate all the more on the single part. And if you listened very, very carefully you could even hear them saying, â€Å"Don't touch the tusks. † ‘take your hand off the ears. â€Å"Stay away room the mouth – that's my area. † Sociology, however, includes all of these areas of study and is probably the broadest of all of the social sciences. The main difference is that sociology focuses on the effects of groups on our actions and decisions. Sociology views behavior as resulting from all of the various influences that these disciplines specifically study. Certainly living in an industrial/technological society affects our motivations and our occupational choices. World War II affected how we view women in the labor force today. Telecommunications have influenced our current work patterns.These are a few examples that demonstrate the effects of our society on b ehavior. Sociology is defined as the systematic study of human social interaction. This means how we interact with persons in any group setting. Most of us follow patterns in our behaviors (think about your morning routines, are they usually the same? ) and this allows sociologists to learn something about our behavior. Sociologists try to describe and to explain behavior. They are people watchers – looking for patterns of behavior which allows sociologists to predict trends in behavior to help determine better social policies.However, sociologists realize that people change which requires that our predictions be tenuous. Never the less, sociologists want to develop a body Of reliable knowledge that can be applied to make our lives more understandable. Sociologists explain behavior through the concepts of structure and roles. Structure is much like a framework or script that guides our behavior. Roles, on the other hand, fit into a structure and deal with how we should perfor m. In a basketball game, rules serve to give the game structure. Everyone who plays knows or should know the rules of the game. This allows everyone to now how to behave and what to expect.

Ethics Essay Example | Topics and Well Written Essays - 2000 words - 2

Ethics - Essay Example Nearly every citizen in the developed world is a customer to a bank or two. Banks are used in nearly every aspect of human lives, some apply for bank’s mortgages, while others apply for assets financing from the banks, and the payment of salaries through bank accounts heightened the need for everyone to operate a bank account in the country. The crisis therefore directly affected nearly every citizen. Whenever a bank makes losses, it does so with other people’s money in it, most banks used their clients money top run business and make profit, in a crisis such as the one experienced in 2009, most of these money therefore get absorbed up in the crisis resulting in direct losses to the very unsuspecting customers. The final major stakeholder in the financial sector is the government, who acts as the moderator in every crisis. The populace, in an attempt to coordinate the operation of activities especially in a democratic society, forms governments; some of the activities c oordinated by a typical government include the financial stability of a country. The country must have enough currency floating within its economy to enhance governance. However, when banks make losses most of the citizens lose faith in the banking sector, which results in the closure of bank accounts as, was experienced in the United Kingdom. This results in governance crisis since the economy fails to have enough money circulating at any one time, the lack of money circulating results in a series of negatively implicating activities most of which would eventually ground the operations of the government. Given this understanding, the British government bailed out a number of banks that has made enough loses resulting in their clients lining up to close their bank accounts. Such occurrences could have stalled the English economy, the government therefore bailed out banks in the country by offering them a seventy billion pounds financial aid. 1.2 The occurrence of the financial crisi s especially in the United Kingdom was purely a managerial issue. The number of banks has increased in the country, this followed the effective and substantial growth in the economy, when the economy becomes liberal, a majority of players comes on board to try the new business opportunities. The resulting competition made the business environment marked with a lot of uncertainty. Every business venture needed customer; they needed business to stay relevant to the market. Banks thus began the packaging of different products key among which was loans. Mortgages, asset financing and basic loans became very easy to access as most of the financial institutions relaxed their terms of borrowing. As more citizens and clients thronged tge banks for loans among other financial services, it was eminent that very soon the country would hit a financial snag. The banks had greatly relaxed their terms and conditions, getting a loan from any bank thus became a child’s play. The English marke t is one of the most aggressive in the world. They thus applied for loans from the banks sighting different reasons most of which the banks never ascertained their credibility. Most of the loaned customers had poor loan payment histories, which unfortunately the banks did not bother to look into. Most of the loaned customers began defaulting; some became unreachable resulting in a definite loss for most of the banks. This was a financial crisis in waiting, the economy plunged into bankruptcy which it

Problem Question - Law of Contract Essay Example | Topics and Well Written Essays - 2000 words

Problem Question - Law of Contract - Essay Example The appeal case will deal with two primary issues; whether the IndyBooks Ltd. adhered to the doctrine of incorporation; and whether an e-mail notification can be taken as form of acceptance of a contract. Doctrine of Incorporation The doctrine of incorporation in English law Contract Law refers to the attaching of terms and conditions to such agreements in a manner that the court acknowledges them as legitimate. For terms to be viewed as incorporated the following three conditions must be met: a) the offerer of the contract must notify the other party of the terms prior to or in the course of entering into the contract; b) the terms and conditions must be attached to the document containing the contract; and c) the originator of the terms must act â€Å"reasonably† to ensure that the terms are within the reach of the other party. These rules are however not statutory1. In this case, IndyBooks Limited met the three conditions by notifying Ryan of the terms and conditions during the registration process. ... She could read the terms and conditions or even download them but she ignored them. Ignoring terms of a contract is no defence to unawareness of the terms. Contractual document The second condition for incorporation of contract articles is that the terms must be written on a form that is planned to be the binding document. In this case the terms were part of the contract document that Ryan had filled and submitted online. Therefore, the defendant acted reasonably to meet this condition, and is likely to win in the appeal. In the United States, the rule of â€Å"minimum contacts† is used to decide most of online contract cases, especially those that are made by a party who is in the country and the other is outside of the country. In the case of Pres-Kap, Inc. v. System One, Direct Access, Inc., [1994] 636 So.3d 1351, for example, the court invoked the rule in arriving at the decision of the case2. In the case, Pres-Kap a party based in New York, chartered System One's automate d airline booking system with computer systems situated in Miami, Florida, but encountered problems with the transaction due to system failure. He then opted to not send the funds and System One filed claims for violation of the agreement in Florida. The court decided that a contractual agreement between two parties in which one party is out of the country does not meet the â€Å"minimum contacts† doctrine for personal jurisdiction. The local company that owned the server was also inadequately prepared to corroborate this. Otherwise, by granting the plaintiff’s prayers, the court predicted that future users of Internet-based services will jam courtrooms wherever particular servers were located. In light of the decision on Pres-Kap, Inc. v. System One, Direct Access, Inc., the court may rule in

No Topic Assignment Example | Topics and Well Written Essays - 500 words - 2

No Topic - Assignment Example The idea behind this sentence means the simple fact that the more we try to develop our society and humanity at large; we are indirectly destroying the future. It was only few years back when we started globally developing ourselves in order to grow. Generally it has been seen that the ways of the humanity actually harms the balance of the nature and impact the environment. Since time immemorial humankind protected itself against nature, now nature must be safeguarded against mankind. Nature is the most important aspect of atmosphere, protecting it should be our foremost responsibility. Specifically risk are the "worldwide house" the Antarctic, sea couches, tropical timberlands, with numerous species debilitated by the insatiable development of interest for new inputs, while earths climate is overburdened with the buildups development deserts. Thus, it was during the 1980s that the ascent of a worldwide environmental cognizance was communicated by numerous voices, all regretting the dangers to the worlds biosphere and the offence to the eras to come. The group obligation to protect the "regular legacy of humanity" was conjured, and "Tending to the Earth" turned into a basic which disturbed spirits worldwide. Regard for the uprightness of nature, autonomously of its esteem for people, and in addition a legitimate respect for the privileges of mankind requested that the global nature should be secured. There have been numerous examples used by the author which shows how efficiently we have been destroying the nature in an irreparable way. All these were given with the sole motive to make us understand that we human beings are gradually destroying the nature and the misbalancing the universe with this act of ours. The in return will try and defend itself in a very ruthless ways. Ways which cannot be sustained by mankind. Until and unless we try and stop ourselves, we will have to face the nature’s fury at some point in future when

Understanding the Concepts Essay Example | Topics and Well Written Essays - 750 words

Understanding the Concepts - Essay Example A current ratio is considered good if is above 1.0. Another ratio of importance for small business owners is net margin. The net margin is a financial metric that measures the absolute profitability of a company. It is calculated diving net income by total sales. A third ratio I would emphasis is return on assets (ROA). Return on assets measures the effectiveness of the owners or managers to generate net income from its assets. As a manager of a large corporation I would target other ratios that small business owners do not consider. The earnings per share (EPS) is an important ratio due to the fact that it measures the amount of income generated per common stock outstanding. A high EPS positively impacts the market value of a common stock. A second financial metric that corporations have to consider is the dividend payout ratio. The dividend payout ratio is an index showing whether a company pays out most of its earnings in dividends or reinvests the earnings internally. A third rat io I would pay close too is inventory turnover. Inventory turnover is calculated dividing cost of goods sold by average inventory balance. It measures how many times a company’s inventory has been sold during a year. Debt financing occurs when companies borrow money from other parties to finance its operations. Three types of debt financing instruments are loans, notes payables, and corporate bonds. The federal government is one of the biggest players in the debt industry. One of the greatest benefits of debt financing is the ability to raise large amounts of money to be paid in monthly payments. Each monthly payment is composed of two portions: equity and interest. Bonds are an advantageous instrument due to the fact that the principal of the bond is paid back at maturity age. A disadvantage of debt financing is the high interest rates that are paid to the lender. Companies with excellent credit scores are able to borrow money at lower prices. Sometimes companies prefer to r aise capital using debt instead of equity because the sale of stocks dilutes the value of the stocks and it lowers the control of the existing owners. The financial results of a company are correlated with the risks taken by the management team of the company. Higher risks propositions tend to have higher return associated with the option. Risk adverse managers do not like risk, thus they avoid it at all costs. From the perspective of an investor purchasing stocks has more risk than investing in treasury bills. Bonds that pay a higher coupon rates have higher risks than lower paying bonds. Two companies that rate corporate and governmental bonds are Moody’s and Standard & Poor’s. The highest rated bond grades are AAA by Moody’s and Aaa by Standard & Poor’s. A financial variable that can be used to measure the risks of a company is the beta coefficient. The beta of a company measures how sensitive a common stock is in relation to fluctuations in the market . A company with a Beta of one moves in the same direction as the market. Companies with fluctuations above one are more sensitive to market fluctuations. A beta below one implies the company is not sensitive to fluctuations in the market. Beta can also be used as part of the formula of the capital pricing asset model (CAPM). The formula to calculate the capital asset pricing model is Ks = Krf +B(Km-Krf) (McCracken, 2009). CAPM compares the risk of a company against the entire

TATA motors Essay Example | Topics and Well Written Essays - 1000 words

TATA motors - Essay Example However, there are issues of uncertainty that affects the automobile industry, such as economic downtimes that reshapes the entire structure of the sector (International Labor Organization, 2010). This presentation thus analyses these uncertainties in relation to how it affects Tata Motors. The automobile industry is subject to consider by many as being the most profitable industries. On the contrary, the industry has been able to experience its own highs and lows. For example, the recent economic downturn experienced in 2009 led to the major economic downturn in the industry (Economic Outlook no. 1210, 2014). Other factors causing uncertainty in this industry are as listed below; Conducting PESTLE analysis is a popular and most useful tool to help in understanding on the reductions or growth through the market. The understanding may include the position of the potential that the business has in the market. The automobile industry is again under the period of uproar. Crises of 2008/09 are far from over, and currently, the industry may probably be marking the start of the second revolution (UNIDO, 2010). These are the three key uncertainties facing the industry; In an overall outlook, India’s automotive industry is in a better shape than compared to what it was five years ago, with the growth progress estimated to continue over the coming years. Four key challenges (best and worst) need to address in determining the future profitability (McKinsey & Company, 2013). 1) Complexity and cost pressure – the future of the industry predicts that there will an extra platform for sharing and more modular systems. More regulatory pressure will occur and prices will be flat (Freyssenet & Groupe, 2009). 2) Diverging markets – the auto industry should adapt to the changing regional and the segment patterns of both supply and demand patterns. There is a threat from the emerging Chinese after sales market that offers new growth opportunities (Giachetti &

Consumers are Passive Victims Manipulated Into Buying Commodities They Essay

Consumers are Passive Victims Manipulated Into Buying Commodities They Cannot Resist - Essay Example This essay discusses and investigates the topic on why the purchasing habits of the consumers are heavily dependent on certain market parameters. Consumer power in the current marketing system is always a controversial one. Majority of the consumers all over the world are passive elements rather than active elements as far market is concerned. In fashion industry, the passive nature of the consumers is more evident. This essay refers to several examples such as: people normally take inspirations from celebrities while they take purchasing decisions in fashion industry. Products endorsed by the celebrities are moving rapidly towards the market than the products which do not have any such backing. In other words, the researcher states that people are blindly trusting the words of the celebrities and product manufacturers and they are not bothering much to research more about the authenticity of the offers put forward by the advertisers and marketers. However, no two individuals are ali ke: either physically or mentally and therefore it is not necessary that a product suited to one person may be suited to another person. To conclude the research, the author suggests his opinion on the topic that modern customers are not ready to accept such claims and they try to boost their image with the help of expensive products that were successfully advertised by celebreties. Long story short, majority of the current consumers are passive in nature while they take their purchasing decisions.

Does the General Sales Tax Impact the Personal Consumption Expenditure Research Paper

Does the General Sales Tax Impact the Personal Consumption Expenditure - Research Paper Example This paper seeks to study the relationship between sales tax and individual consumer expenditure and saving. Table of Contents Table of Contents 2 1.0. Introduction 1Sales tax is part of consumption tax, tax on imposed on spending on goods or services in various states. Sales tax is usually imposed to buyers during the purchasing of goods or services. The sellers are the one who collect the tax. Tax rates vary from one state to another. In United States, the sales tax has been increasing drastically since 1997 and this has led to rise of prices of both services and commodities. The people who are affected indirectly by sales tax are the buyers. Their expenses rise per month forcing them to draw narrow budgets. This is the same in the whole world and the economies of many nations are going down. What it exported or imported is also highly taxed. Sales tax is different from value added tax because it is only imposed once at the retail level. Different states in United States have diffe rent tax rates. There are some jurisdictions in these states that determine the tax rates to be imposed on various goods and services. Goods for manufacture or resale are usually exempted from sales tax. Some other jurisdictions also exempt sales tax on foods sold in grocery shops, agricultural supplies and prescription medications. Sales tax greatly affects the spending of consumers, changes their consumption behavior and marketplace at the household level. 2.0. Literature Review There are many researches that have been done to show how the increase in sales tax affects personal consumption expenditure. Most of the results got from these researches have showed negative impacts on personal consumption expenditure. As Kevin 2001 puts it, this has been the case in the 2United States of America and the rest of the world. In a case study conducted in California in 2007, it was revealed that the best sales tax rate was 7.25%. This was a rapid increase from 6.6% in 2004 while in 1990s it was less than five percent. Most of this was taxed because of transport expenditures that were incurred during transportation of the goods or services. The estimation for the next year after 2007 was 7.75% tax rate and this was observed to be the trend to be followed unless the economy in the whole world is restructured since the people in California must rely on imported and exported goods and services. In this case study, the main objective shall be to show the effects of increased sales tax on the well-being of people in California. The methods that shall be used shall help to come up with resourceful data that shall be analyzed in depth. From the analysis, it shall be clear on the real effects that are caused by increased sales tax. Increase in tax rate has been there in California just as it is with other states in America. Some of the effects may be positive; however, many of them are negative. To the unemployed the situation is worse thus, there must be proposals to look into the issue deeper before it goes beyond recognition. From another research done in the same state to identify the much that is used for consumption by individual persons, according to Kanbur and Spence, it was found out that 65% of the spending per individual was on consumption. It was not, however, constant as it varied with genders and age. There were many reasons that were given for the high spending in consumption and the main one was increased sales ta

Short Story - Suicidal Tendencies Essay Example for Free

Short Story Suicidal Tendencies Essay Jamie stepped into the betting office and instantly a warm blast of hot air hit him and the stink of unwashed bodies and cheap deodorant overpowered his nose so that was all he could smell. He made his way through the smoky haze of cigarette smoke towards the betting counter carefully moving round the leather sofas and chairs and trying not to step in any chewing gum or a half eaten chocolate bar. The guy at the desk looked up at him through the glass and asked, Can I help you sir? Id like to place a bet please he stated. Name please the man at the counter asked and as Jamie replied he tapped it into his database Were sorry but were afraid weve found a problem he whispered quietly What kind of problem? Jamie asked nervously Perhaps youd like to come round he said, opening the door to his left as he spoke and ushered Jamie into the managers office. As the door closed behind him, Jamie took in his surroundings; he was in a large office with a 32-inch plasma screen at one end, a comfortable looking sofa on the wall and a desk with a new computer on it. A man was sitting behind the desk. A middle aged, harassed looking man. He started to speak softly and indicated to Jamie to take a seat on the sofa. Were sorry but based on your credit report, we cant allow you to make any more bets as youre almost in debt But.. please!! Come on youve got to let me get Jamie said, his voice gradually getting louder. Sorry, I wish there was something we could do.. but we cant, sorry I HATE YOU, I WISH YOU WERE DEAD!!! Jamie screamed at the manager, he jumped up and knocked a picture of the wall with his hand then stormed out of the office, knocking over chairs and pushing a 60 year old man over. He felt betrayed and wished his life would end, that was when he decided to commit suicide because he hated life. The manager came out of the betting shop and said to him If you can find i 10 we can allow you bet again as your credit limit will be raised Jamie calmed down then and went of for a walk. Throughout the rest of the day he tried everywhere to get i 10 so he could be allowed to bet again, as it was his passion, he was an addict. Towards the end of the day, Jamie got increasingly frustrated about not being able to find i 10. Eventually he was so angry that he wanted to commit suicide so he went up to the top of a 10 storey car park and as he stood, toes pointing over the edge, poised to jump, he started to come round and decided to back out as he decided he could find the money by other means but then he remembered, the embarrassment he felt in the office and jumped.jumped of the edge. As he hit the ground with a sickening crunch and broke both his legs, blood started to pour out his shirt he saw, next to him, a i 10 note. Show preview only The above preview is unformatted text This student written piece of work is one of many that can be found in our GCSE Miscellaneous section.

Parliamentary Sovereignty in the UK in the Wake of Brexit

Parliamentary Sovereignty in the UK in the Wake of Brexit POn 23 June 2016, the UK government held a referendum to decide whether the country should leave the EU. The majority citizens voted for Brexit (51.89 per cent to 48.11 per cent) with a turnout of 72%, however, they thoroughly fell behind in Scottish and Northern Irish tallies. Be that as it may, the Government was still expected to trigger Article 50 of the Treaty on European Union (TEU) as soon as possible, without the express permission from Parliament. The Prime Minister at the time, David Cameron, had promised that he would follow through with the outcome, even if that meant leaving the EU (BBC, 2017).[1] However, the situation was not as straightforward as presented by the â€Å"Leave† campaign. The principle of parliamentary sovereignty meant that the referendum result had no legal binding. Therefore, the Prime Minister and government were free to ignore the referendum result if they saw fit. Furthermore, some argued that the government had no right to trigger a leave; only Parliament could do so, as a result of the principle parliamentary sovereignty (Weale, 2017).[2] This paper discusses the topic of parliamentary sovereignty in the UK, particularly in the wake of Brexit, and briefly touches on some social consequences had Parliamentary Sovereignty not been respected. The structure of this paper is therefore as follows: First, Section 1 briefly discusses the history behind parliamentary sovereignty in the UK. Then, Section 2 discusses the Miller Case, a case where the High Court upheld parliamentary sovereignty in the wake of Brexit. Finally, Section 3 explores the European Union (Notification of Withdrawal) Act 2017, an Act of Parliament that grants the government power to leave the EU. 1. The Principle of Parliamentary Sovereignty The idea of parliamentary sovereignty was conceived circa the Case of Proclamations in 1608 (Barnett, 2017).[3] This was a court decision that reduced the power of Monarchs. Essentially, the courts decided that moving forward, Kings and Queens would have to obtain Parliament’s permission to change laws. Specifically, the Case of Proclamations stated that â€Å"the King cannot change any part of the common law [†¦.] without parliament† (House of Lords, 1610).[4] Following this, the English Civil War occurred 1642–1651, where Parliamentarians fought against Royalists for ideals such as parliamentary sovereignty. The Parliamentarians were victorious on such occasion and thus began the ‘Glorious Revolution’ in 1688, which established parliamentary sovereignty in England (Goldsworthy, 2010).[5] Then, in 1689, parliamentary sovereignty was enshrined in the Bill of Rights. Similarly to the Case of Proclamations, this bill requires Monarchs to obtain pe rmission from Parliament before changing laws. Specifically, the Bill of Rights said, â€Å"Suspending the laws or the execution of laws by regal authority without consent of Parliament is illegal† (Parliament of England, 1689).[6] In modern day Britain, Parliament consists of three main decision making bodies: the Sovereign (the monarch, i.e. the King or Queen), the House of Lords (i.e. unelected members of parliament), and the House of Commons (i.e. elected Members of Parliament, or MPs). These three bodies form the highest power in the UK. The fact that Parliament has supreme power is known as parliamentary sovereignty. In the words of Legal commentator Albert Dicey, parliamentary sovereignty gives Parliament the power â€Å"to make or unmake any law whatever† (Dicey, 1915, p.3).[7] The only limits to parliamentary sovereignty are those that Parliament sets itself (Bradley, 2011).[8] An example of this self-enforced limit is Parliament’s subordination of the UK to the EU. This came into effect in 1972, when Parliament signed the European Communities Act, under which the UK was compelled to follow EU law (Barber, 2011).[9] Parliament also has the power to lift its self-imposed limits. For exampl e, Brexit means that Parliament will repeal the European Communities Act, thus ending the EU’s control over the UK (Supreme Court, 2017).[10] It is also important to note that only Parliament can repeal Parliamentary acts. Essentially, the government and Queen cannot repeal Acts of Parliament without Parliament’s permission. 23. Parliamentary sovereignty has been a significant part of many cases and has repeatedly been called upon during cases of importance. A quote from Lord Bingham of Cornhill in R (Jackson) v Attorney General [2005] UKHL 56; [2006] 1 AC 262 at para. [9] encapsulates this significance perfectly: The bedrock of the British constitution is the supremacy of the Crown in Parliament. 2. The Miller Case Following the Brexit referendum in June 2016, Times journalist David Pannick noted that the government could not trigger Article 50 by itself; the government would have to first obtain permission from Parliament (Pannick, 2016).[11] This was because of the principle of parliamentary sovereignty. Specifically, Pannick noted that Parliament had agreed to the European Communities Act in 1972, and because only Parliament can reverse its own decisions, and therefore only Parliament can repeal the act and withdraw from the EU. He also drew attention to Article 50 of the Treaty on European Union, which says, â€Å"any member state may decide to withdraw from the union in accordance with its own constitutional requirements† (EU, 2007).[12] Pannick argued that since parliamentary sovereignty is a constitutional requirement, the EU would not accept the UK’s withdrawal without parliamentary approval (Pannick, 2016).[13] Theresa May was dismissive of these claims. She asserted that they were a tactic to delay Brexit and subvert democracy (BBC, 2017).[14] She also stated that the government did not need parliamentary approval to trigger Article 50 (Freehills, 2016).[15] Notably, Theresa May stated, â€Å"It is up to the Government to trigger Article 50 and the Government alone† (BBC, 2017).[16] Many disagreed with Theresa May, as they believed that withdrawal from the EU without Parliament’s permission would be unlawful (Weale, 2017).[17] Several members of the public felt so strongly about this that took legal action against the government. Miller v Secretary of State for Exiting the European Union, or the Miller case as it was known informally, was heard in the High Court of Justice. Miller argued that Parliamentary involvement was necessary because: â€Å"By enacting the 1972 Act, Parliament surrendered aspects of its legislative sovereignty and conferred the same upon (what are now) the EU Institutions. Such conferral cannot be undone [†¦] without Parliamentary consent.† (Supreme Court, 2016, p.21)[18] In plain English, Miller’s argument was that considering Parliament surrendered power to the EU in 1972, only Parliament could take this power back (Supreme Court, 2016).[19] The government disagreed with this claim. They believed that once the UK leaves the EU, the European Communities Act 1972 would simply cease to apply, because former treaties would not exist (Supreme Court, 2016; Weale, 2017).[20] Furthermore, the government argued that they had the royal prerogative to override parliamentary sovereignty. The royal prerogative is an old power that allows governments to make decisions without Parliament, in exceptional circumstances (Freehills, 2016).[21] The government also noted a rule that â€Å"the making and unmaking of treaties is [†¦] within the competence of the government† (Supreme Court, 2017, p.84)[22] The case was debated in the High Court for several weeks until the High Court delivered its verdict on 3 November 2016. The High Court ruled in favour of Miller: the government had to obtain parliamentary authority to trigger Article 50. The High Court had agreed with Miller’s arguments about the principle of parliamentary sovereignty (Supreme Court, 2017).[23] The court explained that because of parliamentary sovereignty, only Parliament could repeal the European Communities Act. This is because only Parliament can repeal an Act of Parliament. The High Court also explained that Article 50 would nullify several rights of UK citizens (Supreme Court, 2017).[24] These rights included the right of UK citizens to live and work freely in other EU countries, and the right to 20 days paid holiday under the Working Time Directive 2003. Parliament put these rights in place when it passed the European Communities Act in 1972. The High Court also ruled against the government’s right to use the royal prerogative (Supreme Court, 2017).[25] To explain why, the High Court cited the case of Burmah Oil Co (Burma Trading) Ltd v Lord Advocate [1965] AC 75, 101. This case involved use of the royal prerogative. Lord Reid, dismissed the royal prerogative as a â€Å"relic of a past age† (House of Lords, 1965, p.101).[26] Lord Reid also explained that the royal prerogative is â€Å"only available for a case not covered by statute† (p.101).[27] Typically, the royal prerogative is only for situations such as declaring war, dissolving parliament and governing colonies (Wade, 1961).[28] So, in Miller’s case, the High Court explained that a royal prerogative was inappropriate for triggering Brexit. Therefore, the government did not have the power to trigger Article 50 without Parliament’s approval. The government was unhappy with the High Court’s decision and chose to appeal it, and as a result the case went to the Supreme Court. Ultimately, the Supreme Court dismissed the government’s appeal, citing the same reason as the High Court (Supreme Court, 2017).[29] Essentially, the court explained, the government in 1972 needed Parliament’s approval to sign the 1972 Accession Treaty. This meant that present-day government also needed Parliament’s approval to repeal this treaty (Supreme Court, 2017).[30] Of course, those in the â€Å"Leave† camp were outraged with the High Court’s decision. Like Theresa May, they believed that Parliament was attempting to obstruct the progression of Brexit. A Ukip donor accused the High Court of declaring war on British democracy (Maguire, 2016).[31] In reality, however, this was not the case; the High Court was merely upholding the British constitution as intended, by honouring the principle of parliamentary sovereignty (Weale, 2017)[32] and following the Rule of Law. Importance of the Rule of Law. On 29 March 2017, the Prime Minister wrote to the President of the European Council to notify the European Council of the United Kingdom’s intention to leave the European Unit and the triggering of Article 50 of the Treaty. Brexit is no longer a hypothetical question. It is a concrete fact – it is happening. An issue that has been brought to the front is the belief that the Government has the power, and right, to act on Brexit without Parliaments involvement. This is even more troubling as the very constitution is built upon Parliamentary sovereignty. The issue of human rights comes up as it can be dangerous, in a country where the legislature is mostly under the control of the executive, to leave it solely up to a sovereign Parliament with an absent constitution. If the Parliament can be avoided altogether, this can lead to an even worse situation overall and so highlights how important it was for the Supreme Court in Miller to stand up for and defend the power of Parliament over the executive.   Brexit is one of the most influential and far-reaching changes to the international social and political landscapes today. Brexit will shape Britain, and the international community, for years to come. It is for this reason that it is undeniable that this process should be founded in the rule of law. To comprehend the importance of the rule of law we must give it a clear definition. A well-known definition is that of Lord Bingham: â€Å"that all persons and authorities in the State, whether public or private, should be bound by and be entitled to the benefit of all laws publicly made, taking effect (generally) in the future and publicly administered in the courts.† The Venice Commission has identified the following 8 components of the rule of law: ‘(1) Accessibility of the law (that it be intelligible, clear and predictable); (2) Questions of legal right should be normally decided by law and not discretion; (3) Equality before the law; (4) Power must be exercised lawfully, fairly and reasonably; (5) Human rights must be protected; (6) Means must be provided to resolve disputes without undue cost or delay; (7) Trials must be fair, and (8) Compliance by the state with its obligations in international law as well as in national law.’ The importance of the rule of law is recognised in multiple international documents. For example, the preamble to the UN Declaration of Human Rights notes the importance of the rule of law in protecting human rights. The Treaty on European Union also couples ‘the rule of law and respect for human rights’. It is this human rights element that the remained of this short essay will focus on. Brexit will reform the social landscape of Britain and Europe. It is of paramount importance that the rule of law is respected in this reformation to ensure that fundamental rights, particularly those of minorities and vulnerable individuals, continue to be respected. This is especially true given that there has been much debate as to whether the Brexit vote was fuelled by xenophobia and racism. Research has shown that there was an increase in support for far-right groups during the Brexit campaign and following the murder of Jo Cox. There has also been an alleged escalation in hate crime targeting migrant communities as well an increase in anti-immigration rhetoric. The Brexit vote, coupled with Trump, and the rise of the far-right, summons fears surrounding the polarization of politics and the creeping rise of extremism. With this in mind, it is quite chilling to consider Lord Bingham’s thoughts on a system which is not founded on the rule of law: â€Å"The hallmark of a regime which flouts the rule of law are, alas, all too familiar: the midnight knock on the door, the sudden disappearance, the show trial, the subjection of prisoners to genetic experiments, the confession extracted by torture, the gulag and the concentration camp, the gas chamber, the practice of genocide and ethnic cleansing, the waging of aggressive wars.† In a time when international politics is becoming increasingly unclear and strained and communities are fraught with increased fear and racial tensions, now more than ever, the rule of law and the importance of Parliamentary Sovereignty must be respected. As noted by the Prime Minister, the task before the British nation is momentous but it should not be insurmountable. Britain post-Brexit has an unclear future and an undefined path. By adhering to the rule of law, the certainty, stability and protection that it provides will ensure that this difficult task is negotiated with the utmost respect for all peoples and their inalienable human rights. 3. The European Union (Notification of Withdrawal) Act 2017 Given that the Supreme Court had dismissed the government’s appeal, the government now needed Parliament’s approval to trigger Article 50. In order to receive this approval, the government introduced a new bill in Parliament. This bill was called the European Union (Notification of Withdrawal) Act 2017.Essentially, this bill would give Theresa May the power to trigger Article 50. However, Parliament had the power to reject the bill if it felt appropriate. This was again because of parliamentary sovereignty (Weale, 2017).[33] Despite that most voters voted ‘Leave’ in the referendum, this result was not legally binding and Parliament could ignore the referendum result. The principle of parliamentary sovereignty means that the ultimate power rests with Parliament, not the public nor the results of referendums. The public only have the power to elect MPs, and once elected, MPs can go against the wishes of their constituents and make their own decisions if they want to. MPs can even go against a referendum result, despite that this might cause great anger with the British public. As Dicey stated, â€Å"the electors can in the long run always enforce their will† (Dicey, 1915).[34] However,   all three decision making bodies of Parliament – the Queen, the House of Lords and the House of Commons – approved the Notification of Withdrawal Act (BBC, 2017).[35] The Queen gave the final green flag on 16 March 2017. This gave the Prime Minister the power trigger to Article 50 and inform the EU of the UK’s withdrawal. The government officially triggered Article 50 on 29 March 2017, when a UK envoy delivered a letter of withdrawal to the President of the European Council (BBC, 2017).[36] The issue of parliamentary sovereignty then took a back seat as the UK began exit negotiations with the EU. Of the 170,000 statutory instruments that have been sent to Parliament in the last 65 years, only seventeen have been rejected, and any substantive debate over individual instruments is a rare occurrence. Responsibility has been delegated for regulation both to the government and the European Union. For this reason, possibly up to sixty per cent of UK law may be derived from EU law in some way. Furthermore, for many years, legislative and technical expertise in the pertinent areas have again been delegated to Brussels. This leaves domestic civil servants under prepared to handle the of important decisions that will need to be made in the coming years. David Allen Green’s analysis is difficult to refute: â€Å"under the cloak of the referendum result there will be a power grab by Whitehall from Westminster. Those rejoicing at â€Å"taking back control† should be careful what they wish for. The executive is, as usual, wanting to take control away from Parliament.† On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. Does this mean that the claims of direct democracy, in the form of the referendum, trump the claims of Parliamentary representative democracy, with the paradoxical effect of giving more power to the executive? The greater part have affirmed that referenda are in and of themselves a product of Parliamentary authority and must accordingly rely on the statute which enables them. The 2015 EU referendum Act only called for the referendum to take place, without establishing how to approach it or the potential consequences. ‘Where, as in this case, implementation of a referendum result requires a change in the law of the land, and statute has not provided for that change, the change in the law must be made in the only way in which the UK constitution permits, namely through Parliamentary legislation.’ The actual political importance of a referendum is not subverted however. What is does assert is the basic dogma that, in a democracy, the people can speak through their representatives in Parliament. Nevertheless, direct democracy cannot be operationalised by giving undiluted power to the executive. 4. Conclusion This paper has discussed parliamentary sovereignty in the UK in the wake of Brexit. First, Section 1 introduced the concept of parliamentary sovereignty in the UK. This section explained that parliamentary sovereignty goes back to the 17th century, when the courts first enshrined the principle in the Bill of Rights. The section also drew attention to the rule that only Parliament can undo Acts of Parliament. I then discussed the Miller case in Section 2. In this case, members of the public argued that the government required Parliaments approval to leave the EU. The courts decided in favour of Millers side; that explained that Parliament was needed to trigger to Article 50 due to parliamentary sovereignty. The decision was controversial because some people saw it as an attempt to subvert the referendum result. Finally, Section 3 discussed the European Union Act 2017. This act that demonstrated the principle of parliamentary sovereignty. The government essentially asked Parliament for permission to trigger Article 50, and Parliament agreed by passing the act. In conclusion, the principle of parliamentary sovereignty was tested in the wake of Brexit. Ultimately however, courts respected the principle and gave Parliament the ultimate power over whether Britain should leave the EU. However, the future is still uncertain, as no-one yet knows what Brexit will look like. Perhaps a future Parliament will reverse the Brexit decision. After all, parliamentary sovereignty gives future Parliaments the right to reverse the decisions of previous Parliaments. What needs to be addressed is the potential consequneces that the referendum may have on Palimentary sovernety and represesentitive democracy throughout the UK. For this reason, Parliment needs to continue to be a central part of the process despite any predetermined preferences from the Government itself. Parliamentary sovereignty must remain intact as, for the many reasons stated, it is an integral part of the United Kingdom’s constitution, because its deliberate and representative functions and ability to hold the executive to account are defining features of the United Kingdom’s enduring constitution. 5. References Barber, N.W., 2011. The afterlife of Parliamentary sovereignty. International Journal of Constitutional Law, 9(1), pp.144–154. Barnett, H., 2017. Constitutional and administrative law, Taylor & Francis. BBC, 2017. BBC News website. Available at: http://www.bbc.com/news [Accessed July 14, 2017]. Bradley, A., 2011. The Sovereignty of Parliament–Form or Substance? The Changing Constitution, 23, pp.54–56. Dicey, A.V., 1915. Introduction to the Study of the Law of the Constitution 8th ed., Liberty Classics. EU, 2007. Treaty on European Union, Freehills, H.S., 2016. Judicial review litigation over the correct constitutional process for triggering Article 50 TEU. Lexology. Available at: http://www.lexology.com/library/detail.aspx?g=f43e102f-ea09-4449-b781-a35ecfe628fe [Accessed July 13, 2017]. Goldsworthy, J., 2010. Parliamentary sovereignty: contemporary debates, Cambridge University Press. House of Lords, 1965. Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75, House of Lords, 1610. Proclamations, Case of [1610] EWHC KB J22, Available at: http://www.bailii.org/ew/cases/EWHC/KB/1610/J22.html. Maguire, P., 2016. Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling. The Guardian. Available at: https://www.theguardian.com/politics/2016/nov/06/brexit-this-is-what-sovereignty-looks-like#img-1 [Accessed July 13, 2017]. Pannick, D., 2016. Why giving notice of withdrawal from the EU requires act of parliament. The Times. Available at: https://www.thetimes.co.uk/article/c8985886-3df9-11e6-a28b-4ed6c4bdada3. Parliament of England, 1689. English Bill of Rights, Supreme Court, 2016. Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†), Available at: http://www.croftsolicitors.com/wp-content/uploads/2016/11/139459-UKSC-2016-0196-Skeleton-for-Expat-Interveners-final-written-case-2.pdf. Supreme Court, 2017. Miller v Secretary of State for Exiting the European Union, London. Available at: https://www.supremecourt.uk/cases/docs/uksc-2016-0196-judgment.pdf. Wade, W., 1961. Administrative Law, London: Oxford University Press. Weale, A., 2017. The Democratic Duty to Oppose Brexit. The Political Quarterly, 88(2), pp.170–181. [1] BBC [2] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 177 [3] Hilaire Barnett, Constitutional and administrative law (Taylor & Francis 2017) [4] House of Lords, Case of [1610] EWHC KB J22 [5] Jeffrey Goldsworthy, Parliamentary sovereignty: contemporary debates (Cambridge University Press 2010) [6] Parliament of England, English Bill of Rights [7] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [8] Anthony Bradley, ‘The Sovereignty of Parliament–Form or Substance?’ (2011) The Changing Constitution 54 [9] Nicholas Barber, ‘The afterlife of Parliamentary sovereignty’ (2011) International Journal of Constitutional Law 149 [10] Supreme Court, Miller v Secretary of State for Exiting the European Union [11] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [12] EU, Treaty on European Union [13] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [14] BBC [15] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [16] BBC [17] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [18] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) 21 [19] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) [20] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [21] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [22] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [23] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [24] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [25] Supreme Court, Miller v Secretary of State for Exiting the European Union 85 [26] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [27] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [28] William Wade, Administrative Law (Oxford University Press 1961) [29] Supreme Court, Miller v Secretary of State for Exiting the European Union [30] Supreme Court, Miller v Secretary of State for Exiting the European Union [31] Patrick Maguire, Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling [32] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [33] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [34] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [35] BBC [36] BBC Parliamentary Sovereignty in the UK in the Wake of Brexit Parliamentary Sovereignty in the UK in the Wake of Brexit POn 23 June 2016, the UK government held a referendum to decide whether the country should leave the EU. The majority citizens voted for Brexit (51.89 per cent to 48.11 per cent) with a turnout of 72%, however, they thoroughly fell behind in Scottish and Northern Irish tallies. Be that as it may, the Government was still expected to trigger Article 50 of the Treaty on European Union (TEU) as soon as possible, without the express permission from Parliament. The Prime Minister at the time, David Cameron, had promised that he would follow through with the outcome, even if that meant leaving the EU (BBC, 2017).[1] However, the situation was not as straightforward as presented by the â€Å"Leave† campaign. The principle of parliamentary sovereignty meant that the referendum result had no legal binding. Therefore, the Prime Minister and government were free to ignore the referendum result if they saw fit. Furthermore, some argued that the government had no right to trigger a leave; only Parliament could do so, as a result of the principle parliamentary sovereignty (Weale, 2017).[2] This paper discusses the topic of parliamentary sovereignty in the UK, particularly in the wake of Brexit, and briefly touches on some social consequences had Parliamentary Sovereignty not been respected. The structure of this paper is therefore as follows: First, Section 1 briefly discusses the history behind parliamentary sovereignty in the UK. Then, Section 2 discusses the Miller Case, a case where the High Court upheld parliamentary sovereignty in the wake of Brexit. Finally, Section 3 explores the European Union (Notification of Withdrawal) Act 2017, an Act of Parliament that grants the government power to leave the EU. 1. The Principle of Parliamentary Sovereignty The idea of parliamentary sovereignty was conceived circa the Case of Proclamations in 1608 (Barnett, 2017).[3] This was a court decision that reduced the power of Monarchs. Essentially, the courts decided that moving forward, Kings and Queens would have to obtain Parliament’s permission to change laws. Specifically, the Case of Proclamations stated that â€Å"the King cannot change any part of the common law [†¦.] without parliament† (House of Lords, 1610).[4] Following this, the English Civil War occurred 1642–1651, where Parliamentarians fought against Royalists for ideals such as parliamentary sovereignty. The Parliamentarians were victorious on such occasion and thus began the ‘Glorious Revolution’ in 1688, which established parliamentary sovereignty in England (Goldsworthy, 2010).[5] Then, in 1689, parliamentary sovereignty was enshrined in the Bill of Rights. Similarly to the Case of Proclamations, this bill requires Monarchs to obtain pe rmission from Parliament before changing laws. Specifically, the Bill of Rights said, â€Å"Suspending the laws or the execution of laws by regal authority without consent of Parliament is illegal† (Parliament of England, 1689).[6] In modern day Britain, Parliament consists of three main decision making bodies: the Sovereign (the monarch, i.e. the King or Queen), the House of Lords (i.e. unelected members of parliament), and the House of Commons (i.e. elected Members of Parliament, or MPs). These three bodies form the highest power in the UK. The fact that Parliament has supreme power is known as parliamentary sovereignty. In the words of Legal commentator Albert Dicey, parliamentary sovereignty gives Parliament the power â€Å"to make or unmake any law whatever† (Dicey, 1915, p.3).[7] The only limits to parliamentary sovereignty are those that Parliament sets itself (Bradley, 2011).[8] An example of this self-enforced limit is Parliament’s subordination of the UK to the EU. This came into effect in 1972, when Parliament signed the European Communities Act, under which the UK was compelled to follow EU law (Barber, 2011).[9] Parliament also has the power to lift its self-imposed limits. For exampl e, Brexit means that Parliament will repeal the European Communities Act, thus ending the EU’s control over the UK (Supreme Court, 2017).[10] It is also important to note that only Parliament can repeal Parliamentary acts. Essentially, the government and Queen cannot repeal Acts of Parliament without Parliament’s permission. 23. Parliamentary sovereignty has been a significant part of many cases and has repeatedly been called upon during cases of importance. A quote from Lord Bingham of Cornhill in R (Jackson) v Attorney General [2005] UKHL 56; [2006] 1 AC 262 at para. [9] encapsulates this significance perfectly: The bedrock of the British constitution is the supremacy of the Crown in Parliament. 2. The Miller Case Following the Brexit referendum in June 2016, Times journalist David Pannick noted that the government could not trigger Article 50 by itself; the government would have to first obtain permission from Parliament (Pannick, 2016).[11] This was because of the principle of parliamentary sovereignty. Specifically, Pannick noted that Parliament had agreed to the European Communities Act in 1972, and because only Parliament can reverse its own decisions, and therefore only Parliament can repeal the act and withdraw from the EU. He also drew attention to Article 50 of the Treaty on European Union, which says, â€Å"any member state may decide to withdraw from the union in accordance with its own constitutional requirements† (EU, 2007).[12] Pannick argued that since parliamentary sovereignty is a constitutional requirement, the EU would not accept the UK’s withdrawal without parliamentary approval (Pannick, 2016).[13] Theresa May was dismissive of these claims. She asserted that they were a tactic to delay Brexit and subvert democracy (BBC, 2017).[14] She also stated that the government did not need parliamentary approval to trigger Article 50 (Freehills, 2016).[15] Notably, Theresa May stated, â€Å"It is up to the Government to trigger Article 50 and the Government alone† (BBC, 2017).[16] Many disagreed with Theresa May, as they believed that withdrawal from the EU without Parliament’s permission would be unlawful (Weale, 2017).[17] Several members of the public felt so strongly about this that took legal action against the government. Miller v Secretary of State for Exiting the European Union, or the Miller case as it was known informally, was heard in the High Court of Justice. Miller argued that Parliamentary involvement was necessary because: â€Å"By enacting the 1972 Act, Parliament surrendered aspects of its legislative sovereignty and conferred the same upon (what are now) the EU Institutions. Such conferral cannot be undone [†¦] without Parliamentary consent.† (Supreme Court, 2016, p.21)[18] In plain English, Miller’s argument was that considering Parliament surrendered power to the EU in 1972, only Parliament could take this power back (Supreme Court, 2016).[19] The government disagreed with this claim. They believed that once the UK leaves the EU, the European Communities Act 1972 would simply cease to apply, because former treaties would not exist (Supreme Court, 2016; Weale, 2017).[20] Furthermore, the government argued that they had the royal prerogative to override parliamentary sovereignty. The royal prerogative is an old power that allows governments to make decisions without Parliament, in exceptional circumstances (Freehills, 2016).[21] The government also noted a rule that â€Å"the making and unmaking of treaties is [†¦] within the competence of the government† (Supreme Court, 2017, p.84)[22] The case was debated in the High Court for several weeks until the High Court delivered its verdict on 3 November 2016. The High Court ruled in favour of Miller: the government had to obtain parliamentary authority to trigger Article 50. The High Court had agreed with Miller’s arguments about the principle of parliamentary sovereignty (Supreme Court, 2017).[23] The court explained that because of parliamentary sovereignty, only Parliament could repeal the European Communities Act. This is because only Parliament can repeal an Act of Parliament. The High Court also explained that Article 50 would nullify several rights of UK citizens (Supreme Court, 2017).[24] These rights included the right of UK citizens to live and work freely in other EU countries, and the right to 20 days paid holiday under the Working Time Directive 2003. Parliament put these rights in place when it passed the European Communities Act in 1972. The High Court also ruled against the government’s right to use the royal prerogative (Supreme Court, 2017).[25] To explain why, the High Court cited the case of Burmah Oil Co (Burma Trading) Ltd v Lord Advocate [1965] AC 75, 101. This case involved use of the royal prerogative. Lord Reid, dismissed the royal prerogative as a â€Å"relic of a past age† (House of Lords, 1965, p.101).[26] Lord Reid also explained that the royal prerogative is â€Å"only available for a case not covered by statute† (p.101).[27] Typically, the royal prerogative is only for situations such as declaring war, dissolving parliament and governing colonies (Wade, 1961).[28] So, in Miller’s case, the High Court explained that a royal prerogative was inappropriate for triggering Brexit. Therefore, the government did not have the power to trigger Article 50 without Parliament’s approval. The government was unhappy with the High Court’s decision and chose to appeal it, and as a result the case went to the Supreme Court. Ultimately, the Supreme Court dismissed the government’s appeal, citing the same reason as the High Court (Supreme Court, 2017).[29] Essentially, the court explained, the government in 1972 needed Parliament’s approval to sign the 1972 Accession Treaty. This meant that present-day government also needed Parliament’s approval to repeal this treaty (Supreme Court, 2017).[30] Of course, those in the â€Å"Leave† camp were outraged with the High Court’s decision. Like Theresa May, they believed that Parliament was attempting to obstruct the progression of Brexit. A Ukip donor accused the High Court of declaring war on British democracy (Maguire, 2016).[31] In reality, however, this was not the case; the High Court was merely upholding the British constitution as intended, by honouring the principle of parliamentary sovereignty (Weale, 2017)[32] and following the Rule of Law. Importance of the Rule of Law. On 29 March 2017, the Prime Minister wrote to the President of the European Council to notify the European Council of the United Kingdom’s intention to leave the European Unit and the triggering of Article 50 of the Treaty. Brexit is no longer a hypothetical question. It is a concrete fact – it is happening. An issue that has been brought to the front is the belief that the Government has the power, and right, to act on Brexit without Parliaments involvement. This is even more troubling as the very constitution is built upon Parliamentary sovereignty. The issue of human rights comes up as it can be dangerous, in a country where the legislature is mostly under the control of the executive, to leave it solely up to a sovereign Parliament with an absent constitution. If the Parliament can be avoided altogether, this can lead to an even worse situation overall and so highlights how important it was for the Supreme Court in Miller to stand up for and defend the power of Parliament over the executive.   Brexit is one of the most influential and far-reaching changes to the international social and political landscapes today. Brexit will shape Britain, and the international community, for years to come. It is for this reason that it is undeniable that this process should be founded in the rule of law. To comprehend the importance of the rule of law we must give it a clear definition. A well-known definition is that of Lord Bingham: â€Å"that all persons and authorities in the State, whether public or private, should be bound by and be entitled to the benefit of all laws publicly made, taking effect (generally) in the future and publicly administered in the courts.† The Venice Commission has identified the following 8 components of the rule of law: ‘(1) Accessibility of the law (that it be intelligible, clear and predictable); (2) Questions of legal right should be normally decided by law and not discretion; (3) Equality before the law; (4) Power must be exercised lawfully, fairly and reasonably; (5) Human rights must be protected; (6) Means must be provided to resolve disputes without undue cost or delay; (7) Trials must be fair, and (8) Compliance by the state with its obligations in international law as well as in national law.’ The importance of the rule of law is recognised in multiple international documents. For example, the preamble to the UN Declaration of Human Rights notes the importance of the rule of law in protecting human rights. The Treaty on European Union also couples ‘the rule of law and respect for human rights’. It is this human rights element that the remained of this short essay will focus on. Brexit will reform the social landscape of Britain and Europe. It is of paramount importance that the rule of law is respected in this reformation to ensure that fundamental rights, particularly those of minorities and vulnerable individuals, continue to be respected. This is especially true given that there has been much debate as to whether the Brexit vote was fuelled by xenophobia and racism. Research has shown that there was an increase in support for far-right groups during the Brexit campaign and following the murder of Jo Cox. There has also been an alleged escalation in hate crime targeting migrant communities as well an increase in anti-immigration rhetoric. The Brexit vote, coupled with Trump, and the rise of the far-right, summons fears surrounding the polarization of politics and the creeping rise of extremism. With this in mind, it is quite chilling to consider Lord Bingham’s thoughts on a system which is not founded on the rule of law: â€Å"The hallmark of a regime which flouts the rule of law are, alas, all too familiar: the midnight knock on the door, the sudden disappearance, the show trial, the subjection of prisoners to genetic experiments, the confession extracted by torture, the gulag and the concentration camp, the gas chamber, the practice of genocide and ethnic cleansing, the waging of aggressive wars.† In a time when international politics is becoming increasingly unclear and strained and communities are fraught with increased fear and racial tensions, now more than ever, the rule of law and the importance of Parliamentary Sovereignty must be respected. As noted by the Prime Minister, the task before the British nation is momentous but it should not be insurmountable. Britain post-Brexit has an unclear future and an undefined path. By adhering to the rule of law, the certainty, stability and protection that it provides will ensure that this difficult task is negotiated with the utmost respect for all peoples and their inalienable human rights. 3. The European Union (Notification of Withdrawal) Act 2017 Given that the Supreme Court had dismissed the government’s appeal, the government now needed Parliament’s approval to trigger Article 50. In order to receive this approval, the government introduced a new bill in Parliament. This bill was called the European Union (Notification of Withdrawal) Act 2017.Essentially, this bill would give Theresa May the power to trigger Article 50. However, Parliament had the power to reject the bill if it felt appropriate. This was again because of parliamentary sovereignty (Weale, 2017).[33] Despite that most voters voted ‘Leave’ in the referendum, this result was not legally binding and Parliament could ignore the referendum result. The principle of parliamentary sovereignty means that the ultimate power rests with Parliament, not the public nor the results of referendums. The public only have the power to elect MPs, and once elected, MPs can go against the wishes of their constituents and make their own decisions if they want to. MPs can even go against a referendum result, despite that this might cause great anger with the British public. As Dicey stated, â€Å"the electors can in the long run always enforce their will† (Dicey, 1915).[34] However,   all three decision making bodies of Parliament – the Queen, the House of Lords and the House of Commons – approved the Notification of Withdrawal Act (BBC, 2017).[35] The Queen gave the final green flag on 16 March 2017. This gave the Prime Minister the power trigger to Article 50 and inform the EU of the UK’s withdrawal. The government officially triggered Article 50 on 29 March 2017, when a UK envoy delivered a letter of withdrawal to the President of the European Council (BBC, 2017).[36] The issue of parliamentary sovereignty then took a back seat as the UK began exit negotiations with the EU. Of the 170,000 statutory instruments that have been sent to Parliament in the last 65 years, only seventeen have been rejected, and any substantive debate over individual instruments is a rare occurrence. Responsibility has been delegated for regulation both to the government and the European Union. For this reason, possibly up to sixty per cent of UK law may be derived from EU law in some way. Furthermore, for many years, legislative and technical expertise in the pertinent areas have again been delegated to Brussels. This leaves domestic civil servants under prepared to handle the of important decisions that will need to be made in the coming years. David Allen Green’s analysis is difficult to refute: â€Å"under the cloak of the referendum result there will be a power grab by Whitehall from Westminster. Those rejoicing at â€Å"taking back control† should be careful what they wish for. The executive is, as usual, wanting to take control away from Parliament.† On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. Does this mean that the claims of direct democracy, in the form of the referendum, trump the claims of Parliamentary representative democracy, with the paradoxical effect of giving more power to the executive? The greater part have affirmed that referenda are in and of themselves a product of Parliamentary authority and must accordingly rely on the statute which enables them. The 2015 EU referendum Act only called for the referendum to take place, without establishing how to approach it or the potential consequences. ‘Where, as in this case, implementation of a referendum result requires a change in the law of the land, and statute has not provided for that change, the change in the law must be made in the only way in which the UK constitution permits, namely through Parliamentary legislation.’ The actual political importance of a referendum is not subverted however. What is does assert is the basic dogma that, in a democracy, the people can speak through their representatives in Parliament. Nevertheless, direct democracy cannot be operationalised by giving undiluted power to the executive. 4. Conclusion This paper has discussed parliamentary sovereignty in the UK in the wake of Brexit. First, Section 1 introduced the concept of parliamentary sovereignty in the UK. This section explained that parliamentary sovereignty goes back to the 17th century, when the courts first enshrined the principle in the Bill of Rights. The section also drew attention to the rule that only Parliament can undo Acts of Parliament. I then discussed the Miller case in Section 2. In this case, members of the public argued that the government required Parliaments approval to leave the EU. The courts decided in favour of Millers side; that explained that Parliament was needed to trigger to Article 50 due to parliamentary sovereignty. The decision was controversial because some people saw it as an attempt to subvert the referendum result. Finally, Section 3 discussed the European Union Act 2017. This act that demonstrated the principle of parliamentary sovereignty. The government essentially asked Parliament for permission to trigger Article 50, and Parliament agreed by passing the act. In conclusion, the principle of parliamentary sovereignty was tested in the wake of Brexit. Ultimately however, courts respected the principle and gave Parliament the ultimate power over whether Britain should leave the EU. However, the future is still uncertain, as no-one yet knows what Brexit will look like. Perhaps a future Parliament will reverse the Brexit decision. After all, parliamentary sovereignty gives future Parliaments the right to reverse the decisions of previous Parliaments. What needs to be addressed is the potential consequneces that the referendum may have on Palimentary sovernety and represesentitive democracy throughout the UK. For this reason, Parliment needs to continue to be a central part of the process despite any predetermined preferences from the Government itself. Parliamentary sovereignty must remain intact as, for the many reasons stated, it is an integral part of the United Kingdom’s constitution, because its deliberate and representative functions and ability to hold the executive to account are defining features of the United Kingdom’s enduring constitution. 5. References Barber, N.W., 2011. The afterlife of Parliamentary sovereignty. International Journal of Constitutional Law, 9(1), pp.144–154. Barnett, H., 2017. Constitutional and administrative law, Taylor & Francis. BBC, 2017. BBC News website. Available at: http://www.bbc.com/news [Accessed July 14, 2017]. Bradley, A., 2011. The Sovereignty of Parliament–Form or Substance? The Changing Constitution, 23, pp.54–56. Dicey, A.V., 1915. Introduction to the Study of the Law of the Constitution 8th ed., Liberty Classics. EU, 2007. Treaty on European Union, Freehills, H.S., 2016. Judicial review litigation over the correct constitutional process for triggering Article 50 TEU. Lexology. Available at: http://www.lexology.com/library/detail.aspx?g=f43e102f-ea09-4449-b781-a35ecfe628fe [Accessed July 13, 2017]. Goldsworthy, J., 2010. Parliamentary sovereignty: contemporary debates, Cambridge University Press. House of Lords, 1965. Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75, House of Lords, 1610. Proclamations, Case of [1610] EWHC KB J22, Available at: http://www.bailii.org/ew/cases/EWHC/KB/1610/J22.html. Maguire, P., 2016. Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling. The Guardian. Available at: https://www.theguardian.com/politics/2016/nov/06/brexit-this-is-what-sovereignty-looks-like#img-1 [Accessed July 13, 2017]. Pannick, D., 2016. Why giving notice of withdrawal from the EU requires act of parliament. The Times. Available at: https://www.thetimes.co.uk/article/c8985886-3df9-11e6-a28b-4ed6c4bdada3. Parliament of England, 1689. English Bill of Rights, Supreme Court, 2016. Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†), Available at: http://www.croftsolicitors.com/wp-content/uploads/2016/11/139459-UKSC-2016-0196-Skeleton-for-Expat-Interveners-final-written-case-2.pdf. Supreme Court, 2017. Miller v Secretary of State for Exiting the European Union, London. Available at: https://www.supremecourt.uk/cases/docs/uksc-2016-0196-judgment.pdf. Wade, W., 1961. Administrative Law, London: Oxford University Press. Weale, A., 2017. The Democratic Duty to Oppose Brexit. The Political Quarterly, 88(2), pp.170–181. [1] BBC [2] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 177 [3] Hilaire Barnett, Constitutional and administrative law (Taylor & Francis 2017) [4] House of Lords, Case of [1610] EWHC KB J22 [5] Jeffrey Goldsworthy, Parliamentary sovereignty: contemporary debates (Cambridge University Press 2010) [6] Parliament of England, English Bill of Rights [7] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [8] Anthony Bradley, ‘The Sovereignty of Parliament–Form or Substance?’ (2011) The Changing Constitution 54 [9] Nicholas Barber, ‘The afterlife of Parliamentary sovereignty’ (2011) International Journal of Constitutional Law 149 [10] Supreme Court, Miller v Secretary of State for Exiting the European Union [11] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [12] EU, Treaty on European Union [13] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [14] BBC [15] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [16] BBC [17] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [18] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) 21 [19] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) [20] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [21] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [22] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [23] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [24] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [25] Supreme Court, Miller v Secretary of State for Exiting the European Union 85 [26] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [27] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [28] William Wade, Administrative Law (Oxford University Press 1961) [29] Supreme Court, Miller v Secretary of State for Exiting the European Union [30] Supreme Court, Miller v Secretary of State for Exiting the European Union [31] Patrick Maguire, Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling [32] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [33] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [34] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [35] BBC [36] BBC

A Psychological Analysis of My Writing :: Writing Education Teaching Essays

A Psychological Analysis of My Writing "God! I've always hated this stupid shrink's office. Everything is placed so god damned precisely. Everything is so god damn clean. It's as if the bastard is striving for perfection. Strive. That's all he can do. Thinks he knows everything. Thinks he knows how I think, when even I don't know how I think..." "Man, this fellow's office is immaculate. I can't see a speck of dust anywhere. Christ, this guy is really anal. Holy Ghost! Now, I'm starting to sound like freakin' Freud. The man's got me thinking like a shrink. This isn't good. No, not at all..." "Hey! What's that!?! It's my flippin' file. The anal-retentive bastard left out my flippin' file. Well, it's about me...and I have a right to see what he's saying about me--don't I? Heck yes!" "Let's see here. What's this? Oh, it's that stupid exercise he had me do. Geez! I wrote that over twelve weeks ago. I don't know why I had to do that moronic exercise. It's like he's going to find out anything about me in a two page piece of exposition using an extended metaphor for my conception of life at a university. Jesus, I can't even remember what metaphor I used. I hope I compared the university to a colon, because of all the crap I have to deal with. Alright, maybe school isn't that bad. Well, since the shrink is usually fashionably late, I might as well read the damn thing..." -------------------------------------------------------------------------------- Last summer, a few of my friends and I went on a canoe trip in the Quetico. I had never been on a canoe trip prior to this excursion, so I only had a vague idea of what I would be subjected to on such a trip. I naively believed that the whole affair would be something like a vacation absent the amenities, but, as I soon discovered, it was anything but a vacation. At the end of our first day of paddling, I was wet and exhausted. From this rather inauspicious beginning, my vacation devolved quickly into a hellacious "forced march." You see, my friend, who planned the trip, had set a destination that he thought that we should reach by the end of the third day and that if we didn't reach this destination we couldn't claim to be men. Initially, I thought that the whole trip was a waste of time and money; I couldn't believe that anyone, masochists excluded, would want to participate in such an affair.

Book Review of The Things they Carried Essay -- essays research pape

Tim O’Brien’s, The Things they Carried is a riveting tale of struggle and sacrifice, self indulgence and self pity, and the intrapersonal battles that reeked havoc on even the most battle tested soldiers. O’Brien is able to express these ideas through eloquent writing and descriptive language that makes the reader feel as if he were there. The struggle to avoid cowardice is a prevailing idea in all of O’Brien’s stories.   Ã‚  Ã‚  Ã‚  Ã‚  In â€Å"On the Rainy River†, O’Brien writes of intrapersonal struggle in its most profound form. The gripping torture of indecision seemed to paralyze Lt. Jimmy Cross in every move he made. Fear is what kept him away from the war, and fear is what made him join his countrymen in battle. A pacifist who did not support the war, the narrator Jimmy Cross was forced to make the difficult decision of what was more important to him. In the end, it was Cross’s reluctancy to deal with the consequences of pacifism which made his decision to go to war. That indecision seems to stay with Cross throughout the book and causes him much hardship in many of the short stories.   Ã‚  Ã‚  Ã‚  Ã‚  The struggle to avoid cowardice is very important to the narrator. In his time near the Canadian border, he has much time for self reflection. That self reflection seemed to be something very necessary for Lt. Jimmy Cross. While there, he discovered that devotion to his family, his hometown, and his country was stronger than devotion to his own mora...

Negative Effects of Tv on Family Life

Negative Effects of TV The television has many effects on family life and the individual, causing family bonds to unravel and the individual to become naive of their surroundings. The TV keeps one hooked for hours on end, causing family relationships to diminish and personal relationships to weaken. Not only does the TV seem to be a good alternative to conversations and interactions amongst one another, but it also helps to create a gap between the fictional world of TV and reality.Since the invention of the home television, it has become a crucial part in everyday household life. Children spend less time with family, because it is simply easier to sit down and be entertained by the TV. †The time spent next to it [the TV] exceeds the amount of time spent together with any other family member. † (Wattermann) Watching TV has a major effect on the way a child communicates with other family members and friends, distancing them from real-world situations and problems. Parents spend long hours working and want an effective suppressant for their children. Contemporary parents work a lot, but when they come back home they are not eager to spend time with their child†¦Ã¢â‚¬  (Wattermann) Even adults fall into the attraction of taking themselves out of their childs’ life, in order to relax or gain the free time they long desire. The effect the TV has on the family has been negative in comparison to the original intention of bringing the TV into the home, back in the 1940s. The depiction of the family watching TV together has changed, and now with multiply TVs present in a home, the separation and disfunction of the family has increased.TV also has a negative effect on the individual, because it takes away from potential relationships and also promotes bad behavior and aggressions as seen on violent television shows. What is being watched on television has the potential to influencing negative behavior, within the child or even adult. In an articl e from the AAP or the American Association of Pediatrics, it was noted that, â€Å"Extensive research evidence indicates that media violence can contribute to aggressive behavior, desensitization to violence, nightmares, and fear of being harmed. † (Pediatrics Vol. 108 No. ) The violence seen on TV, can lead to violent acts later on. Individuals are affected by what they see on TV and can be influenced by the suggestive nature that is described in almost every TV program. â€Å"Even in G-rated, animated movies and DVDs, violence is common† (Boyse, RN). The TV violence has an effect on people and children of all ages, and even though some programs are educational and beneficial for the development and growth of the child, there are so many other programs going on at the same time that contradict the idea of â€Å"good TV†. Television watching also has a major impact on the self-image one has of themself.The TV paints a false image of what the normal and accepted person should look like. The person watching, therefore gets sucked into the mindset that they have to be like the well-toned models seen on tv, this creates many different problems. Insecurities within the individual flourish and they are constantly bombarded with images of how they should be, in order to fit into today’s society. While watching constant images of healthy women and men makes some people immediately jump off the couch and start their â€Å"cardio routine† some sit back and envy what they simply will never have.Ironically, this leads to eating disorders and obesity. â€Å"People, who spend hours and hours in front of the TV sets, are under very high risk of becoming overweight and obese. † (API Heathline) Either way, false advertisement of the way someone should be perceived has a negative effect on the viewer. In general, the content on TV impacts who were are and who we want to become in order to fit into society. Another factor involved in tel evision watching, is the amount and the persistence of commercials.Commercials make up a majority of television air time, trying to influence people to spend time and resources on products and new inventions that will make you better fit into society. For example, food commercials are constantly influencing people to make new recipes or to go to the newest most delicious restaurant in town. Other commercials such as the shopping channel become appealing to the older audience who are alone and constantly craving new things. This leads to hording and other disorders, including the addiction of television watching in itself.Commercials and news articles also persuade people in terms of politics, economic issues, and social influences therefore inducting the one-way nature of the viewers. If people constantly go to the TV for current updates on news and other current events then it deters the need to communicate with one another and create the social relationships needed to have a cohes ive balance in life. Another problem that arises with TV is the effect it has on one psychologically. Kids spend many hours in front of the TV, especially over long periods of isolation. Some adults can argue that the constant atching of television is the beginning of a new age of addiction. â€Å"Studies about negative effects of television addiction show the TV addicts’ people through its tranquilizing numbing affect, causing them to relax, become drowsy, and then desire to watch more TV. † (Parenting-Healthy-Children) Watching TV seems to have the same effects that habit- forming narcotics have on the individual. When watching hours upon hours of TV, one is quickly relaxed and put into a state of obliviousness to the outside world, therefore having similar effects of mind altering drugs.TV watching has many effects on the viewer and can lead to many social and personal problems. Family relationships, individual self- consciousness, and violent/ inappropriate subject matter all lead to the conclusion that too much television can be harmful to our society. TV is readily available to every one of all ages, and the majority of the material is geared toward a more mature audience. Over time, TV has changed dramatically from mostly family-oriented TV programs to programs geared to different age groups, in order to attract different audiences. Children and TV: The Negative Effects of Television. †Ã‚  Children and TV: The Negative Effects of Television. N. p. , n. d. Web. 13 Feb. 2013. â€Å"Media Violence. †Ã‚  Media Violence. N. p. , n. d. Web. 13 Feb. 2013. â€Å"Bad Effects Of Watching Too Much TV | Academic Programs International a Health Line. â€Å"Academic Programs International Health Line Bad Effects Of Watching Too Much TV Comments. N. p. , n. d. Web. 13 Feb. 2013. â€Å"The Negative Effects of Television Addiction and Computer Addiction. †Ã‚  The Negative Effects of TelevisionAddiction and Computer Addiction. N. p. , n. d. Web. 13 Feb. 2013.

Shadow Kiss Chapter 18

Eighteen EVERYTHING BECAME FUZZY after that. I had vague impressions of moving in and out of consciousness, of people saying my name, and of being in the air again. Eventually, I woke up in the school's infirmary and found Dr. Olendzki looking down at me. â€Å"Hello, Rose,† she said. She was a middle-aged Moroi and often joked that I was her number one patient. â€Å"How are you feeling?† The details of what had happened came back. The faces. Mason. The other ghosts. The terrible pain in my head. All of it was gone. â€Å"Fine,† I said, half-surprised to be saying those words. For a moment, I wondered if maybe it had all been a dream. Then I looked beyond her and saw Dimitri and Alberta looming nearby. The looks on their faces told me the events on the plane had indeed been real. Alberta cleared her throat, and Dr. Olendzki glanced back. â€Å"May we?† Alberta asked. The doctor nodded, and the other two stepped forward. Dimitri, as always, was a balm to me. No matter what happened, I always felt a little safer in his presence. Yet even he hadn't been able to stop what had happened at the airport. When he looked at me like he was now, with an expression of such tenderness and concern, it triggered mixed feelings. Part of me loved that he cared so much. The other part wanted to be strong for him and didn't want to make him worry. â€Å"Rose†¦Ã¢â‚¬  began Alberta uncertainly. I could tell she had no clue how to go about this. What had happened was beyond her realm of experience. Dimitri took over. â€Å"Rose, what happened back there?† Before I could utter a word, he cut me off. â€Å"And do not say it was nothing this time.† Well, if I couldn't fall back on that answer, then I didn't know what to say. Dr. Olendzki pushed her glasses up the bridge of her nose. â€Å"We only want to help you.† â€Å"I don't need any help,† I said. â€Å"I'm fine.† I sounded just like Brandon and Brett. I was probably only one step away from saying, â€Å"I fell.† Alberta finally regained herself. â€Å"You were fine when we were in the air. When we landed, you were most definitely not fine.† â€Å"I'm fine now,† I replied stonily, not meeting their eyes. â€Å"What happened then?† she asked. â€Å"Why the screaming? What did you mean when you said we needed to make ‘them' go away?† I briefly considered my other fallback answer, the one about stress. That sounded completely stupid now. So, again, I said nothing. To my surprise, I felt tears build up in my eyes. â€Å"Rose,† murmured Dimitri, voice as soft as silk against my skin. â€Å"Please.† Something in that cracked me. It was so hard for me to stand against him. I turned my head and stared at the ceiling. â€Å"Ghosts,† I whispered. â€Å"I saw ghosts.† None of them had expected that, but honestly, how could they have? Heavy silence fell. Finally, Dr. Olendzki spoke in a faltering voice. â€Å"W-what do you mean?† I swallowed. â€Å"He's been following me for the last couple of weeks. Mason. On campus. I know it sounds crazy – but it's him. Or his ghost. That's what happened with Stan. I locked up because Mason was there, and I didn't know what to do. On the plane†¦ I think he was there too †¦ and others. But I couldn't exactly see them when we were in the air. Just glimpses†¦ and the headache. But when we landed in Martinville, he was there in full form. And – and he wasn't alone. There were others with him. Other ghosts.† A tear escaped from my eye, and I hastily wiped at it, hoping none of them had seen it. I waited then, not sure what to expect. Would someone laugh? Tell me I was crazy? Accuse me of lying and demand to know what had really happened? â€Å"Did you know them?† Dimitri asked finally. I turned back and actually met his eyes. They were still serious and concerned, no mockery. â€Å"Yeah †¦ I saw some of Victor's guardians and the people from the massacre. Lissa's†¦Lissa's family was there too.† Nobody said anything after that. They all just sort of exchanged glances, hoping perhaps that one of the others might shed light on all this. Dr. Olendzki sighed. â€Å"Could I speak with the two of you privately?† The three of them stepped out of the examining room, shutting the door behind them. Only it didn't quite catch. Scrambling off the bed, I crossed the room and stood by the door. The tiny crack was just enough for my dhampir hearing to pick up the conversation. I felt bad about eavesdropping, but they were talking about me, and I couldn't shake the feeling that my future was on the line here. † – obvious what's going on,† hissed Dr. Olendzki. It was the first time I'd ever heard her sound so irate. With patients, she was the picture of serenity. It was hard to imagine her angry, but she was clearly pissed off now. â€Å"That poor girl. She's undergoing post-traumatic stress disorder, and it's no wonder after everything that's happened.† â€Å"Are you sure?† asked Alberta. â€Å"Maybe it's something else†¦Ã¢â‚¬  But as her words trailed off, I could tell she didn't really know of anything else that would explain it. â€Å"Look at the facts: a teenage girl who witnessed one of her friends getting killed and then had to kill his killer. You don't think that's traumatic? You don't think that might have had the tiniest effect on her?† â€Å"Tragedy is something all guardians have to deal with,† said Alberta. â€Å"Maybe there's not much to be done for guardians in the field, but Rose is still a student here. There are resources that can help her.† â€Å"Like what?† asked Dimitri. He sounded curious and concerned, not like he was challenging her. â€Å"Counseling. Talking to someone about what happened can do worlds of good. You should have done that as soon as she got back. You should do it for the others who were with her while you're at it. Why doesn't anyone think of these things?† â€Å"It's a good idea,† said Dimitri. I recognized the tone in his voice – his mind was spinning. â€Å"She could do it on her day off.† â€Å"Day off? More like every day. You should pull her from this entire field experience. Fake Strigoi attacks are not the way to recover from a real one.† â€Å"No!† I had pushed open the door before I realized it. They all stared at me, and I immediately felt stupid. I'd just busted myself for spying. â€Å"Rose,† said Dr. Olendzki, returning to her caring (but slightly chastising) doctor mode. â€Å"You should go lie down.† â€Å"I'm fine. And you can't make me quit the field experience. I won't graduate if you do.† â€Å"You aren't well, Rose, and there's nothing to be ashamed of after what's happened to you. Thinking you're seeing the ghost of someone who died isn't too out there when you consider the circumstances.† I started to correct her on the thinking you're seeing part but then bit it off. Arguing that I'd really seen a ghost wasn't probably going to do me any favors, I decided, even if I was starting to believe that was exactly what I was seeing. Frantically, I tried to think of a convincing reason to stay in the field experience. I was usually pretty good at talking myself out of bad situations. â€Å"Unless you're going to put me in counseling 24/7, you're just going to make it worse. I need something to do. Most of my classes are on hold right now. What would I do? Sit around? Think more and more about what happened? I'll go crazy – for real. I don't want to sit on the past forever. I need to get moving with my future.† This threw them into an argument about what to do with me. I listened, biting my tongue, knowing I needed to stay out of it. Finally, with some grumbling from the doctor, they all decided I would go on half-time for the field experience. It proved to be the ideal compromise for everyone – well, except me. I just wanted life to go on exactly as it had. Still, I knew this was probably as good a deal as I'd get. They decided that I'd do three days of field experience a week, with no night duties. During the other days, I'd have to do some training and whatever bookwork they dug up for me. I'd also have to see a counselor, which I wasn't thrilled about. It wasn't that I had anything against counselors. Lissa had been seeing one, and it had been really useful for her. Talking things out helped. It was just†¦well, this was just something I didn't want to talk about. But if it came down to this or being kicked out of the field experience, I was more than happy to go with this. Alberta felt they could still justify passing me on half-time. She also liked the idea of having counseling going on at the same time I was dealing with fake Strigoi attacks – just in case they really were traumatizing. After a bit more examination, Dr. Olendzki gave me a clean bill of health and told me I could go back to my dorm. Alberta left after that, but Dimitri stuck around to walk me back. â€Å"Thanks for thinking of the half-time thing,† I told him. The walkways were wet today because the weather had warmed up after the storm. It wasn't bathing suit weather or anything, but a lot of the ice and snow were melting. Water dripped steadily from trees, and we had to sidestep puddles. Dimitri came to an abrupt stop and turned so that he stood right in front of me, blocking my path. I skidded to a halt, nearly running into him. He reached out and grabbed my arm, pulling me closer to him than I would have expected him to do in public. His fingers bit deep into me, but they didn't hurt. â€Å"Rose,† he said, the pain in his voice making my heart stop, â€Å"this shouldn't have been the first time I heard about this! Why didn't you tell me? Do you know what it was like? Do you know it was like for me to see you like that and not know what was happening? Do you know how scared I was?† I was stunned, both from his outburst and our proximity. I swallowed, unable to speak at first. There was so much on his face, so many emotions. I couldn't recall the last time I'd seen that much of him on display. It was wonderful and frightening at the same time. I then said the stupidest thing possible. â€Å"You're not scared of anything.† â€Å"I'm scared of lots of things. I was scared for you.† He released me, and I stepped back. There was still passion and worry written all over him. â€Å"I'm not perfect. I'm not invulnerable.† â€Å"I know, it's just†¦Ã¢â‚¬  I didn't know what to say. He was right. I always saw Dimitri as larger than life. All-knowing. Invincible. It was hard for me to believe that he could worry about me so much. â€Å"And this has been going on for a long time too,† he added. â€Å"It was going on with Stan, when you were talking to Father Andrew about ghosts – you were dealing with it this whole time! Why didn't you tell anyone? Why didn't you tell Lissa †¦ or †¦ me?† I stared into those dark, dark eyes, those eyes I loved. â€Å"Would you have believed me?† He frowned. â€Å"Believed what?† â€Å"That I'm seeing ghosts.† â€Å"Well†¦ they aren't ghosts, Rose. You only think they are because – â€Å" â€Å"That's why,† I interrupted. â€Å"That's why I couldn't tell you or anybody. Nobody would believe me, not without thinking I'm crazy.† â€Å"I don't think you're crazy,† he said. â€Å"But I think you've been through a lot.† Adrian had said almost the exact same thing when I asked him how I could tell if I was crazy or not. â€Å"It's more than that,† I said. I started walking again. Without even taking another step, he reached out and grabbed me once more. He pulled me back to him, so that we now stood even closer than before. I glanced uneasily around again, wondering if someone might see us, but the campus was deserted. It was early, not quite sunset, so early that most people probably weren't even up for the school day yet. We wouldn't see activity around here for at least another hour. Still, I was surprised to see Dimitri was still risking it. â€Å"Tell me then,† he said. â€Å"Tell me how it's more than that.† â€Å"You won't believe me,† I said. â€Å"Don't you get it? No one will. Even you †¦ of all people.† Something in that thought made my voice catch. Dimitri understood so much about me. I wanted – needed – him to understand this too. â€Å"I'll†¦try. But I still don't think you really understand what's happening to you.† â€Å"I do,† I said firmly. â€Å"That's what no one realizes. Look, you have to decide once and for all if you really do trust me. If you think I'm a child, too na?ve to get what's going on with her fragile mind, then you should just keep walking. But if you trust me enough to remember that I've seen things and know things that kind of surpass those of others my age†¦well, then you should also realize that I might know a little about what I'm talking about.† A lukewarm breeze, damp with the scent of melted snow, swirled around us. â€Å"I do trust you, Roza. But†¦ I don't believe in ghosts.† The earnestness was there. He did want to reach out to me, to understand†¦but even as he did, it warred with beliefs he wasn't ready to change yet. It was ironic, considering tarot cards apparently spooked him. â€Å"Will you try to?† I asked. â€Å"Or at the very least try not to write this off to some psychosis?† â€Å"Yes. That I can do.† So I told him about my first couple of Mason sightings and how I'd been afraid to explain the Stan incident to anyone. I talked about the shapes I'd seen on the plane and described in more detail what I'd seen on the ground. â€Å"Doesn't it seem kind of, um, specific for a random stress reaction?† I asked when I finished. â€Å"I don't know that you can really expect ‘stress reactions' to be random or specific. They're unpredictable by nature.† He had that thoughtful expression I knew so well, the one that told me he was turning over all sorts of things in his head. I could also tell that he still wasn't buying this as a real ghost story but that he was trying very hard to keep an open mind. He affirmed as much a moment later: â€Å"Why are you so certain these aren't just things you're imagining?† â€Å"Well, at first I thought I was imagining it all. But now †¦ I don't know. There's something about it that feels real†¦ even though I know that isn't actually evidence. But you heard what Father Andrew said – about ghosts sticking around after they die young or violently.† Dimitri actually bit his lip. He'd been about to tell me not to take the priest literally. Instead he asked, â€Å"So you think Mason's back for revenge?† â€Å"I thought that at first, but now I'm not so sure. He's never tried to hurt me. He just seems like he wants something. And then †¦ all those other ghosts seemed to want something too – even the ones I didn't know. Why?† Dimitri gave me a sage look. â€Å"You have a theory.† â€Å"I do. I was thinking about what Victor said. He mentioned that because I'm shadow-kissed – because I died – I have a connection to the world of the dead. That I'll never entirely leave it behind me.† His expression hardened. â€Å"I wouldn't put a lot of stock in what Victor Dashkov tells you.† â€Å"But he knows things! You know he does, no matter how big an asshole he is.† â€Å"Okay, supposing that's true, that being shadow-kissed lets you see ghosts, why is it happening now? Why didn't it happen right after the car accident?† â€Å"I thought of that,† I said eagerly. â€Å"It was something else Victor said – that now that I was dealing in death, I was that much closer to the other side. What if causing someone else's death strengthened my connection and now makes this possible? I just had my first real kill. Kills, even.† â€Å"Why is it so haphazard?† asked Dimitri. â€Å"Why does it occur when it does? Why the airplane? Why not at Court?† My enthusiasm dimmed a little. â€Å"What are you, a lawyer?† I snapped. â€Å"You question everything I'm saying. I thought you were going to have an open mind.† â€Å"I am. But you need to too. Think about it. Why this pattern of sightings?† â€Å"I don't know,† I admitted. I sagged in defeat. â€Å"You still think I'm crazy.† He reached out and cupped my chin, tipping my face up to look at his. â€Å"No. Never. Not one of these theories makes me think you're crazy. But I've always believed the simplest explanation makes sense. Dr. Olendzki's does. The ghost one has holes. But, if you can find out more†¦then we may have something to work with.† â€Å"We?† I asked. â€Å"Of course. I'm not leaving you alone on this, no matter what. You know I'd never abandon you.† There was something very sweet and noble about his words, and I felt the need to return them, though mostly I ended up sounding idiotic. â€Å"And I won't ever abandon you, you know. I mean it†¦ not that this stuff ever happens to you, of course, but if you start seeing ghosts or anything, I'll help you through it.† He gave a small, soft laugh. â€Å"Thanks.† Our hands found each other's, fingers lacing together. We stood like that for almost a full minute, neither of us saying anything. The only place we touched was our hands. The breeze picked up again, and although the temperature was probably only in the forties, it felt like spring to me. I expected flowers to burst into bloom around us. As though sharing the same thought, we released our hands at the same time. We reached my dorm shortly after that, and Dimitri asked if I'd be okay going in on my own. I told him I'd be fine and that he should go do his own thing. He left, but just as I was about to step through the lobby door, I realized my overnight bag was still back at the med clinic. Muttering a few things that would have gotten me a detention, I turned around and hurried back in the direction I'd just come. Dr. Olendzski's receptionist motioned me toward the examining rooms when I told her why I was there. I retrieved the bag from my now-empty room and turned into the hall to leave. Suddenly, in the room opposite mine, I saw someone lying in bed. There was no sign of any of the clinic's staff, and my curiosity – always getting the better of me – made me peek inside. It was Abby Badica, a senior Moroi. Cute and perky were the adjectives that usually came to mind when I described Abby, but this time, she was anything but. She was bruised and scratched up, and when she turned her face to look at me, I saw red welts. â€Å"Let me guess,† I said. â€Å"You fell.† â€Å"W-what?† â€Å"You fell. I hear that's the standard answer: Brandon, Brett, and Dane. But I'll tell you the truth – you guys need to come up with something else. I think the doctor's getting suspicious.† Her eyes went wide. â€Å"You know?† It was then that I realized my mistake with Brandon. I'd come at him demanding answers, which had made him reluctant to share anything. Those who'd questioned Brett and Dane had faced similar results. With Abby, I realized that I just had to act like I already knew the answers, and then she'd give up the information. â€Å"Of course I know. They told me everything.† â€Å"What?† she squeaked. â€Å"They swore not to. It's part of the rules.† Rules? What was she talking about? The royal-bashing vigilante group I'd been picturing didn't really seem like the type to have rules. There was something else going on here. â€Å"Well, they didn't have much of a choice. I don't know why, but I keep finding you guys afterward. I had to help cover for them. I'm telling you, I don't know how much longer this can go on without someone asking more questions.† I spoke like I was a sympathizer, wanting to help if I could. â€Å"I should have been stronger. I tried, but it wasn't enough.† She looked tired – and in pain. â€Å"Just keep quiet until everything's set, okay? Please?† â€Å"Sure,† I said, dying to know what she'd â€Å"tried.† â€Å"I'm not going to drag anyone else in. How'd you even end up here? You're supposed to avoid attracting attention.† Or so I assumed. I was totally making this up as I went along. She grimaced. â€Å"The dorm matron noticed and made me come in. If the rest of the Man? finds out, I'm going to get in trouble.† â€Å"Hopefully the doctor'll send you on your way before any of them find out. She's kind of busy. You've got the same marks as Brett and Brandon, and none of theirs were that serious.† So I hoped. â€Å"The†¦uh, burn marks were a little tricky, but they haven't had any problems.† It was a gamble in my game here. Not only did I have no clue about the specifics of Brett's injuries, I also didn't actually know if those marks Jill had described on him were burns. If they weren't, I might have just blown my insider act. But, she didn't correct me, and her fingers absentmindedly touched one of the welts. â€Å"Yeah, they said the damage wouldn't last. I'll just have to make up something for Olendzki.† A small flicker of hope shone in her eyes. â€Å"They said they wouldn't, but maybe†¦maybe they'll let me try again.† It was at that moment that the good doctor returned. She was surprised to see me still there and told me I needed to get back home and rest. I said goodbye to both of them and trekked back out into the cold. I barely noticed the weather as I walked, though. Finally, finally, I had a clue in this puzzle. Man?.