Many Lives Many Masters Essays - Brian Weiss, Hypnotherapists

Many Lives Many Masters Many Lives, Many Masters is a book about a psychologist Brian L. Weiss, who by helping his patient he helps himself as well. Through Catherine he learned that his conventional approach through the scientific method and medication was not the proper way to heal his patients. Catherine comes in with anxiety, panic attacks and phobias and wants a way out of it all. Dr. Weiss approaches the situation in a scientific manner as he does with all of his patients, he doesn't get very far until he decided to use hypnosis. He would have liked to use medication but her fear of swallowing pills prevented that. During hypnosis she begins to remember her childhood but not this childhood her past life. At first Dr. Weiss is very skeptical I mean there is no scientific explanation for this but he decides to continue. In her past lives he begins to discover why she has so many of the fears and phobias that she has. As well, during hypnosis she begins to identify others in her life now as some from her past lives. During one of these hypnosis after her death a different voice begins to speak. This voice knows things about Dr. Weiss' past that no one else would and could know because he never shared the details with Catherine about his personal life. This Masters begins to tell him about his meaning in life, a message. One that through his religious beliefs as well as through his scientific methods he could not understand. The Masters spoke of many plains that were reached throughout your past lives. You could only reach these plains if you solved the problem you had in your life. For example, if you leave a life and never learn to trust in your next life, you must learn to trust. If this is achieved you would be able to reach to the next plain and receive more knowledge. He began to believe and listen. Through this listening, he began to have new meaning in his life and learned how to help Catherine through hers. He than began to try to reach the end of Catherine's lives to get t o the end in the hope that the Masters would relay another message through Catherine. The masters did not appear every time that Catherine remembered a death in her past life only when they decided to relay this message. These messages then stopped and Catherine was cured. Then years later Dr. Weiss believed it was time for him to pass this message to others through his book Many Lives, Many Masters. In the beginning of the book I was very captivated by Catherine's past life regressions. The belief that there was past lives and knowledge obtained from each life was a great revelation. Then, the masters began to speak; this became a little far fetch for me. I'm not saying that Dr. Weiss didn't hear these masters speak but that he might have misinterpreted the message the masters are really trying to bring across. He was very na?ve at the time, and began to learn about things beyond the scientific method and was not ready to learn so much information. I can not say with certainty that maybe later in his next books he learned the deeper meaning of the masters messages. I also think that when the masters spoke of the religious individuals ?People of the religious orders have come closer than any of us because they've taken these vows of chastity and obedience.? reaching a higher plain much faster because of it. This was his way of somehow holding on to faith something he was taught g rowing up. Not all the book is full of weaknesses though, the stories that Catherine remembered from her past life regressions were I believe the strongest points in this book. She spoke of people in her past lives as though she knows them now or strangers. The idea that we decide to come back with certain people and that somehow we decide to meet again was the most fascinating. The same as in Mutant Message were Marlo learns that in a past life she made a promise with

The Worlds Newest Countries Since 1990

The Worlds Newest Countries Since 1990 Since the year 1990, 34 new countries have been created, many as a result of the dissolution of the U.S.S.R. and Yugoslavia in the early 1990s. Others became new countries as a result of anticolonial and independence movements, including Eritrea and East Timor. Union of Soviet Socialist Republics Fifteen new countries became independent when the Union of Soviet Socialist Republics (U.S.S.R.) dissolved in 1991. Most of these countries declared independence a few months before the Soviet Union officially collapsed: ArmeniaAzerbaijanBelarusEstoniaGeorgiaKazakhstanKyrgyzstanLatviaLithuaniaMoldovaRussiaTajikistanTurkmenistanUkraineUzbekistan Former Yugoslavia Yugoslavia dissolved in the early 1990s into five independent countries: June 25, 1991:  Croatia  and SloveniaSeptember 8, 1991:  Macedonia (officially The Former Yugoslav Republic of Macedonia) declared independence on this date, but wasnt recognized by the United Nations until 1993 and the United States and Russia until February of 1994.February 29, 1992: Bosnia and HerzegovinaApril 17, 1992:  Serbia and Montenegro, also known as the Federal Republic of Yugoslavia Other New Countries Thirteen other countries became independent through a variety of circumstances, including independence movements: March 21, 1990:  Namibia became independent of South Africa.  Previously, Namibia was known as South West Africa when the latter was officially a German territory.May 22, 1990:  North and South Yemen merged to form a unified Yemen.October 3, 1990: East Germany and West Germany merged to form a unified Germany after the fall of the Iron Curtain.September 17, 1991:  The Marshall Islands was part of the Trust Territory of Pacific Islands (administered by the United States) and gained independence as a former colony. On this date,  Micronesia, previously known as the Caroline Islands, also became independent from the United States.January 1, 1993: The Czech Republic and Slovakia became independent nations when Czechoslovakia dissolved. The peaceful separation was also known as the Velvet Divorce, after the Velvet Revolution which had led to the end of communist rule in Czechoslovakia.May 25, 1993: Eritrea, which was part of Ethiopia, seceded and gained independence. The two nat ions later became involved in a violent war over disputed territory. A peace agreement was reached in 2018. October 1, 1994: Palau was part of the Trust Territory of Pacific Islands (administered by the United States) and gained independence as a former colony.May 20, 2002: East Timor (Timor-Leste) declared independence from Portugal in 1975 but did not become independent from Indonesia until 2002.June 3, 2006: Montenegro was part of Serbia and Montenegro (also known as Yugoslavia) but gained independence after a referendum. Two days later, Serbia became its own entity after Montenegro split.February 17, 2008: Kosovo unilaterally declared independence from Serbia. The representatives of the Kosovo people unanimously agreed that the country would be independent of​ Serbia despite the objections of eleven representatives of the Serbian minority.July 9, 2011: South Sudan peacefully seceded from Sudan following a January 2011 referendum. Sudan had been the site of two civil wars, and the referendum received near unanimous approval.

A Capitalization Cheat Sheet

A Capitalization Cheat Sheet A Capitalization Cheat Sheet A Capitalization Cheat Sheet By Mark Nichol Capitalization is a bewilderingly complex issue, with many rules and exceptions. This post outlines the basic, most common guidelines for capitalization, with examples. Academic degrees: Lowercase- â€Å"bachelor’s degree†; capitalize entirety of most abbreviations (with a few exceptions, including PhD and DLitt) Academic disciplines: Capitalize only proper names- â€Å"Asian studies† (except as part of a full name of an entity (â€Å"the School of Business,† â€Å"the Department of Philosophy,† â€Å"the Commission on the Liberal Arts,† etc.) Acronyms and initialisms: Capitalize most abbreviations of proper names- NATO, FBI (but some style guides and writing handbooks call for using initial capitalization only for extensive and established acronyms, as with Nasdaq); most abbreviations for units of measurement are not capitalized, but check a dictionary or style guide for exceptions Animal names: Lowercase terms except in the case of proper names- â€Å"African elephant,† â€Å"Steller’s jay† (do the same for animal breeds, as in â€Å"Labrador retriever,† though specialized publications often capitalize all words in breed names); capitalize first word in binomial and trinomial nomenclature (â€Å"Homo sapiens,† â€Å"Gorilla gorilla gorilla†), but differentiate between nomenclature and popular name (â€Å"Pinus ponderosa,† but â€Å"ponderosa pine†) Astronomical terms: Capitalize most names of specific bodies and collections of bodies- â€Å"the Milky Way,† but â€Å"the solar system†; capitalize Earth (and Moon and Sun) in astronomical references but lowercase in terrestrial or figurative contexts- â€Å"The third planet is Earth,† but â€Å"The earth is flat† (do not capitalize earth when the word is preceded by the) and â€Å"Where on earth is he?† (and â€Å"The sun is about to rise† and â€Å"The moon is full†) Brand names and trademarks: Follow capitalization as used by the brand owner, but ignore logo format- for example, the brand names Lego and Time (the magazine) are treated as all-caps in the respective company logos; companies discourage genericization of trademarks such as kleenex and xerox, but writers have no obligation to honor such usage as â€Å"Kleenex Brand Facial Tissue† Color terms for ethnic identification: Lowercase unless a company or publication prefers otherwise- â€Å"black man,† â€Å"white people† Compass points: Generally lowercase, but capitalize in geopolitical contexts- â€Å"the Pacific Northwest,† â€Å"customs prevalent in the East†) Cultural terms: Look up specific terms, as treatment varies widely- â€Å"art deco,† but Beaux-Arts Emphasis: Capitalize only in ironic contexts- â€Å"He was apparently a Big Man on Campus†; do not capitalize entire words, except perhaps to denote a newspaper headline or signage (and then, small caps are recommended) Epithets: Capitalize key words- â€Å"Alfred the Great,† â€Å"Babe Ruth,† â€Å"Michael ‘Air’ Jordan,† â€Å"the Windy City,† â€Å"Big Pharma† File formats: The Chicago Manual of Style recommends capitalizing names of formats, but do so only in such usage as â€Å"I made a GIF from the video,† and lowercase (and precede with a dot) in references to files such as â€Å"The latest version of Microsoft Word uses the file extension .docx† Foreign terms: German capitalizes all nouns, but lowercase German words adopted into English- hausfrau, schadenfreude, weltanschauung (if it’s in the dictionary, it’s English) Generations: Lowercase except in the case of initials or other single letters- â€Å"baby boomers,† â€Å"generation X† Geographical names: Capitalize in proper names, but lowercase in generic usage- â€Å"the Mississippi River,† but â€Å"the river†; check style guides for variations such as â€Å"the Pacific coast†/â€Å"the West Coast†; lowercase metaphorical and nonliteral use of proper names- â€Å"manila envelope,† â€Å"They set out to create a utopia† Historical terms: Look up specific terms, as treatment varies widely- â€Å"the colonial period,† but â€Å"the Gilded Age† Honorifics: Capitalize key words- â€Å"the First Lady,† â€Å"Your Honor† (but â€Å"Yes, my lord†) Key commands: Capitalize words denoting switch, keyboard, and command functions- â€Å"the Pause button,† â€Å"the Command key,† â€Å"the Save command,† etc. Kinship names: Capitalize only in direct address or in place of or in combination with a name- â€Å"Yes, Mother,† â€Å"We’re going to Grandmother’s house,† â€Å"Uncle Joe† (but â€Å"my uncle Joe†) Laws, theories, and the like: Capitalize only proper names- â€Å"Newton’s third law,† â€Å"the Pythagorean theorem† Letters as letters: Capitalize only if the letter is specified as an uppercase letter- â€Å"a capital C† (exception: letter grades, as in â€Å"She earned four As†) Letters as shapes or musical notes, or points, concepts, or hypothetical names: Capitalize- â€Å"a V-shaped symbol,† â€Å"from point A to point B,† etc. (exception, lowercase- but italicize- letters in rhyming schemes, as in â€Å"an abab pattern†) Medical conditions: Capitalize only proper names- â€Å"Alzheimer’s disease,† but â€Å"muscular dystrophy† Natural events and phenomena: Capitalize names of storms but otherwise lowercase generic words- â€Å"Hurricane Harvey,† but â€Å"the San Francisco earthquake† Organizational entities: Capitalize in proper names, but lowercase in generic usage- â€Å"the Federal Bureau of Investigation,† but â€Å"the bureau†- and â€Å"the federal government†); lowercase generic versions of entity names- â€Å"the company,† â€Å"the museum,† â€Å"the committee,† etc.; lowercase the preceding entities’ names (unless house style allows exceptions) People’s names: Capitalize names of real and fictional people, but lowercase figurative usage- â€Å"Jack Nicholson,† â€Å"Jack Sprat,† but â€Å"every man jack†; capitalize personifications- â€Å"Mother Nature,† â€Å"Ol’ Man River† Prefixes for proper names: Look up specific terms, as treatment varies- pre-Columbian, but transatlantic Seasons: Lowercase- winter, spring, summer, fall Titles of compositions: Capitalize key words- â€Å"Pride and Prejudice† (check a style guide for specifics) Titles of jobs and offices: Capitalize key words before the name (except when modified) and lowercase after the name or in isolation- â€Å"Director of Marketing John Smith,† â€Å"Pastor Jane Jones† (but â€Å"former director of marketing John Smith,† â€Å"John Smith, director of marketing,† and â€Å"the director of marketing,† as well as â€Å"the pastor†); capitalize in direct address (â€Å"As you were, Sergeant†) or in formal written contexts or in a ceremonial or promotional list Titles of nobility: Capitalize before names and when using full title in isolation- â€Å"There’s Prince Charles,† â€Å"the Duke of Windsor† (but â€Å"the duke†) Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Style category, check our popular posts, or choose a related post below:50 Incorrect Pronunciations That You Should AvoidThat vs. WhichThe Two Sounds of G

Change Management in Schools Essay Example | Topics and Well Written Essays - 4000 words

Change Management in Schools - Essay Example But here this paper instead of filling its contents with intentional verbosity, our approach is quite goal-oriented. In addition, many of these research areas are further convoluted with links and interactions to other, nor-related research that need to be considered. Finally, the lack of accurate measurability severely hampers the statistical assessment of suitability of a stated hypothesis. But this paper is rather unconventional and attempts to dig out the actual problems and stumbling blocks that hamper the process of change management in our institutions. While above-mentioned factor pertaining to the lack of accurate measurability is true for the entire field of education, it is particularly acute in researches directly related on such topics. For this reason, published articles have the search for an explanation of actions and phenomena in common as a general rule all, albeit from different points of views. But this paper is, as mentioned above is rather goal-oriented fraught with realistic recommendations and suggestions. Despite the fact that the field of this issue has attracted some of the best researchers within the educational realm, the lack of unity in opinion as well as a structured overview is outmost apparent. This paper attempts to overcome this lack by providing a comprehensive overview and analysis of current recruiting and retaining concepts. Nonetheless, an attempt is made with this paper to lessen the validation pressure from lack of data by providing the results of a small but comprehensive literature review thorough a number of books, journals and web-based sources. Thus, coming out from the ambit of educational concerns, this issue has become an inevitable topic to think upon in general. To date, there have been various researches conducted on this topic; similarly this paper is a humble attempt from my side not only to have a discussion on it in general but also to explore some unexplored avenues related with this issue that may furt her help us reaching at rather down-to-earth conclusion. There is no doubt that in Britain, in the last ten years, we have seen massive strides forward in the education system. The establishment of a national curriculum and other reforms have provided the basic framework for improvement in educational provision, but at a considerable cost to teachers. Since the Education Reform Act (1988), we have seen a continuous stream of systemic, top-down change which has had a major impact on teachers' professionalism. Their roles in strategic planning and decision making have been dominated by the requirement to implement externally driven initiatives, and workloads have expanded leading to high levels of stress, low levels of morale and difficulties with recruitment and retention. This study is offering a strategy to help school management reconstruct their professionalism by providing a framework within which they can play a full and active part in school improvement and school development. The research carried out and the consequent conclusion thereof offered here has the potential to bring about lasting change and has raised standards through the enhancement of teachers'

Summary Essay Example | Topics and Well Written Essays - 250 words - 84

Summary - Essay Example Current activities in the business world make communication skills the utmost vital thing in doing business. Most employees believe that communication skills may boost their value in business which may eventually enhance production. Communication courses may further introduce skills that are beneficial to the individual employee and even for the management (Belohlov, Popp & Porte 53-59). Industries always attempt to achieve the most effective and efficiency in all aspects of communication particularly from people who have graduated with communication skills course. Most firms would therefore strive to recruit employees based on their communication skills since the skills play significant role in determining future success of the company. It is undeniable that businesses have recognized the benefits of communication skills (Belohlov, Popp & Porte 53-59). However, after selection and recruitment, companies do very little to ensure continuous training for their employees. Both learning institutions and businesses should ensure an improvement in communication to avoid communication challenges faced in the current business Summary Essay Example | Topics and Well Written Essays - 750 words - 5 Summary - Essay Example Therefore, prejudice should only be redefined for proper regulation and people should not think of totally eradicating prejudice. Prejudice is amongst some of the currently prohibited aspects in the society and especially in the United States. Prejudice is associated with hate speech and has similar magnitude of regards. The general public has expressed its concern against prejudice as well as the hate speech related to race, gender or both. Individuals such as Francis L. Lawrence have been expressed to the stipulations shunning prejudice due to his utterance. Francis L. Lawrence once expressed that blacks were the most disadvantaged and lacked genetic hereditary to merit any higher advantage. Craig Rogers also filed an expensive case about her lesbian professor of psychology for leaving her feeling rapped and also trapped. Learning institutions have formulated strategies to ensure no tolerance to prejudice of any manner ranging from racism to Christian bashing. This has been impleme nted to ensure that the society is favorable to the perceived minorities. By resisting every element of prejudice, it does not depict that the racial aspect does not exist in every individual. Nonetheless intellectual pluralism should be embraced to permit respect of expression of every individual. "Only when racism and other forms of prejudice are expunged," The suppression of prejudice targets the time when there will be a total belief among individuals in the society that there is no difference in human origin, a provision that is even doubted still. The author states that, â€Å"I doubt such a day will ever arrive.† The feeling of segregation is recurrent in human and should be suppressed every time. If a total freedom exists, people will be legitimate in their diverse thoughts such as insanity of the homosexuals, their barrier to reproduction and the doubts they impose on people. Moreover, as the efforts are geared towards doing away with the prejudice it is realized tha t no much achievement are attained and as a result the conditions worsen. Therefore, it would be wise to start thinking and implementing the facets of prejudice at the expense of eliminating them. Prejudice has caused much confusion in the society and bad habits in the society such as homosexuality benefit from the policies and opposing homosexuality is a prejudice to the group. For instance the student arraigned before the senate for hate speech against the homosexuals by outlining that it can be treated by a therapy. In this case it is not easy to determine who is right neither is it necessary but proper direction and modification of prejudice to be useful to the society is critical. According to Rauch, "eradicating prejudice" is so vague a proposition as to be meaningless.† Science is the rationale behind impartiality in alleviating prejudice. In spite of the capability of science to be factual and unbiased, the scientists are equally biased and would engage their biases in reasoning hence influencing the results. Therefore, the rationale posed by science is vulnerable to the least influences beginning by emotions that supersede their love for truth. There is a predominant belief that for a system to attain an unprejudiced condition, individuals responsible for its formulation must be unprejudiced in their life and work. However there is much confusion experiencing by understanding that prejudice led to the discovery of the Auschwitz gas

Law Essays Negligence Damages Breach

Law Essays Negligence Damages Breach Negligence Damages Breach For the purposes of this paper, it is assumed that liability for negligence rests solely on the Umbridge Village Fà ªte Committee (UVFC) with regard to the damages suffered by Tony and Will as it is generally accepted that legal responsibility should lie with the event organiser/hirer. The insurance policy should indemnify the Borsetshire County Council (BCC) against all activities on the agreed land, except to the extent that the damage is due to any act or omission of the BCC. In order to succeed in a claim for negligence, the claimant must prove that they were owed a duty of care, that the duty was breached, and that the breach resulted in the damage complained of. The authority for duty of care is the leading case of Donoghue v Stevenson (1932) and it is well established law that event organisers owe a duty of care to the participants, spectators and the general public who attend their events. It follows that the UVFC had a duty to ensure that all foreseeable risks had been adequately assessed and that the appropriate safety measures had been put in place with regard to the planned competitions. Given that a duty has been established, it must now be determined whether the UVFC has breached that duty. According to Alderson B, in Blyth v Birmingham Waterworks (1856), to avoid breaching a duty of care, the defendant must meet the standard of a â€Å"reasonable man†. This test is objective and recognises that the average person can not foresee every risk. Case law has established that anyone acting within a specific area of skill must show the same standard of care as a reasonable person with that particular skill. Therefore, the question to ask is â€Å"what would a reasonable event organiser, placed in the same position as the UVFC, have done, and did the UVFC meet that standard?† If it can be shown that the UVFC did not use sufficient care with regard to the competitions, liability in negligence may arise. Tony On the facts, it was wholly unreasonable to allow a competitor to use a garden trowel as a spile given the nature of the game. Any reasonable person would have recognised that using such an implement in that manner could result in serious injury. Therefore, the UVFC is in breach of its duty. It is readily apparent that ‘but for’ the negligent act of the event organiser in allowing the trowel to be used in the competition, this injury would not have occurred. Therefore, the UVFC will be liable for the injury unless the damage is too remote. The test for remoteness of damage as held in The Wagon Mound (1961) is that the damage must have been reasonably foreseeable. This is readily established because all Tony must prove is that some personal injury was foreseeable. The precise circumstances need not be foreseeable, as damages can be recovered for an â€Å"unforeseeable form of a foreseeable type of injury†, and for â€Å"unforeseeable consequences of a foreseeable type of injury† Therefore, it is likely that the UVFC will be liable for Tony’s injury. The UVFC may argue volenti non fit injuria. Case law has established that spectators assume the risk of injury when attending certain events and thus indemnify the organisers. For example a person attending an ice hockey event accepts the risk they could be injured by a puck. Similarly, a spectator at a golf tournement â€Å"runs the risk of the players slicing or pulling balls which may hit them with considerable velocity and damage.† However, Wilks v Cheltenham Home Guard Motor Cycle and Light Car Club (1971) established that a spectator can recover damages for injury resulting from the negligent act of one of the competitors or the failure of the event organiser to guard against accidents which are â€Å"foreseeable and not inherent in the sport or entertainment†, unless it can be shown that the spectator agreed to take the risk of being injured. Therefore the UVFC would need to prove that Tony â€Å"freely and voluntarily, with full knowledge of the nature and extent of the risk he ran, impliedly agreed to incur it.† Tony is regarded as having accepted the risk of injury due to foreseeable playing errors but not the risk of injury due to a reckless disregard of his safety. On the facts, Tony could not have assumed the risk of injury, as it was not foreseeable or inherent, that such an implement would be used in the event. If the court agreed, the defence would fail. Will It has already been established that the UVFC owes a duty of care. Therefore, Will must demonstrate that the UFVC was in breach of its duty. Would the reasonable event organiser, having regard for the safety of the competitors, allow the game to be played in the river? It is accepted fact that football matches are played on a pitch. Furthermore, it is common knowledge that rocks are usually present along riverbeds and that they can be slippery. Thus, there was an obvious danger of a slip and fall injury. The reasonable organiser would have recognised the risk and selected a more suitable site for the match. Therefore, the UVFC is in breach of its duty. Can it be said that the accident would not have occurred ‘but for’ the negligence of the UVFC? Undoubtedly, Tom’s act of tackling Will for the ball was a contributing factor in the incident. Did it constitute a novus actus? Can it be said that Will would have suffered injury ‘but for’ the negligence of either the UVFC or Tom? The courts have made it clear that they approach causation as a matter of common sense. Therefore, the judge must decide, of the two acts, which was the effective cause of Will’s injury. In applying the common sense approach to this scenario, the act of a third party will not be treated as the effective cause of the damages unless it was entirely unreasonable and independent of the original negligent act. It appears that the negligent act of holding the match in the river will be considered the effective cause of Will’s injury. Tom’s tackle was an incidental risk of the game and was neither unreasonable nor independent. Again there is no issue of remoteness, as personal injury was foreseeable. Does UVFC have any available defences to avoid liability? It could be argued that Will voluntarily consented to the risk of injury by participating in the match. It is accepted that a person engaged in playing a lawful game takes on himself the risks incidental to being a player. However, according to Gillmore v LCC (1938), he does not take on himself additional risks due to the provision of unsuitable premises or inadequate safety precautions. Gillmore was distinguished from the usual volenti non fit injuria cases on the grounds that the council, in allowing the game to be played on a highly polished surface, added a danger beyond the usual dangers involved in the playing of the game. Will may contend that holding the game in the river was an added danger. To succeed, the UVFC will have to prove that Will chose to run the risk having full knowledge of both the nature and extent of the risk, that he agreed to waive his rights in respect of such damage, and that he was not acting under any relevant pressure. If this is proven, Will’s claim will be unsuccessful as the defence operates as a full waiver of liability. In addition, a case could be made that Will accepted that playing in the river increased his risk of injury and as such, his decision to participate anyway was causative. It should be noted that while knowledge of the risk may show contributory negligence, it does not prove voluntary assumption of that risk. On that basis, it may be decided that Will acted carelessly and any damages awarded would be reduced taking into account his contributory negligence. With regard to Emma’s claim, the case of Cole v Davies-Gilbert and others (2007) was recently decided on similar facts. The Court ruled that there was no evidential basis on which to hold the event organiser or land owner liable for the claimant’s injury. The Occupiers’ Liability Act, 1957 (OLA 1957), introduced a common duty of care to visitors which is defined under section 2(2). This duty imposes a positive obligation on occupiers to ensure visitors are reasonably safe and is not the same as the duty of care in negligence. The definition of premises includes land and buildings, thus clearly encompassing the green. Section 1(2) provides that visitors are those persons who at common law would be treated as invitees and licensees. Based on the facts, Emma was a visitor because she had implied permission to walk across the green and was not acting outside the scope of her permission to be there. Therefore, she was owed a common duty of care. Occupier is not defined in the Act, however, according to Lord Denning in Wheat v Lacon (1966) â€Å"an occupier is someone who has a sufficient degree of control over premises that he ought to realise that any failure on his part to use care may result in injury to a person coming lawfully there as his visitor.† There can be more than one occupier and physical occupation is not compulsory. Thus, both the BCC and the UVFC could be considered occupiers under the Act. However, Emma may wish to pursue her claim against the UVFC in negligence rather than under the Act, since it no longer has control over the premises. The standard of care required of an occupier under the Act is the same as in common law negligence. The Court must look at whether or not the occupier’s conduct was below the standard of similar occupiers acting in the same circumstances. If the conduct does not fall below the standard of the reasonable occupier then it will not be said to have acted negligently. It is easily accepted that a deep hole in the centre of a public green poses a risk of harm and as such is a foreseeable danger. However, it is important to note that it is the visitor who must be reasonably safe and not the premises. Thus the fact that the exposed hole existed does not, without more, constitute a breach of duty. Thus the essential point to consider is whether the occupier acted reasonably. In so deciding, we must consider whether the hole had been adequately sealed after the event and whether a reasonable system of inspection and maintenance was in place. Assuming that this was the first incident involving the hole, it would be reasonable to believe that the hole had been properly sealed given the amount of time which passed without incident. Presumably, the UVFC would have been responsible for reinstating the green after the fà ªte under the hirer’s agreement with the BCC. It follows that the UVFC met the standard of care required of an occupier of premises and will not be liable for Emma’s injury. In negligence, the UVFC owes Emma a duty of care under the neighbour principle and as such, it could be argued that the UVFC was responsible for what went wrong. However, the Committee has acted reasonably in sealing the hole. Therefore there is no breach in negligence either. Finally, any claim against the UVFC would fail unless it could be proven that they knew, or had reasonable grounds to believe, that the hole had been exposed and did not take the necessary steps to avert the danger. In Emma’s claim against the BCC, it is unclear on the facts provided, what knowledge, if any, the BCC had of the exposed hole. Assuming it had no knowledge, Emma would have to prove that the Council’s system of inspection and follow up did not meet the accepted standard employed by other councils, or that it acted unreasonably. This would be difficult given that there were no prior incidents and no mention of complaints by groundskeepers or subsequent hirers of the green. Thus, if it could be shown that sensible and reasonable action was taken with regard to inspecting and maintaining the green, the BCC would escape liability. Conversely, if the BCC knew the hole was exposed, it could be found liable given the fact that it would not have been onerous to ensure that the hole was filled in properly and a ‘reasonable occupier’ would have done so. Under s2(4)(a) OLA 1957, it is possible to discharge the duty owed by providing adequate warnings that enable the visitor to avoid the danger. However, a warning is not to be treated without more as absolving the occupier from liability, unless in all the circumstances it was enough to enable the visitor to be reasonably safe as explained in Roles v Nathan (1963). In Rae v Mars UK (1989), it was held that â€Å"where an unusual danger exists the visitor should not only be warned of the danger but a barrier or additional notice should be placed to show the immediacy of the danger†. On the facts of the present case, there were no warnings or barriers. Therefore the BCC did not discharge its duty under the provision and should be held liable for Emma’s injury. Section 2(1) OLA 1957 provides that an occupier may exclude his duty ‘by agreement or otherwise’. Ashdown v Samuel Williams Sons Ltd (1957) held that it is sufficient for an occupier to post a â€Å"clear and unequivocal notice† at the point of entry excluding liability with respect to non-contractual entrants. Once again, on the facts, this was not done. A key point here is that the Unfair Contract Terms Act 1977 controls the exclusion of liability for negligence including the common duty of care under OLA 1957. Section 2(1) of the 1977 Act prohibits any attempt to exclude liability for personal injury resulting from negligence, although this is only applicable in a business context. If Emma could establish that she entered the green under contract she could successfully claim damages against the BCC even if it had posted an exclusion notice. A final consideration is the Compensation Act 2006 which serves to remind us that the law does not compensate people who are involved in pure accidents. Furthermore, Section 1 draws attention to the fact that in determining whether there has been a breach of duty, the court will consider whether â€Å"precautionary and defensive measures, if taken, would prevent desirable activities†, thereby attempting to â€Å"ensure that normal activities are not prevented due to fear of litigation and excessively risk-averse behaviour.† Therefore, unless Emma proves causative fault against either defendant, her claim should fail as clearly, too high a duty of care imposed by the courts would interfere with the reasonable enjoyment of life. Therefore, in the absence of any evidence to the contrary, Emma’s accident should be considered just that; an accident.

Crude Oil Price Volatility Economics Essay

Energy plays the cardinal function in the universe economic system. In malice of considerable disposition to alternative renewable beginnings of energy like air current, H2O, atomic and solar power, the function of rough oil in macroeconomic motions has non waned yet ( Mehrara & A ; Mohaghegh, 2011 ) . Since the find and production of oil Nigeria in 1958, the subsector has continued to play a major and dominant function in the Nigerian economic system. The extractive sector in the Nigerian economic system is big and extended, with oil playing a critical function. With about 37.2 billion barrels in militias and 2.13 % of planetary production, Nigeria has the universe ‘s 10th largest proven militias ( 3.1 % of planetary militias ) , and is among the top 10 oil manufacturers ( Akinlo, 2012 ) . Nigeria has been a member of the Organization of the Petroleum Exporting Countries ( OPEC ) since July 1971. Presently, there are 12 member states including Nigeria in this international organisation whose purpose of the organisation, harmonizing to its Statute, is the finding of the best agencies for safeguarding their involvements, separately and jointly ; inventing ways and agencies of guaranting the stabilisation of monetary values in international oil markets with a position to extinguishing harmful and unneeded fluctuations ; giving due respect at all times to the involvements of the bring forthing states and to the necessity of procuring a steady income to the bring forthing states ; an efficient, economic and regular supply of crude oil to devouring states, and a just return on their capital to those puting in the crude oil industry ( OPEC, 2012 ) . Crude Oil is an of import trade good non merely because it is of course happening in the Earth but because of the many fractions that are derived from it after the refinement procedure. Those changing fractions such as fuel oil, jet fuel, kerosine etc. are extracted at different temperatures during the refinement procedure. The demand for rough oil is derived from the demand for its fractions and it depends on a big figure of factors such as its class, sulfur content and its locations. Crude Oil is classified in the international market harmonizing to changing molecular features by giving pricing mentions to the countries where such barrels are produced. Such pricing mentions include the North American West Texas Intermediate, Nigerian Bonny Light, Brent etc. In most oil exporting states, authorities which is well big in comparing with little private sector, straight receives the oil gross. Spending this gross, authorities ‘s behaviour becomes the most of import feature of the economic system. In other words, the financess needed for authorities ‘s outgo come from oil gross. So, financial and pecuniary policies depend upon oil monetary value ( Rosser & A ; Sheehan, 1995 ) . Oil monetary value is extremely variable ; even more than any other trade good ( Dehn, 2001 ) . Crude oil monetary values have increased on norm from US $ 25 per barrel in 2002 to US $ 55 per barrel in 2005. There has been a steep upward tendency in the monetary value of rough oil in recent old ages, making a record nominal high of US $ 147 in mid-2008 and a crisp bead to US $ 46 a barrel ( Akpan, 2009 ) . The transmittal mechanisms through which oil monetary values have impact on existent economic activity include both supply and demand channels. The supply side effects are related to the fact that rough oil is a basic input to production, and accordingly an addition in oil monetary value leads to a rise in production costs that induces houses to take down end product. Oil monetary value alterations besides entail demand-side effects on ingestion and investing. Consumption is affected indirectly through its positive relation with disposable income. Oil monetary value rises cut down the consumers passing power. Investing may besides be affected if the oil monetary value daze encourages manufacturers to replace less energy intensive capital for more energy-intensive capital. The magnitude of this consequence is in bend stronger the more the daze is perceived to be durable. For this ground, the theoretical literature has been of a general equilibrium nature, with different writers delega ting different weights to the supply and demand channels ( Olomola & A ; Adejumo, 2006 ) . When oil monetary value depreciates, big public sector expectedly can non cut down its disbursement instantly and proportionally ; so faces immense shortages. The financial instabilities followed by an oil monetary value lessening can be lay waste toing if the state is extremely dependent on oil grosss ; which is the instance in most oil exporting states. More disappointingly such falls are normally unpredictable. Several uncomplete undertakings and immense debts are the chief heritages of this period for the undermentioned fruitful epoch. After some rough experiences, presents, insulating the existent sectors of economic system from oil monetary value volatility is accepted as one of the most of import functions of authorities ( Mehrara & A ; Mohaghegh, 2011 ) . Presently, one-year budgets are formulated in Nigeria based on oil monetary values. The 2009 budget was revised in line with the predominating market monetary value of oil declarative mood of immense dependance of Nigeria on oil returns. In 2012, there was an intense argument refering the benchmark monetary value of Crude Oil that would be the footing of gross and outgo computations in the passing of the 2013 Appropriation Act ( budget ) through the Nigerian National Assembly. Huge influx of oil grosss in Nigeria are more frequently associated with enlargement in the degree of Government passing while periods of dwindling oil grosss are normally accompanied by budget shortages. There is no addition stating that Nigeria relies so much on gross from oil exports, but, it every bit massively imports refined crude oil and other related merchandises. Evidence, for case, shows that Government disbursement, which hitherto, before 1999 remained good below N0.5 trillion, hit N1.02 trillion grade in 2001 and N1.5 trillion in 2004. The figures for 2006 and 2007 stood at N2.04 and N2.45 trillion severally ( Aliyu, 2009 ) . Oil monetary value dazes are preponderantly defined with regard to monetary value fluctuations ensuing from alterations in either the demand or supply side of the international oil market ( Hamilton, 1983 ) . These alterations have been traditionally traced to provide side breaks such as OPEC supply quotas, political turbulences in the oil-rich Middle East and activities of hawkish groups in the Niger Delta part of Nigeria. The dazes could be positive ( a rise ) or negative ( a autumn ) . Two issues are identified sing the dazes ; foremost is the magnitude of the monetary value addition which can be quantified in absolute footings or as per centum alterations, second is the timing of the daze, that is, the velocity and continuity of the monetary value addition ( Akpan, 2009 ) . Traveling by the foregoing, four oil dazes can be observed in Nigeria. Each of the dazes had connexions with some motions in cardinal macroeconomic variables in Nigeria. For case, the 1973-74, 1979-80, and 2003-2006 periods were associated with monetary value additions while the oil market prostration of 1986 is an episode of monetary value lessening. During the first oil daze in Nigeria ( 1973-74 ) , the value of Nigeria ‘s export measured in US dollars rose by about 600 per cent with the footings of trade lifting from 18.9 in 1974 to 65.3 by 1982. Government gross which stood at 8 per cent of GDP in 1972 rose to about 20 per cent in 1975. This resulted in increased authorities outgo owing mostly from the demand to monetise the rough oil grosss. Investing was mostly in favor of instruction, public wellness, conveyance, and import replacing industries ( Nnnanna & A ; Masha, 2003 ) . During the oil monetary value daze of 2003-2006, Nigeria recorded addition in the portion of oil in GDP from approximately 80 per cent in 2003 to 82.6 per cent in 2005. The daze was gradual and persisted for a piece. This could be regarded as a lasting daze. The consequence of the daze was a favorable investing clime, increased national income within the period although a little diminution was observed in the growing rate of the GDP. Despite this sensed benefit of oil monetary value alteration, the macroeconomic environment in Nigeria during the roars was unwanted. For case, rising prices was largely dual figure in the 1970s ; money supply grew steeply, while immense financial shortages were besides recorded ( Akpan, 2009 ) . The growing way of the state has been really unsmooth over the old ages. During the oil roar epoch, approximately 1970-78, GDP grew positively by 6.2 per centum yearly – a singular growing. However, in the 1980s, GDP had negative growing rates. In the period 1988-1997 which constitutes the period of Structural Adjustment Programme ( SAP ) , which entails economic liberalisation, the GDP responded to economic accommodation policies and grew at a positive rate of 4.0 per centum. Agriculture, industry and fabrication, oil and gas sectors had greater laterality in the composing of the Nigeria ‘s GDP. The twelvemonth 1989 – 1998 was the most disruptive period in the history of the state ‘s growing form. Real GDP grew merely by an norm of 3.6 per centum, against the population growing rate of 2.8 % during the same period. Inflation, poorness, exchange rate were all at dismaying rates. Foreign direct investing, which is a necessary engine of growing, was stifled be cause of unsupportive enabling environment. Between 1999 and 2008, the state ‘s growing public presentation improved significantly. GDP growing rate averaged 7.8 % during the decennary entirely due to the growing of non-oil sector which grew by 9.5 per centum. In this respect, nevertheless, oil sector constitutes both a retarding force on growing and a beginning of instability in GDP growing form ( Aliyu, 2009 ) . Ongoing financial and pecuniary reforms aim to cut down the degree of rough oil dependence but at the minute, uncertainnesss about the degree of rough oil monetary values has cost the economic system a batch of investing chances over the old ages. In order for Nigeria to achieve balanced, uninterrupted and sustainable economic growing, the consequence of volatility in oil monetary values must be given equal attending.STATEMENT OF THE PROBLEMIn Nigeria, the rate of petroleum oil dependence is high. It accounted for about 82.1 % of entire authorities gross during the oil roar in 1974 before cut downing to a portion of 64.3 % by which was a effect of the rapid diminution in universe market monetary value of rough oil. The portion of oil gross in entire authorities gross still remains significant as evidenced by the attainment of 85.6 % and 86.1 % in 2004 and 2005 severally ( Akpan,2009 ) . This has generated a batch of involvement particularly amongst stakeholders in the Nigerian econom ic system. Of recent, is the argument in the Nigerian National Assembly about the appropriate petroleum oil monetary value benchmark to be included in the 2013 Appropriation Act which has generated a batch of contention. From a planning position, fluctuations in the petroleum oil monetary value have been the beginning of a batch of incomplete authorities undertakings due to the alterations in the gross watercourse and the dependability of cost estimations. The transmittal mechanisms through which rough oil monetary values impact on existent economic activity and analysing the dynamic interrelatedness among the selected macroeconomic variables is of great importance. Variations in rough oil monetary values hinders effectual economic planning and development most particularly for rough oil dependent economic systems like Nigeria. The impact of these fluctuations in footings of magnitude, continuance and way is of great importance if the Nigerian economic system must come on. The following are inquiries refering to the impact of rough oil monetary value volatility in Nigeria: – How significantly can Crude Oil Price fluctuations hinder sustainable economic growing in Nigeria? What magnitude of the alterations in macroeconomic variables is associated with fluctuations in rough oil monetary value?1.3 OBJECTIVES OF THE STUDYThe wide aim of this survey is to analyse the consequence of petroleum oil monetary value volatility on economic activity in Nigeria. The specific aims include: a. To analyse the consequence of oil monetary value volatility on the growing rate of existent GDP, Inflation rate, Money supply and other financial and pecuniary variables. B. To find whether there is a long tally relationship between oil monetary value volatility and existent GDP growing in Nigeria. 1.4 RESEARCH QUESTIONS The inquiries that guide the research are as follows: a. Is there a important relationship between Oil monetary value dazes and economic system activity in Nigeria? B. What is the magnitude of the relationship ( if any ) between Oil monetary value dazes and macroeconomic variables in Nigeria?1.5 HYPOTHESES OF STUDYThe followers are the research hypotheses to be tested during the survey: Holmium: Crude Oil Price has no important consequence on economic activity in Nigeria. H1: Crude Oil Price has a important consequence on economic activity in Nigeria.1.6 SCOPE AND LIMITATIONS OF THE STUDYThis survey on the consequence of volatile economic activity may be relevant to all states in the universe but the overall considerations, analysis and deductions are within the model of the Nigerian economic system. This survey covers the periods from 1975 to 2011. However, restrictions due to unavailability and undependability of informations could originate in the class of the survey and this should non be overlooked.1.7 DEFINITION OF UNFAMILIAR TERMSThe undermentioned footings used during the survey are explained below: a. Volatile: Care to change frequently or widely B. Organization of Petroleum-Exporting Countries ( OPEC ) : An organisation of states formed in 1961 to hold on a common policy for the production and sale of crude oil. Its members include Iraq, Indonesia, Iran, Kuwait, Libya, Angola, Algeria, Nigeria, Qatar, Saudi Arabia, the United Arab Emirates, and Venezuela.1.8 SIGNIFICANCE OF STUDYThis survey is of import to demo the extent to which the Nigerian economic system is affected by rough oil by analyzing macroeconomic variables. It is necessary to understand the way, continuance and magnitude of the relationship.1.9 METHODOLOGYThe variables to be considered include: a. Oil Price Variance B. Real Gross Domestic Product Growth Rate c. Inflation Rate d. Index of Industrial Production e. Money Supply f. Government Outgo The clip period under consideration is 1975-2011. The Ordinary Least Square Method is used because it is the best linear indifferent calculator. Garch ( 1,1 ) theoretical account is used to mensurate rough oil monetary value volatility and the conditional discrepancy series generates the volatility informations. Johansen Co-Integration technique based on vector autoregressive theoretical account determines the long tally relationship between oil monetary value fluctuations and GDP growing. Vector Error Correction Model ( VECM ) specifies convergence or divergency among the variables in the theoretical account. Trials for Stationarity ( being of unit roots ) such as the augmented dickey-fuller and Phillip Perron Tests will be employed. Variance decomposition, impulse response map, farmer causality trial examines consequence of Oil Price volatility on other variables.1.10 DATA BeginningsSecondary informations beginnings from Central Bank Statistical Database, Central Bank Statistical B ulletin, OPEC Statistical Bulletin British Petroleum Statistical Review of World Energy.1.11 OUTLINE OF CHAPTERS