Public Trust Doctrine: Indian Contours

Who owns the Earth and its resources? To what extent may the general public claim the pure water, clean air, rich soil, and the myriad services Earth provides to sustain human life? Across continents and spanning centuries, a dynamic tension continues between those who would circumscribe the Earth’s bounty for private use and those who would carefully allot Earth’s riches to satisfy human needs. Private property—sequestering Earth’s resources for personal, exclusive use—has its zealous advocates, and in many locales its legal status is unimpeachable, and its ideology is unquestioned.But a competing ideology, dating from antiquity[1], holds that some of Earth’s riches should never be sequestered for private use, must be left for the public’s enjoyment, and must be stewarded by those in power. Codified 1,500 years ago during the Roman Empire, legal scholars labeled this the â€Å"Public Trust Doctrine. † The Public Trust Doctrine perseveres as a value system and an ethic as its expression in law mutates and evolves. More recently, scholars, activists, and lawyers have begun discussing the rights of people to access and enjoy various essential resources and services the Earth so generously yields.The Public Trust Doctrine primarily rests on the principle that certain resources like air, sea, waters and the forests have such a great importance to the people as a whole that it would be wholly unjustified to make them a subject of private ownership. The said resources being a gift of nature should be made freely available to everyone irrespective of the status in life. The doctrine enjoins upon the Government to protect the resources for the enjoyment of the general public rather than to permit their use for private ownership or commercial purposes.Three types of restrictions on governmental authority are often thought to be imposed by the public trust: first, the property subject to the trust must not only be u sed for a public purpose, but it must be held available for use by the general public; second, the property may not be sold, even for a fair cash equivalent; and third, the property must be maintained for particular types of uses. I begin this article by tracing the historical origins of the Public Trust Doctrine, charting its (r)evolutionary leaps across centuries, legal regimes, and environmental entities.I then shift legal gears and analyze certain current environmental problems vis-à  -vis this Doctrine. I explore how the judicial creativity complements and expands the Public Trust Doctrine’s legal connotations, which, for 1,500 years, have constrained how Earth’s resources can be used and have guided who must bear responsibility for stewarding resources for the public good. Evolution of the doctrine Roman Law: 1,500 years ago, the Roman Emperor Justinian simplified the jumble of laws governing his Empire.He commissioned dozens of the era’s leading jurists, whose wisdom became codified in the Corpus Juris Civilis. [2] In 529, Justinian’s code contained a Section as: â€Å"By the law of nature these things are common to all mankind, the air, running water, the sea and consequently the shores of the sea. †[3] The Public Trust Doctrine, as this notion came to be known, suggests that certain resources—usually water, but now much more—are common, shared property of all citizens, stewarded in perpetuity by the State. 4] Several hundred years after the fall of the Roman Empire, a copy of the Corpus Juris Civilis was rediscovered in Pisa, and scholars spent centuries analyzing the tome. [5]In the peripatetic manner that has come to characterize it, the Public Trust Doctrine migrated with the Corpus Juris Civilis throughout Europe, to both civil law and common law regimes. [6] English Law: The Magna Carta codified Justinian’s words in England, and in 1225 King John was forced to revoke his cronies’ exc lusive fishing and hunting rights, because this violated the public’s right to access these common resources. 7] Thus in England, while the King had vested ownership of public lands, he stewarded them in trust for the public. This notion of government ownership of resources held in trust as a commons is a shared precept in all places where the Public Trust Doctrine persists. [8] Evolution in India: India has the roots of this doctrine in ancient Vedas when every king was to protect the trees and natural resources. But somehow it bore mere moral and religious obligations and lacked legal recognition. The PTD has been recognized as a part of law of the land in 1997 in the case of M.C. Mehta v. Kamal Nath. The evolution of the same has been discussed in the next Chapter. [9] An insight into Indian legal arena Article 21 of India’s constitution declares: â€Å"No person shall be deprived of his life or personal liberty except according to procedure established by law. â⠂¬ [10] Laws that conflict with or abridge fundamental rights named in the constitution are voided. [11] Citizens are allowed to challenge violations of these rights directly, and in fact citizen suits are the most rapid means to challenge actions that threaten fundamental rights. 12] In India, Judges have taken these substantive and procedural rights seriously and have buttressed them by establishing the Public Trust Doctrine to secure powerful protections for citizens’ Environmental Human Rights[13].While the constitution does not explicitly provide for Environmental Human Rights, Indian courts have gone further than almost any in naming environmental rights that serve the fundamental right to life. [14] The claims that impinge on Article 21’s fundamental right to life include various challenges where ecosystems have been impaired. 15] India’s Supreme Court stopped unauthorized mining causing environmental damage, holding that this â€Å"is a price that has to be paid for protecting and safeguarding the right of the people to live in a healthy environment with minimal disturbance of ecological balance. †[16] When a government agency action threatened a local fresh water source, the High Court of Kerala held that government â€Å"cannot be permitted to function in such a manner as to make inroads into the fundamental right under Art. 1. . . . The right to sweet water and the right to free air are attributes of the right to life, for these are the basic elements which sustain life itself. †[17] In a case upholding a statute that allows India to pursue justice following the Bhopal gas leak disaster, the Supreme Court further consolidated the link between Article 21’s right to life and the right to a clean environment. [18] In 1997, the landmark case of M.C. Mehta v. Kamal Nath[19] conjured up the Public Trust Doctrine in India. In that case, the Minister of the Environment (respondent) impermissibly allowed a motel to be built at the mouth of a river, and impermissibly allowed the motel to change the course of the river (which created subsequent flooding in nearby villages) in violation of the Public Trust Doctrine—which hadn’t explicitly existed before this case. 20]Before invoking the Public Trust Doctrine, the court alludes to: the classic struggle between those members of the public who would preserve our rivers, forests, parks and open lands in their pristine purity and those charged with administrative responsibilities who, under the pressures of the changing needs of an increasingly complex society, find it necessary to encroach to some extent upon open lands heretofore considered inviolate to change. 21] In this case, the court summons up the Public Trust Doctrine by first saying â€Å"The notion that the public has a right to expect certain lands and natural areas to retain their natural characteristic is finding its way into the law of the land. †[22] To justify thi s notion, the court cites excerpts from a Harvard Environmental Law Review article: â€Å"Human activity finds in the natural world its external limits.In short, the environment imposes constraints on our freedom; these constraints are not the product of value choices but of the scientific imperative of the environment’s limitations†[23] , promoting a new kind of natural law exigency for protecting environmental resources in the name of protecting fundamental human rights. [24] The court then revisited Justinian’s notion of the Public Trust Doctrine, including the exegesis of more than a half dozen seminal cases[25] of United States law that invoked and reinvigorated the Public Trust Doctrine. 26] The court concluded: â€Å"Our legal system—based on English common law —includes the public trust doctrine as part of its jurisprudence. The State is the trustee of all natural resources which are by nature meant for public use and enjoyment.Public at l arge is the beneficiary of the sea-shore, running waters, airs, forests and ecologically fragile lands. The State as a trustee is under a legal duty to protect the natural resources. These resources meant for public use cannot be converted into private ownership. 27] And thus the â€Å"aesthetic use and the pristine glory of the natural resources, the environment and the eco-systems of our country cannot be permitted to be eroded for private, commercial or any other use unless the courts find it necessary, in good faith, for the public goods and in public interest to encroach upon the said resources. †[28] The Supreme court for the first time recognized and declared, â€Å"the Public Trust Doctrine as discussed in this judgment is a part of the law of the land. †[29] In M. I. Builders Pvt. Ltd. v.Radhey Shyam Sahu[30], the Indian Supreme Court subsequently hitched the Public Trust Doctrine to the constitutionally guaranteed right to life. [31] The court held that a pub lic park and market are public trust resources that may not be replaced with a shopping complex. [32] Citing the precedent of M. C Mehta, the court reasserted that the Public Trust Doctrine is part of Indian law,[33] and thus ordered the appellant to restore the park that it had destroyed when it (and the government agency that permitted its actions) improperly violated the public trust. 34] The park in a crowded area is of â€Å"historical importance and environmental necessity. †[35] To allow the construction would mean that citizens â€Å"would be deprived of the quality of life to which they are entitled under the law. †[36]Because the government’s Development Authority was the trustee of the park, it had violated â€Å"the doctrine of public trust, which [is] applicable in India. †[37] The government authority was obliged to manage this park for the public good, and it â€Å"has deprived itself of its obligatory duties which cannot be permitted. [38 ] The court noted that â€Å"this public trust doctrine in our country, it would appear, has grown from Article 21 of the Constitution. †[39] The Public Trust Doctrine was invoked anew specifically to protect the fundamental human rights enshrined in the Constitution. Here, then, the Indian Supreme Court avers that the actions of the government and the private party appellant violated the right to life guaranteed in Article 21 of the Indian Constitution, and the government agency has committed these violations by violating PTD.Drawing on the Illinois Central[40] decision to explain Sax’s central tenet of the PTD[41], the court recited that â€Å"when a state holds a resource which is available for the free use of the general public, a court will look with considerable skepticism upon any governmental conduct which is calculated either to reallocate the resource to more restricted uses or to subject public uses to the self-interest of private parties. †[42] Subse quent litigation has affirmed the PTD’s relevance in Indian law.For example, the High Court of Jammu & Kashmir[43] allowed a manufacturing plant to be constructed, but only if the regional government observed its PTD duties to ensure that all possible pollution safeguards were implemented. A plant for filling cylinders with LPG was started after complying with the statutory requirements and clearance from PCB. When the residents objected the plant to continue and filed a writ of mandamus, the court after referring to Article 21, 47[44], 48-A[45], 51(A)(g)[46] and the post independence legislations invoked the doctrine of public trust and held that natural resources belong to people.The decision once again said that Article 21 of the constitution required that the government observe its public trust duties, for the â€Å"public has a right to expect certain lands and natural areas to retain their natural characteristics. †[47] The judgment also extended the scope of the Public Trust Doctrine, as â€Å"there can be no dispute that the State is under an obligation to see that forests, lakes and wildlife and environment are duly protected. [48] The Fomento Resorts Case (2009)[49]: Here, Fomento Resorts and Hotels Ltd had extended the construction of its hotel resort encroaching upon a public road and parking place which was a natural access to people visiting the Vainguinim beach. On a writ petition filed by a local residents, the Bombay High Court ordered demolition of the unauthorized structures following which the resort company preferred an appeal in the apex court.The apex court concurred with the view of the local residents that the unauthorized construction had put hindrances in their access to the beach. ‘Natural resources like beaches, forests, rivers and other water bodies are for uninterrupted and unhindered use of the general public and even the State cannot deprive them of their natural rights’, the Supreme Court held. Such rights are governed by the â€Å"public trust doctrine† and people can move the courts for enforcing the rights and directed Fomento resorts Goa to emolish its unauthorised construction on Vainguinim Beach, which had been overlooked by the state government. â€Å"The State cannot transfer public trust properties to a private party, if such a transfer interferes with the right of the public the court can invoke the public trust doctrine and take affirmative action for protecting the rights of the people to have access to light, air and water and also for protecting rivers, sea, tanks, trees forest and associated natural eco-system.The doctrine puts an implicit embargo on the right of the State to transfer public properties to private party if such transfer affects public interest, mandates affirmative State action for effective management of natural resources and empowers the citizen to question ineffective management thereof,† the apex court ruled. AN ANALYSIS OF THE JUDICIAL TRENDS The aforementioned decisions, however a major breakthrough, do not reveal whether the judges are saying this Doctrine has always been a part of Indian law, or whether it is a new provision.Mostly they seem to reiterate that United States law has always found the Doctrine to be part of its common law heritage as a British colony, and so should be done here as well. What is distinctively clear, however, is that the court felt the Public Trust Doctrine was necessary to bolster its demands on the government to advance constitutionally protected rights. It also appears that putting the Public Trust Doctrine in service of constitutionally guaranteed environmental rights puts not only new strictures on government, but also places new constraints on private property rights in India.Those constraints could be cast as a sextuple threat to Indian private property rights. First, the Indian Constitution mandates a fundamental right to life. Second, two decades and dozens of court cases interpret this constitutionally provided right to mean that environmental harms themselves are proscribed in order to serve the fundamental right to life. Third, to prohibit private acts that threaten environmental resources essential to safeguard the right to life, the Indian Supreme Court has repeatedly cited the â€Å"polluter pays principle and the precautionary principle† as emerging norms of international environmental law. 50] Fourth, the Public Trust Doctrine is asserted to buttress the government’s ineluctable responsibility to protect the right to life and the ancillary rights that serve the fundamental right.Fifth, private rights of action against private or government parties are permitted to vindicate the fundamental and corollary rights. Finally, the Indian Constitution requires an affirmative â€Å"fundamental duty† of every citizen of India â€Å"to protect and improve the natural environment including forests, lakes, rivers, wild life, a nd to have compassion for living creatures. [51] While a thorough examination of Indian private property rights is beyond the scope of this project, the combination of court-enshrined corollary environmental rights in service of fundamental right to life when accompanied with a decade-old reinvention of the Public Trust Doctrine means that whatever rights private property owners had before in India are now cast in a new, circumscribed way[52]. Contemporary Twists in the tale:Multi faceted Application of the doctrine National parks and national monuments harbor some of the most scenic areas in India. Each summer, motorists and tourist lineup to see the majesty of places like Kanha National Park , the holy shrines of Haridwar, Mankadevi, Rishikesh, Gangotri and Yamnotri and numerous Beaches and backwaters, gawking at wildlife and snapping photos to share. These public lands are also rich in natural resources like coal, oil, gas and timber.It is generally expected that Nation’s leadership would put these â€Å"public lands† wisely to use. Today, the conflict between protection of natural resources upholding the doctrine of public trust and the responsibility of state to manage national interests of industrialization and preservation of natural resources. Sometimes these conflicts are subtle, and sometimes the interests they represent are in direct opposition. This section discusses two case studies as a way to raise the issues.The first case the conflict is between traditional Native religious practitioners and commercial mountain climbing interests. The conflicts may seem more subtle as the policy makers see the mountain climbing â€Å"recreational† use that ought to be consistent with traditional native use since both depend, to some extent, upon the preservation of the mountain and its aesthetic qualities. However it is far too simplistic to assume that recreational use of public lands is consistent with â€Å"preservation† uses.Whi le environmentalists frequently deplore the idea that natural resources exploitation can achieve a friendly coexistence with â€Å"preservation† of these spectacular places, the current political and economic climate reflects the emphatic commitment to commercial exploitation of public lands. Native peoples’ longstanding interests in these public lands are frequently reduced to a religious attachment or, in policy terms, an interest in â€Å"sacred sites protection. All the policymakers overlook in the process that the native people have a unique relationship with their ancestral homelands, which are time and again encroached upon. Natives have legal, moral, political and cultural interests in their ancestral homelands, and these multiple and complex interests should not be described as purely religious in nature.The following case study addresses a compelling issue for contemporary policymakers: how do we protect the inherent rights of the people to the natural resou rces which are time and again endangered by industrial and commercial exploiters? 53] The story revolves around the tribes people of Kalahandi who oppose Vedanta[54]’s takeover of a region they hold in reverence. For the last one year, the Niyamgiri hills in Kalahandi district of southwestern Orissa have been reverberating with protests and demonstrations. The tribals of the area[55], who worship the hills as living gods—are taking on Vedanta, a UK-based mining major that has acquired a license from the government to exploit the abundant bauxite reserves in the pristine region.Conflicts between tribals and the state are nothing new—especially when they are portrayed as a struggle between the modern (read: progressive governments and corporates) and the primitive (read: tribals). Vedanta, in partnership with the state-owned Orissa Mining Corporation, promises to put India on the global map as undisputed leader in production of iron ore, aluminium and zinc. But th e tribals are asking if this should be at the cost of destroying their habitat, with which, in their animist traditions, they engage in a sacred covenant.And environment activists ask if there can ever be another Niyamgiri once the mining starts. A visit there is a trip to paradise—lush greenery, scores of streams crisscrossing the mountains, rich soil, an abundance of wildlife. In fact much of the region is protected under Section 18 of the Indian Wildlife Act, and the Orissa government had declared it an elephant reserve as recently as 2004. But once the mining begins, the ecosystem will be lost. The pollution and degradagion and degeneration has begun. The earlier warnings were all ignored.The first had come from the central empowered committee in 2002, constituted under the EPA[56]. The committee observed: â€Å"Had a proper study been conducted before embarking on a project of this nature and magnitude involving massive investment, the objections to the project from the environmental/ecological/forest angle would have become known in the beginning itself and in all probability the project would have been abandoned. † The second came from WII in 2006. Its status report said, â€Å"Mining could trigger irreversible changes in the ecological characteristics of the area.The cost-benefit value should not only take into account the material benefits of bauxite mining†¦ (but also) the perpetuity of the resources and ecosystem services that would be provided by these forests in the future. Compromising long-term economic returns, therefore, cannot be an alternative for short-term gains. † The apex court, however, ruled in 2008 that the company was free to mine after it complies with the due process of law. Today the public trust doctrine serves an important role in adjudicating tribal rights and state responsibilities. 57] Modern case laws have defined contours of State responsibility and highlighted it’s application towards prote ction of the interests of â€Å"We, the People. †Skeptics may say the process could allow Vedanta scope for intervention, but the tribal activists are steadfast in their resolve. â€Å"We’re not against development,† they say, â€Å"But the state must recognize the rights of tribal communities that have lived here for ages. † Critical analysis Is the public trust doctrine a threat to private property? Is it a vital, evolving common law doctrine? Or a metastasizing source of governmental uthority over private land? These are certain inevitable questions to be raised by the critics of the said Doctrine. Analysing the Doctrine, it can be said that it serves two purposes: it mandates affirmative state action for effective management of resources and empowers citizens to question ineffective management of natural resources. The Public Trust Doctrine can be used as leverage during policy deliberations and public scoping sessions and hearings. This forces agenci es to prove that their actions are not environmentally harmful to the extent that they will destroy a public resource.If the agencies fail to provide a more environmentally benign alternative, then you can bring up a Public Trust lawsuit. Although the court process may be long and arduous, many important precedents have been established. It is interesting to note that in the Kamal Nath case[58] the Supreme Court held that even if there is a separate and a specific law to deal with the issue before the Court, it may still apply public trust doctrine. If there is no suitable legislation to preserve the natural resources, the public authorities should take advantage of this doctrine in addition to the fact that there was a branch of municipal law.Secondly the Supreme Court in M. I. builders[59], however, stated that public trust doctrine has grown from Article 21 of the constitution. By attaching this doctrine to the fundamental right to life, the Supreme Court appears to be willing to diversify the application of this doctrine. It seems likely that the court would give precedence to right to life when the public trust doctrine, as a part of right to a safe and healthy environment, is challenged by any other fundamental rights.Thirdly by ordering the Mahapalika to restore the park to its original beauty, the Supreme Court redefined the duties of a trustee to its beneficiaries the users of the park. In effect, it aligned the local authorities duty as a trustee with the concept of intra-generational and inter-generational equity. Fourthly, the case came before the court as a judicial review and not as challenge against the decision of the government from a beneficiary. As this doctrine acts as a check upon administrative action by providing a mechanism for judicial or resource allocation decisions.Therefore, public trust doctrine could serve as an additional tool for environmental protection particularly where administrative discretion has been abused. IMPORTANCE O F PUBLIC PARTICIPATION FOR PROPER IMPLEMENTATION OF PTD Public participation is a necessary component of vibrant, dynamic, functioning and participatory democracy. It has potential to make all governmental decision making transparent, rational just, fair and responsive as a good governance practice which entails effective participation in public policy making provisions of the rule of law.Public participation also serves as a useful device to make government and its agencies accountable and at the conceptual level public participation is inextricably linked with democracy, decentralization, self-administration, self-management and respect for human rights and fundamental freedoms. The idea of public participation has also entered the arena of environmental protection and its recognition as an important part of environmental decision making is discernible at all levels of government. 60]The contribution of public participation in environmental decision-making to the substantive quali ty of decisions was given a significant boost with the entry into force of the Aarhus Convention[61] adopted through the United Nations Economic Commission for Europe. The Convention stresses that public participation in environmental decision-making contributes to â€Å"the protection of the right of every person of present and future generations to live in an environment adequate to his or her health and well-being. † NEED FOR PROPER FRAMEWORKOF LAWS IMPLEMENTING THE DOCTINEThe public trust doctrine could provide a practical legal framework for restructuring the way the oceans are regulated and managed. It would support ocean-based commerce while protecting marine species and habitats. The public trust doctrine is â€Å"a simple but powerful legal concept,† that obliges governments to manage certain natural resources in the best interests of their citizens, without sacrificing the needs of future generations. Extending the public trust doctrine to ocean waters would help State agencies better manage conflicting demands such as conservation, offshore energy development, fisheries and shipping in the 3. million nautical square miles of water included in the nation's territorial sea and EEZ.Currently dozens of laws, regulate species and activities in these waters, without any mandated, systematic effort to coordinate their actions for the public good. Though the public trust doctrine is well suited to serve as a critical legal foundation for a coordinated, ecosystem-based ocean policy, it has not yet been formally articulated by the executive branch, nor has it been recognized by courts or expressly established in statutory law.As we contemplate managing our ocean resources, not only for today but for future generations, we need to ask ourselves two critical questions: For whom should the country's oceans be managed? And for what purpose? The public trust doctrine answers both of these questions. International Scenario It is a common law concept, defined and addressed by academics in the United States and the United Kingdom. Various common properties; including rivers, the seashore, and the air, are held by the government in trusteeship for the uninterrupted use of the public.The sovereign could not, therefore, transfer public trust properties to a private party if the grant would interfere with the public interest. The public trust has been widely used and scrutinized in the United States (The Mono Lake case being the breakthrough)[62], but its scope is still uncertain. Various have been made to apply this doctrine to protect navigable and non-navigable waters, public land sand parks, and to apply it to both public and private lands and ecological resources.The Supreme Court of California has broadened the definition of public trust by including ecological and aesthetic considerations. Although the public trusts doctrine is not without its fair share of criticism it is being increasingly related to sustainable development, the precautionary principle and bio-diversity protection. The doctrine combines the guarantee of public access to public trust resources with a requirement of public accountability in respect of decision-making regarding such resources.Moreover, not only can it be used to protect the public from poor application of planning law or environmental impact assessment, it also has an intergenerational dimension. The Stockholm Declaration of United Nations on Human Environment evidences this seminal proposition: â€Å"The natural resources of the earth, including the air, water, land, flora and fauna and especially representative samples of natural system, must be safeguarded for the benefit of present and future generations through careful planning or management, as appropriate†¦ Conclusion Om vanaspataye Shanti Bhavantu[63] The Rishis of Aryavrata, the great thinkers of the ancient period pronounced above in the Vedas in no uncertain terms. However, we have sadly forgotten this pre cept except uttering the words occasionally while conducting havan to propitiate Gods and Nature without understanding the implication of this Mantra.In recent years these life supporting systems are gradually declining through the capricious exploitation of earth’s resources by the ever expanding human population in order to meet its growing material needs in the name of modernization and development and so does our relationship with natural resources continues to deteriorate till nature’s resources are exploited and utilized in a more rational & economical way to maintain a sustainable development. Environment is common heritage for all.Obviously, conservation and development can and must go hand in hand unrevealing and understanding the complexities of various eco-systems with a changing attitude of â€Å"touch-me-not† to â€Å"use me wisely†. It is evident that the state is not the owner of the natural resources in the country but a trustee who holds fiduciary relationship with the people. By accepting this task the government is expected to be loyal to the interests of its citizens and to discharge its duty with the interest of the citizens at heart and involve them in decision-making process concerning the management of natural resources in the country.The Public Trust Doctrine may provide the means for increasing the effectiveness of environmental impact assessment laws. The Public Trust Doctrine stands for the proposition that some of nature’s gifts inherently belong to all people, and the government must steward these to prevent both private arrogation of public resources and the â€Å"tragedy of the commons† from unfettered public access to these shared resources. [64] Environmental Human Rights represent a growing movement to codify this belief, to make positive law that firms up the philosophy promulgated for 1,500 or so years in the name of the Public Trust Doctrine.In addition, the Public Trust Doctrine h as expanded its reach to cover more of the Earth as the interrelatedness of ecosystem processes becomes more defined, and the success of the strategy in protecting those processes becomes more apparent. The Public Trust Doctrine encourages government officials to fulfill their stewardship duties. Judicial vigilance creates obligations erga omnes, i. e. , duties that must be performed. The Public Trust Doctrine urges judges to take a hard, skeptical look when government action appears to allow private interest to impede public trust environmental resources.The Public Trust Doctrine naturally shrinks what constitutes private property rights (and moves us to reconsider them as â€Å"private† â€Å"property† â€Å"rights†), either because certain resources never actually were subject to private usurpation, or never should have been. The Public Trust Doctrine has always reflected a value preference for public over private access to environmental assets. Invoking envi ronmental rights as human rights amplifies the public’s right, now and in the future, to share in ecological gifts fundamental to human health and wellbeing.

Witness

The development of characters is enhanced by Peter Weir’s film techniques? Discuss this statement with reference to witness The film Witness focuses on the clash of cultures, allowing Peter Weir to comment on the injustices of modern culture and the development of characters as a result. In the film Witness the Western World influences and changes the characters through the new experiences they face and encounter. Throughout the course of the film the Amish boy, Samuel Lapp undergoes many changes as he is influenced and corrupted by the horrors of the Western World as appose to the Amish culture which dwells on living a pacifist lifestyle within which he lives. The murder scene in Witness is critical to revealing the change of Samuel’s experiences from innocence to complete awareness of the horrors of the world. The close up of Samuel’s eye through the keyhole in the bathroom door reveals that we are seeing the course of events through his point of view and perspective on the situation. However in the bathroom scene Samuel witnesses a brutal murder which vicissitudes his character to one that has knowledge of the danger and violence in the Western World. The Western World’s morals and values of what is veracious and immoral are different to that of the Amish society. The Amish and John Book have different perceptions of justice as illustrated throughout the gun scene. In this scene both John Book and Eli reprimand Samuel when he touched the gun. The close up of Samuel handling the gun provokes contradictory responses from both John Book and Eli. John Book is concerned that the gun is loaded and hands Samuel the gun without bullets. To John Book the bullets symbolise the power to exert justice; the gun is purely the vessel like he is, from which justice can be delivered. The close up of Samuel directs the audience’s attention to the fact that it is Samuel whose mind is being influenced and challenged by his exposure to the western world. In contrast Eli’s view is that the gun symbolises the unclean nature of the Western Culture as it has the power to take away a man’s life. However the gun is purely an extension of a person’s values whether that is moral or unmoral values. The Amish culture dwells on the concept of peace within their community and lives a pacifist lifestyle; however when the western world collides with the Amish lifestyle many differences yet some similarities show through. This reveals Peter Weir’s ultimate comment the despite our differences and similarities uman nature draws individuals together. The western lifestyle is represented through the Dark music which conveys the cruelness and brutality of the Western World coming into and influencing and challenging characters within the Amish community. This is revealed in the final gun scene. In this scene John uses what is within the Amish community to defeat the corrupt cops that are coming against him. In the final gun s cene there is a sense of community in order to protect the Amish culture whereas the murder scene there is a sense of individualism and corruption.

Peace Corp Essay Example | Topics and Well Written Essays - 250 words

Peace Corp - Essay Example This was related to what we were engaged in at home (Kirk 53). The team comprised of persons who were IT enthusiasts. Unlike the friends in Africa, it was something I had encountered previously. Having engaged in communication processes during my earlier schooling endeavors, it was easy to help this young people enhance their skills in technology. I benefited greatly from this program. To begin with, I had the opportunity to work in an exceedingly remote region with no tapped water, electricity, and appropriate shelter. The roads in the villages were in a poor state. As a result, we had to stride stretched distances to amass information from youth projects deep in the countryside (Kirk 52). This made me tough thus acknowledging varied cultures and ethnic associations. Academically, I had the opportunity to teach IT skills to people who failed to comprehend such concerns. Evidently, I gained a lot from this through learning how to tackle problems together. Peace Corp offers a chance for people to engage in processes that help the neglected. As such, it builds personalities and enhances

African American Women in Labor Unions Black, Brave and Bold Essay

African American Women in Labor Unions Black, Brave and Bold - Essay Example Black women operated in American workforce and labor movements throughout the span of the mid nineteenth to mid-twentieth century.During this time,America was not a place where people of color were treated fairly, which was more evident in the south. However, this was also the span of time that marked the emancipation of slaves through the Thirteenth Amendment, which caused a mass migration of African Americans into the northern parts of America. Blacks had a better opportunity, though immensely unequal to that of whites, to minutely progress in status due to many laws and stipulations placed upon them because of their skin tone.Black women operated in American workforce and labor movements throughout the span of the mid nineteenth to mid-twentieth century. During this time, America was not a place where people of color, particularly African Americans, were treated fairly, which was more evident in the south. This prospect was more probable in the North.Moreover, during this time, wo men in general were not viewed positively. In fact, women were also emancipated from the bondage of not being able to vote, just as blacks through the Nineteenth Amendment. Therefore, to be an African American female laborer in American society in this time period was accompanied with many trials and tribulations.Since there were two strikes (being a black female) of African American women in the mid-nineteenth to mid-twentieth century, this study will investigate a few cases that showcase the strength of the black woman worker during this time. This study will compare and contrast the success of the various examples and explain how each one glorifies Marxists views. Marxist thinking caused black women of that era to stand for equality in the workplace. A synopsis of each case will be given and will explain how they relate to Marxist ideas. The study will be divided into empirical and theoretical questions that exist in Marxist ideologies. It will answer the question whether or not there is evidence that forms of society exist only for as long as they advance productive power, and are replaced by revolution. The theoretical question is whether there are sufficient evidences to support Marxist functional explanations. 1. Karl Marx (1813-1883) Karl Marx is a philosopher but is popularly known for his works as a revolutionary communist that inspired the foundation of many communist regimes in the 20th century. He has many philosophical ideas on other subjects, but this study will dwell on the political economic policy of Karl Marx that deals on the economic inequalities. He rejects the assumption that economic inequalities do not affect political equalities but focuses on the inequalities of neither individuals nor citizens but by the entire class. For Marx, the most fundamentally problematic inequality is that between those who own the means of economic production and those who do not. That some are rich and others poor is of concern, but this is only symptomatic of the former, deeper inequality. (Stamford Science Encyclopedia) Marx points out also to the inequality of sexes that is no longer economic in nature, but still forms a basis of capitalist political economic system. In a capitalist political economy, Marx contends that the economy, institutions of society and structure of society are controlled by the capitalist class and become basis for legitimacy. He said that the " ideologies of liberal democracy only serve to legitimate what is in fact a system of freedom and democracy only for some. The political equality emphasized by liberals is but a veil for the economic inequality that is so fundamental to a capitalist society and so detrimental to human freedom." (Source) As for other thinkers, equality is not an end in itself for Marx. Instead, equality in ownership and control of the means of production is a necessary prerequisite for freedom. 2. Other dedicated source synopsis 2.1 "We are all leaders". This is a kind of unionism that existed in 1930s. Staughton Lynd describes it as different from the bureaucratic business unions today. This was inspired by women nut pickers in St. Louis

Essay Assignment Example | Topics and Well Written Essays - 500 words - 4

Assignment - Essay Example It often comes with some challenges. This paper explores the benefits of working for an international firm as well as the disadvantages. First, working for an international company like BMW gives a person the chance of experiencing a new country with different culture. There is a possibility of an employee being posted to a foreign country, which is impossible with local companies. Working in a new country gives an employee the opportunity to explore places he or she may not have travelled to and experience new cultural practices across the world while getting paid. As such, working for an international firm is an adventure worth exploring. Second, working with foreign people at BMW enables one to get new business perspectives. Working in an international firm gives one an opportunity to develop a global view on business operations. Different countries have different approaches to doing business. As such, a person who works for an international firm is better placed to learn more about international business compared with someone who works for a local firm. Third, international firms like BMW usually offer their employees more competitive salaries compared to domestic firms. By accepting foreign appointment, one is likely to receive a potential increase in his or her income. This makes working for an international organization more of a fun and rewarding more than working for domestic firms. Fourth, BMW has a diverse workforce, which gives one the chance to experience the benefits of diversity in the workplace. The company is likely to give one a crucial opportunity of working with individuals of diverse backgrounds. One is in a position to learn different ways of solving a particular problem because different communities have different problem-solving approaches. While working for international companies such as BMW seems lucrative, there are some challenges for individuals who work for these organizations. First, cultural

Benefits of Bespoke Construction Contracts Term Paper

Benefits of Bespoke Construction Contracts - Term Paper Example Bespoke Contracts are core parts of the construction industry. The contractual agreements developed in the context of the specific industry are usually based on general contracts – which refer to all tasks usually developed in the context of construction projects; however, a construction project may be quite complex and it needs to be based on a contract developed especially for it: a bespoke contract will be used in this case to cover all aspects of this project; in other words, Bespoke construction Contracts are contracts tailored to the needs of a specific construction project. It is possible that the development of a construction project is primarily based on a general construction contract; during the development of the project it is made clear that certain aspects of the project are not appropriately or adequately addressed; a Bespoke Contract will be used to cover any gaps in the provisions necessary for the successful development of the project; in the above case, the Bespoke Contract will have a supplementary role in the project’s completion (O’Reilly, 1999, p.37). In order to understand the value of Bespoke Contracts compared to the existing construction contracts, we should refer primarily to the role of Bespoke Contracts within the construction industry. Bespoke Contracts can be characterized as contracts of specific characteristics; their structure and their content are likely to be influenced by the conditions of the market, the willingness of the parties but also the demands of a particular construction project.   All the above factors can influence the effectiveness of Bespoke Contracts – either in the short or the long term. In the study of Cox et al. (1997) the contractual environment of UK is set under examination; it is noted that in the contractual relations developed in the context of the above industry are likely to include the following elements: ‘the relationship, the risk apportionment, the division of responsibilities and the reimbursement mechanism’ (Cox et al., 1997, p. 127).

Leadership Types Essay Example | Topics and Well Written Essays - 500 words

Leadership Types - Essay Example This style is often referred to as ‘management by exception’, implying that transactional leaders are not interested in altering or transforming the work environment or employees, unless some problem occurs. Joseph McCarthy, a Wisconsin state senator is a famous example of transactional leadership due to his style of rewarding his followers for bringing him intelligence regarding communist spies, and punishing those who failed to follow his orders. Transformational style of leadership, on the other hand, is aimed to inspire and motivate employees, rather than expecting a set performance from them. Leaders following this style of leadership employ motivation and team-building tactics with employees. â€Å"The dynamics of transformational leadership involve strong personal identification with the leader, joining in a share vision of the future, or going beyond the self-interest exchange of rewards for compliance† (Hater & Bass, 1988). Jack Welsh, CEO of General Elec tric between 1981 and 2001, changed the bureaucratic organization into one in which employees stretched their potential to achieve long-term goals. Both styles of leadership are important, depending on different situations. However, transformational leadership holds greater merit in most scenarios, as it makes use of motivational tactics which go a long way to fulfill the esteem needs of employees, helping them to achieve self-actualization. In ethical style of leadership, leaders respect the rights and dignity of employees during the course of their leadership. Ethical leaders should treat, encourage, and direct their employees in an ethical manner. For instance, Lola Gonzales, founder and CEO of Accurate Background Check actually fired herself when she found out that redundancy was the only option left to keep her company afloat. Instead, she acquired a part-time job

Agile Software Development Methodologies Essay Example | Topics and Well Written Essays - 750 words

Agile Software Development Methodologies - Essay Example This paper presents an overview of the agile software development methodologies. The basic purpose of this research is to show that 'agile software development methodologies' are a superior design method that is why Scrum and XP rapidly emerging frameworks as  methodologies. This software development methodology is simple and much faster than all other traditional software development approaches. Basically, agile software development methodologies are based on iterations. In this scenario, small teams work jointly with other project stakeholders or customer to make out rapid prototypes, proof of concepts, or a wide variety of features in an attempt to classify the issue to be solved. In addition, the project team determines the necessary requirements for the iteration, develops the prototype, creates and runs suitable test scripts, and the user of the system authenticates the results of the tests. In the entire scenario, confirmation appears much earlier in the project development life cycle than it would with other traditional software development methodologies, and as a result allowing stakeholders to change requirements at the same time as they are still moderately painless to change (Serena, 2007; Rehman, ullah, Rauf, & Shahid, 2010). As discussed above, agile software development methodologies adopt the incremental and iterative way to improve the efficiency and usefulness of the overall software development process. ... bt, the customer’s contribution and active participation in the software development process helps software project teams build exact and high quality product. Another most important advantage of agile software development methodologies is that they do not engage a lot of documentation for the reason that the software development team depends almost completely on informal internal communication. In addition, agile software development methodologies offer an excellent support for the implementation of changes and continually revising any other stage of the software development process. Additionally, the outcomes of the agile software development methodologies come out in small incremental editions or releases keeping in mind the changing requirements of the project. If a change has been made to the existing requirements, then it is updated in the next iteration. Thus, the basic goal of agile software development methodologies is to give pleasure to the customers by satisfying t heir requirements at any stage of the project development life cycle (Rehman, ullah, Rauf, & Shahid, 2010; Boehm & Turner, 2003). In addition, the agile software development methodologies are aimed at effectively dealing with the changes throughout the software development process. For instance, agile development methodologies such as SCRUM, Feature-Driven Development, and eXtreme Programming (XP) intend to minimize the expenses of changes all the way through the software development life cycle. In this scenario, XP is based on the quick iterative planning and development cycles with the intention of forcing trade-offs and offering the utmost value characteristics as soon as possible. Also, XP incorporates a wonderful characteristic recognized as â€Å"constant and systemic testing† to

Changing the age of gambling Essay Example for Free

Changing the age of gambling Essay Everyone has gambled something in their life; it could be betting your baseball cards to see who can eat the most slices of pizza, or who is paying for soft drinks as each races to the nearest QuikTrip when you were kids. But why at the age eighteen, when we are considered adult citizens, do they restrict our rights to gamble in most casinos? If they restricted our rights to gamble, what would be next on their agenda? We need to put a stop to it now, by taking that step to re-evaluate the gambling age at twenty-one. The legalization of gambling at the age of eighteen would bring unity throughout the states, state revenue, and job opportunities. If the United States legalizes the age of gambling to eighteen it would unify all the states and discard all confusion about the age of gambling. Our neighbor from the north, Canada, has legalized gambling to the age of eighteen and prospered vastly from it. Currently, there are casinos in Las Vegas, Atlantic City, etc. that are for the ages of twenty-one. But on the contrary, there are currently casinos on cruises and Indian reservations that are for the ages of eighteen (United 22). If America wanted to set an example for all the countries around the world, they must show more consistency with their own policies. Changing the age of gambling uniformly throughout the states has more benefits than disadvantages. The main argument against changing the gambling age was the addiction that it would bring to the people. The addiction of gambling would ruin lives and bring separation between their families (Morris 14). But why all of sudden does the government care about ruining peoples lives and separation between families? Take for instance, all the lives the government ruined through wrongfully accusing victims that are sitting in prison for no apparent reason. Also, look at how unjust that as an eighteen year old adult can serve for our country and risk their lives by being separated from our family but are still not allowed to gamble. The government does not need to put so much restriction on the minor problems, with this resolution it would allow them to focus on the major issues in the United States today. The unification of the gambling age like Canada has vastly increased the economy with casinos. Gambling in Canada has a net economic benefit that was equivalent to $3. 044 billion in 1995, up from $526 million in the 1990 economy (Council 3). Casinos in Las Vegas made $6. 1 billion in revenue since the first one opened (Council 5). Las Vegas revenue would easily triple if the legal gambling age was changed to eighteen. There tends to be casinos on Indian reservation that was for eighteen year olds and seemed very busy. Not only do they make money, but a large amount of the money was made from eighteen year olds who are attracted from surrounding cities according to one of the blackjack dealers. When the Aztar Casino opened up in Evansville, Indiana, gambling opponents feared that it would increase crime rates and encourage prostitution in the state. One would almost say that they were disappointed when their prophecies didnt prove true (Morris 19). The statistics have failed to support either the claim that the casino has caused a crime increase or any other negative expectations. As more states allowed gambling casinos in the past decade, the consensus was that casinos lowered the crime rate in the communities in which they were located. Lobbyists, developers and management pointed to studies showing dips in the crime rate after a flurry of casino construction in the 1990s (Morris 19). Casinos would become busier with the change of age to legally gamble and in return hire more positions. The gambling industry has become a major employer in most provinces in Canada, employment in the gaming industry increased from 11,900 to 39,200, an increase of 330% (Earl 7), and in Las Vegas every casino has at least 4000 employees (Earl 8). According to the 2000 census, there are about 1. 1 million eighteen year olds in the United States. Casinos would gain more business and hire more employees because of the increased business. People gambled for a variety of reasons, whether for a break from their daily lives, the thrills of the chase, or the challenge of beating the odds. Gambling should not be restricted to a certain age or to a certain area. If we legalized the age of gambling to eighteen we would bring unity throughout the states. Changing the gambling age to eighteen could maximize the states revenues through people being employed and people constantly visiting. There should be a change of the gambling age to eighteen because this policy would restrict and violate our rights as citizens within the United States. Works Cited Council of State Governments, Gambling; A Source of State Revenue Lexington: RM, 1973. Earl L. Grinols, Gambling in America: Cost and Benefits New York: Cambridge University Press, 2004. Morris Ploscowe and Edwin J. Lukas, Gambling: American Academy of Political and Social Science Philadelphia: Annals, 1950. United States Congress: Senate- Select Committee on Indian Affairs, Gambling on Indian Reservations and Lands Washington D. C. : G. P. O. , 1985.

Aims and Objectives Essay Example for Free

Aims and Objectives Essay Hypothesis: Shopping centres in the Central Business District area are better in the sense that they provide a higher level of quality and variety of goods than the shopping centres in the residential areas. Aims and objectives: * Our general objective is to compare and contrast two shopping centres in the Central Business District (CDB) against another two shopping centres in the residential areas. We are also keen to investigate the various factors that influence the people’s decision to patronise the particular shopping centres. For example, the shopping malls in the CDB areas might be a better place to shop in terms of shopping quality and variety but on the other hand, the shopping malls in the residential areas might appeal to the public better in terms of close proximity to their homes and convenience. Our studies will intend to find out the link that exists between the shopping centres of our choice, and uncover a pattern that we will be going in further detail in our results and findings according to public opinion through means like surveys and in addition, our own feelings on the contributing factors or reasons. Our main focus would be the quality of shopping provided by the shopping mall. This includes the services, accessibility and the facilities provided that improves the shopping experience for the patrons. We will be taking surveys of the patrons there to find out their feelings about the shopping mall and its quality. We would also go there and do general analysis of the mall ourselves. This is to give us a base of comparison between our ideas of good quality compared to the peoples’ idea of good quality observed in a shopping mall.

Treatments for Type 1 Diabetes

Treatments for Type 1 Diabetes Type 1 Diabetes, which normally called as juvenile onset or Insulin-Dependent Diabetes Mellitus (IDDM) are usually appear during childhood, teenage years, or early adulthood(7,8). In the Islet cell of pancreas, Beta makes insulin. It is an autoimmune disease meaning that immune system will destroys beta cell, hence insulin cannot be produced. As a result the cells in our bodies will not be able to process the glucose and therefore have no energy for movement (21) . Moreover, the glucose is unable to be transferred from bloodstream to the cells and the glucose level will increase in the blood compared to normal. Main symptoms include blurred vision, passing urine more often than usual and unusual thirst(8). The problem Diabetes was the seventh leading cause of death listed on U.S. death certificates in 2006. This ranking is based on the 72,507 death certificates in 2006 in which diabetes was listed as the underlying cause of death (11). Moreover, IDDM cannot be prevented as it mostly inherited by the parent cell as the research said if you have a family member with Type 1 Diabetes, your risk is about five to six percent, compared to the risk in general population which is 0.4%(2). Hence what are possible treatments to replace the insulin to minimise the rise of glucose level in the blood? (248 words) A POSSIBLE SOLUTION Insulin pump therapy Insulin pump is a small mechanical device, a little larger than a pager that is worn outside the body, often on a belt or in a pocket (13). It will deliver insulin through cannula on the infusion site and the patients have to decide how much insulin will be given as it is not automatic. Nipro Diabetes Systems Amigo OmniPod Insulin Management System The goal of insulin pump therapy is to imitate the insulin secretion pattern which can be seen in people without diabetes. Two patterns released by insulin are: Basal insulin is insulin that is delivered continuously in small amounts. Bolus insulin, which is extra dosed insulin released for controlling the glucose level after taking meals (2). (388 words) Standard bolus indicates insulin is pumped completely and diffuses at the onset of bolus. Spike shape was pumped which expected to act the fastest possible for that kind of insulin. Hence, they must take meals which contain high carb and low protein and fat in order to lowers the blood sugar levels quickly. Extended bolus represents the spreading of insulin over time by slow infusion. By pumping square wave shape, the bolus is avoiding a high initial dose of insulin entering the blood causing low blood sugar level before digestion. Therefore, they should take more high fat high protein meals such as steak, which will be raising blood sugar for many hours past onset of the shape. Figure is a combination bolus of spike shape and square wave shape (12).Combo bolus.JPG This will give larger dose of insulin at first and extent the tails of insulin action. As a result, those who have combination bolus are appropriate for high fat meals such as pizza and chocolate cake. (608 words) This method can increase the spike bolus action and extend the action for several hours. Thus, super bolus people must take certain foods (like sugary breakfast cereals) which cause a large post-prandial peak of blood sugar. It attacks the blood sugar peak with the fastest delivery of insulin that can be practically achieved by pumping. In the year 2009, about 1119 pumpers are recorded in United State and this is the one of the solution for mimicking the production of insulin in the body. The age group ranging from 0 to 20 shows the highest user of insulin pump; hence it is proven that diabetes type 1 usually appear in childhood and teenage years. (767 words) Over the years, a number of different types and brands of insulin have been developed to meet different needs. SOCIAL AND ECONOMICAL IMPLICATIONS Katherine G who was diagnosed with diabetes and keep asking what had I done wrong? And wanted to smack every overweight person she saw. From Gretchen Becker The First Year Type 2 Diabetes copyright 2001(1). First and foremost, after being diagnosed as diabetic, some of them cannot accept the fact and take some time to mourn their loss. Some of them might fell depressed for example: In 2007, the world is estimated to spend at least USD 232 billion to treat and prevent diabetes and its complications. By 2025, this lower-bound estimate will exceed USD 302.5 billion. Source: http://www.worlddiabetesday.org/files/docs/Economic_aspects.pdf(15)They also worried about the next generation as Type 1 Diabetes is inherited and get stress thinking about the complication of diabetes which cause them to use wheelchair because has no feet and also being wheeled in order to use the dialysis machine(1,5). They may lose their self esteem to face the world. Some might be under pressure as they have to be strict on their food intake and must follow the diet for diabetic. Moreover, they need to take a lot of medicine and also insertion. From this statement, I can concluded that diabetes is a highly cost disease. First and foremost, the insulin pump therapy itself is a very expensive and a lot of money spends for buying the insulin needed for pumping. Secondly, diabetes has long term complications which are dangerous for instance retinopathy, neuropathy and also kidney failure. They must use a lot of money in order to prevent these complications from spreading at their body. As we all know, not all diabetic people are wealth and they only depend on only one income source, hence can we imagine how they would survive with this disease especially those from the poorest countries and family. (15) (1307 words) BENEFIT AND RISK Advantages BEST hbA1cs before the pump The level of hbA1C decreases with an average of 6.3 after using the insulin pump compared to 7.2 before using the pump. The pumper users also show decreasing pattern from 725 to 713. So, the percentage of getting long-term complication for instance stroke, heart disease, blindness, kidney failure and also amputation can be lowered. (1383 words) Pumpers have been shown to experience lesser episodes of severe hypoglycaemia compared to people who take injections. Clinical studies shown that using fast acting insulin, the glucose control can be improved with less risk of hypoglycaemia (3,22). Moreover, the pumper can keep up-to-date with their daily schedule. They are flexible to move and free to do what they want for example they can keep on the pump during exercising in the evening. Insulin pumpers must change the infusion site about three times a week, and using about only 156 insertion a year but the injection can achieved mean more than 1,400 injection per year. (3,22) (1527 words) Disadvantages An episode of diabetic ketoacidosis state of inadequate insulin levels resulting in high blood pressure and accumulation of organic acids and ketones in the blood may take place if the pumpers do not receive sufficient amount of fast acting insulin for many hours. There is high risk of infection if the catheter site of cannula has not been changed every three days and also skin reactions such as rashes may appear at the site of cannula. This therapy is very expensive as pumps are high prices. By using insulin therapy, the society might know that you have diabetes since this is one of the popular ways to cure it (19) . Some of diabetic might develop blurring vision soon after starting insulin due to a change of lens refraction and it will correct itself within two to three weeks (3) . The picture 2 shows the process of forming of diabetic ketoacidosis. Source: http://www.deo.ucsf.edu/type2/diabetes-treatment/complications/diabetic-ketoacidosis.html (1669 words) ALTERNATIVE SOLUTIONS Exercising People, who exercise regularly, when compared to those who do not exercise, decrease their chance of developing diabetes by 30 to 50%. Exercise help by improving the bodys to use insulin and causes cholesterol level and blood pressure to drop (4). Aerobic exercise burns calories to help in managing the weight, strengthen the heart and lungs and gives endurance. In other word, it improves the bodys ability to use insulin and prevent diabetes. We must do warm up and cool down before and after exercising. Take at least 20 minutes and three times a week to exercise. Furthermore exercise can increase the uptake of glucose by muscles thus increase in carbohydrate intake. We must take enough carbohydrate before exercising but overdose of carbohydrate will results in hyperglycaemia. As diabetes, insulin must be sufficient before and after exercise because strenuous exercise and insufficient insulin will worsen diabetic control (5). Supplement vitamin and herbs Vitamin E helps dissolve fresh clot in veins and reduce the oxygen requirement of tissue and cell. Moreover, it also helps to from new skin (in healing the ulcer and burns) and increases the blood supply to tissue, thus reduces diabetes gangrene and amputations. Vitamin E reduces the need for insulin in 30% of diabetes (6). Biotin is B vitamin that functions in manufacture and use of carbohydrate, fat and amino acids. It enhances insulin sensitivity and increase the activity of enzyme glucokinase, enzyme responsible for the first step in the use of glucose in liver as this enzyme is low in diabetic. It also helps in the treatment of diabetic neuropathy (7). (1937 words) EVALUATIONS Through the years, we have introduced valuable solutions for patients and healthcare professionals-including continuous glucose monitoring (CGM), CareLinkà ¢Ã¢â‚¬Å¾Ã‚ ¢ Therapy Management Software and the MiniMed Paradigm ® REAL-Time System, the worlds first integrated insulin pump and CGM System. Source: http://www.minimed.com/about/index.html (22) From the book of Diabetes Demystified written by Masharani, M.D copyright 2008(2); provide us a brief about diabetes. It helps us to know well about diabetes and why they have this disease. Moreover, ways of taking care for diabetic people also included and it provides me with the chart and also graphs for better understanding. The information are also available in the other books (1,4,5,6,7,8).Hence the facts are reliable. However, the publishing date was 2008 and the information might not be updated. I believe this website; has given me reliable and factual data. This is because it is owned by Medtronic Minimed, Incoporation and has been updated the info this year, 2010. Furthermore, they had led the technology about insulin pump therapy for 25 years and pioneered it since 1983. It helps pumpers to understand better about good control, insulin pump therapy and why pump therapy rather than the other. (2168 words)

Makeover Feminism Essay -- Social Sociology Feminism Essays

Makeover Feminism Most viewers of commercial television or consumers of popular magazines have seen striking images of women whose appearance has been dramatically altered. Many of these â€Å"made-over† women changed their body image through diet and exercise regimes, skillfully applied makeup, or elective cosmetic surgery. Possessed of higher education, prestigious careers, and families, these successful women often report that they felt some aspect of their appearance prevented them from reaching their goals. Responding to criticism from feminists, they defend the choice to enhance their appearance as a tactical effort to win power in normative society. Drawing on popular media interpretations of third wave feminism, women compelled to politicize a personal decision to â€Å"improve† their image have wrapped this act in ideological jargon. Makeover Feminism is a cheeky new slogan meant to express the idea that conformity to cultural norms of physical beauty achieved through artificial and sometimes extreme means asserts female power. These women deny submission to patriarchal fantasies of the feminine ideal, claiming agency in the choice to alter their faces and/or bodies. Significant numbers of females submit to costly and dangerous, deforming, and potentially lethal procedures in an effort to claim power through beauty. This trend is visible in the annals of medical journal statistics that demonstrate an increase in the number of elective surgeries undergone by women in the last ten years. ------------------------------------------------------------------------------ Year Total Annual Procedures ----------------------------------------------------------------------------... ...ted, feminism is basically a shift from woman as eternal Other—always defined from outside—to woman as Self. Makeover Feminism, despite its sincere discourse within the tradition, cannot accomplish the goal of female liberation. Works Cited American Society of Plastic Surgeons. â€Å"National Clearinghouse of Plastic Surgery Statistics.† 2004. 12 Aug. 2004. . Donovan, Josephine. Feminist Theory: The Intellectual Traditions of American Feminism. New York: Continuum, 1992. Franzoi, Stephen L. Social Psychology. 3rd ed. New York: McGraw-Hill, 2003. Laing, R.D. The Politics of Experience. New York: Ballantine, 1973. Lotz, Amanda D. â€Å"Communicating Third-Wave Feminism and New Social Movements: Challenges for the Next Century of Feminist Endeavor.† Women and Language 26.1 (2003): 2-9.

How The Web :: essays research papers

The internet is a great invention because it makes things a great deal easier for us nowadays. It is also helpful in many ways, especially, in the way of convenience. Rather than go somewhere to pay your bills, you can just do it online with a credit card. You can also check your bank statements and find out where you stand financially. These are example of good ways that the internet helps out in the world. I would have to agree with David Rothenberg when he says that the web is ruining student’s research papers. If I was a collage professor and I were to see that all of my student’s papers seemed so fake, I would be devastated. When the internet is abused to the point where it is used for just anything will affect the loss of originality, laziness, and students reading less.   Ã‚  Ã‚  Ã‚  Ã‚  While students are in collage, they do many research papers on certain topics. Most of them dread doing these kinds of papers because the numbers of pages are high. They are also time consuming and that is a big issue to a student because we all have our own lives, most of us, as we know, never have much time to spend on just a paper. So, most of the students in college try to do the easiest thing, like resort to just the internet. There is a very important term that is used in college a lot, that term is called Plagiarism. If any student turns in a paper that is plagiarized, they are kicked out of that college and given a large fine. The internet plays a big role on this word. So many people are victims of plagiarism because they only use the internet and forget about using other sources like encyclopedias, books, and newspapers. Back then, it wasn’t a problem, but nowadays people just what to do things the easy way.   Ã‚  Ã‚  Ã‚  Ã‚  Secondly, since the internet is revolved around everything we do, students have now become lazy. Most of the world advertises that school assignments must be revolved around computers; even librarians say this as well. The more our technology develops in this world, the easier everything becomes. Nowadays, it’s about what makes your life easier and more convenient and I think there should be a change. On the internet there are so many short-cuts. Instead of reading carefully, and synthesizing, we do cut and paste, change the font size, and readjust the margins.

Career in Criminal Justice

There are several different careers to choose from in the criminal justice field. I was unsure of which direction to go in until I joined the military. One of the career paths that interest me is a career in the military. My second choice would be outside of the military. The two professions that interest me the most is OSI (Office of Special Investigations) and DEA (Diversion Investigator). Both of these jobs have many comparisons and some differences. The first job that interest me the most is Office of Special Investigations. OSI is an officer or an enlisted job in the United States Air Force. Basically, you have to plan and conduct investigations. They interview witnesses and interrogate people who is suspected of committing a violation of the UCMJ (Uniform Code of Military Justice). This job consists of many responsibilities such as conducting lineups and fingerprint suspects, write reports, provide testimony at court proceedings, and participate in surveillances and crime scene searches. Some of the skills needed to perform this job is great writing and speaking skills. Also you need to have qualification to bear firearms. The reason why this is important, because all knowledge is mandatory of special investigative policy. Also techniques in fraud, counterintelligence, personnel background, and technical security services are demanded as well. Other skills needed for the criminal justice field that coincides are driving skills, report-writing abilities, and significant weapon skills (p 205 Schmalleger). Other qualifications is to pass the United States military physical fitness test and their background check. You have to be physically fit to perform this job and maintain criminal free record. You can read also  Justice System Position Paper   The second job that interest me is a Diversion Investigator. This job is part of the Drug Enforcement Administration. You have to perform many duties such as examine the accounts of manufactures, pharmacies, and hospitals. Conducting security breaches, investigating the misuse of pharmaceutical prescriptions, and retrieving contraband is also part of the career field. Their mission is to enforce the controlled substances laws and regulations of the U. S. and bring it to the criminal and civil justice systems. They have many responsibilities such as proper investigation, prepare for rosecutions of major violated crimes, manage the drug intelligence program, and conduct a professional work environment at all times. Some of the skills that are required is to have the ability to gather research and analyze data, interpreting regulations, and the ability to communicate. Some of the criminal justice skills needed is having administrative skills, management techniques and radio communicatio n skills (p 205 Schmalleger). With this profession you have to pass a background check, pass a drug test and be physically fit. In some cases, you may have to relocate. In conclusion, the skills listed for both jobs are needed to accomplish the mission. They are required to help prepare a potential investigator for the real world. It enables you to perform at optimal levels of extreme and stressful situations. These career fields inspire me because, the very skills needed to perform the job are parallel to my professional long term goals in numerous ways. With both jobs, you need great communication skills are the foundation of the mission. Being able to write and speak clearly is also a key. As an investigator, I am confidently sure you will be doing a great amount of writing and a whole lot of public speaking. Testifying in court will be often for you. The reason why I am interested in OSI is because I am already a part of a career field that is similar and will be able to advance in the military as an investigator. The reason I would be interested in DEA is because, I have great management skills and will maintain an ambitious attitude to protect the United States military and civilian population from misuse of drugs. You can read also King v Cogdon The strategies I would use to achieve the skills needed for the jobs I selected is the criminal investigations strategy and the emergency response strategy (p 212 Schmalleger). The criminal investigation strategy is the manner by which a hearing of evidences involving to an existing delinquency is amassed. This could be leading up to an apprehension. The emergency response is the manifestation of a cop at an event when there is an instant threat at hand. Both of these strategies will be of use to achieve the skills needed for my career choices.

Historical Figure in Nurse Anesthesia Essay

From time immemorial there have been operations or surgeries of very kind practiced by both medical doctors and traditional healers. Both major and minor surgeries were very painful because nothing had been discovered to relief the pain or cause numbness for these surgeries or operations to be less painful. (Karlet 2004) notes, â€Å"With time some pioneers on medicine tried everything and every way to find something or some drug that may relieve the pain. However, the most looked after drug was the one that will induce sleep or unconsciousness at the same time creates lack of sensation†. History has it that many early doctors tried many ways until one William Morgan discovered and introduced surgical anesthesia of its kind and it proved working even better than any other anesthesia of that time. This paper will focus on William Thomas Green Morgan, his achievements, challenges, controversies and successes. It will analyze the impact of his discoveries from his times to the modern times in nursing anesthesia. However, (D’Antonio 1999) notes that, â€Å"the discovery of anesthesia was dogged with controversy for the reason that many people at that time wanted to go to the books of history and to be known as the first to discover the most sorts after remedy in the world of medicine†. Impact Analysis. William Thomas Green Morgan was born in the year 1819 in Charlton Massachusetts. He attended Northfield and Leicester academies for his education. After school William T. G. Morgan was an enterprising young man of many interests as he tried his luck in everything that came on his way. He became a painter for a while, then worked as a clerk in Worcester County and later tried his hand in business as a salesman in Boston. William Morgan never showed interest in medicine or anything related to medicine. Nevertheless, when he tried all these ventures, he never found them satisfying and thus he was not settled. After all these adventures Morgan joined Baltimore College of Dental Surgery in eighteen forty (1840). This was the world’s first college of dentistry even though William Morgan was not the first student to go through this college. During his studies Morgan partnered in business with Horace Wells who was a dental doctor by profession in Hartford. Morgan found that the partnership was not promising and working the way he wanted and thought thereby dissolving their partnership after a few months. After this partnership dissolution, Morgan the dental student left the college midway and hence did not graduate (Wolfe 2001). In the year 1844 William Morgan joined college again and this time round it was the prestigious Harvard Medical School. His intention was to increase or advance his dental knowledge even though it was shadowed by trying to impress his girlfriend Rebecca by name who he married later. Unfortunately this time again he never completed his degree from Harvard medical school. However, he developed curiosity in the field of medicine and because he never completed his degree, he started attending chemistry lectures by Professor Charles Jackson. From this time on William Morgan developed great interest and liking in chemistry and medicine in general despite the fact that he was more business oriented than a medical practitioner. During his attendance in chemistry lectures that touched on ether and its properties Morgan felt to capitalize that opportunity of using ether to lessen pain or create lack of sensation during surgery. It was a horrendous experience especially when patients were recommended for amputations. William Morgan himself during his youth had undergone a very painful surgery but fortunately he survived. At last there was some promising remedy as the inhalation of ether caused or induced unconsciousness. William Morgan tried these ether properties while extracting a tooth of a patient and it was very successful and painless. He went as far as testing this ether on himself and animals which worked right. This showed how eager and curious he was to invent the proper anesthetic to help patients recommended to undergo surgery. The history of anesthesia was awakened. Before William Morgan many other remedies of painless surgery had been tried but they were not a success and some became poisonous. Some reduced the pain and some did not. Alcohol was used and it was not a success story. William Morgan used ether after keenly learning its properties and Professor Charles Jackson. This was the anesthetic that had been discovered because William proved it right after extracting a patient’s tooth painlessly in Boston. At last William Morgan was relieved but controversy started after claiming to have discovered an anesthesia which indeed worked. However, he continued practicing as a dentist and the money from this proceedings or practice supported his education (Wolfe 2001). Morgan was more a businessman than a dentist as controversies surrounding his discovery raged on as (Wolfe 2001) claims that â€Å"William Morgan was an unsuccessful businessman, an embezzler and a poorly trained dentist who saw in an anesthetic properties of ether an opportunity to become rich†. The controversy was among his competitors, among them Horace Wells the dentist and Professor Charles Jackson the chemist who was his lectures. But it was William Morgan who in 1846 became the first man to use ether to extract a tooth of his patient painlessly in Boston General Hospital. Early William Morgan had tried opium which only but relieved pain (Wolfe 2001). This and many other attempts aroused the eagerness to find anesthesia nevertheless ether became very popular not only in Boston and the United States of America but the discovery news spread around the whole world like wild fire. Communication during those years was extremely underdeveloped and poor but transport by water was in use and the sailors carried the good news of the discovery to Asia, Europe and Australia far down the Pacific. Many doctors and surgeons wanted to prove the good news as others criticized it. The discovery and the experimentation of ether by William Morgan was very controversial because even his teacher wanted to be recognized as the one who discovered the anesthetic properties of ether, but it was clear that all these people who claimed to be the first to make the discovery did not attempt to test and put it into practical use, only William T. G. Morgan dared and indeed he succeeded. In the United States the controversy raged on as who was who that was behind etherization as William Morgan continued to use it on his patients and it really worked. (Royal College of Anesthetists 2008), â€Å"Morton conducted various experiments on him and animals and afterwards he successfully performed a dental extraction in his office in Boston. † As time went by Morton’s experience with ether was a success, the horrible and noisy surgeries were past tense. William Morton went a step further to invent an ether delivery instrument which he called Letheon Inhaler which was used by patients to inhale ether. (The Royal College of Anesthetists. Internet source 2008). William Thomas Green Morton was a man to reckon with during the mid 19th century because his inner drive desire was to alleviate the pain and the suffering of patients recommended for surgery even though in the back of his mind he wanted to make profit out of it. This had caused controversy among historians. After all William Morton was open-hearted because he gave his discovery to the world without any restrictions. However, he was unsuccessful to patent his Letheon Inhaler. (Royal College of Anesthetists 2008) notes that, â€Å"Morton offered free rights to his innovation to all charitable institutions the country and undoubtedly he was ardently in favor of the abolition of surgical pain although with profit to himself†. Morton’s discovery was handy during the American bloody civil war as many injured soldiers were relieved of pain and operated on painlessly by the use of ether. Morton himself administered ether to thousands of the combatants in the civil war. (The Royal College of Anesthetists. Internet source 2008). These controversies dogged him for a long time until one time he met the then 14th president of the United States Franklin Pierce to highlight to him the controversies he was facing so that he can give a verdict on his case but all was in vain. Historians have generally agreed that Morton set the pace for ether and other subsequent anesthetics to be used (Wolfe 2001). He (Wolfe 2001) further says, â€Å"In history, controlling the pain caused by surgery had been a problem for a long for a long time, many chemical agents with pain relieving properties were recognized before they were used practically even though some like chloroform were harmful and dangerous. Morton started systematic studies on the anesthetic effects of ether convinced the medical world the importance of pain free operations through his demonstration of ether inhalation. The news of ether inhalation and anesthesia spread around the world very quickly and the first to be administered outside the USA was in Norway in the year 1847†. The good news spread to other parts of the world was published in magazines and newspapers as dental doctors and surgeons tried the new discovery which for them was a great and or tremendous success in history of painless surgery. (The Royal College of Anesthetists. Internet source 2008). Unfortunately, William T. G. Morgan died from cerebral hemorrhage due to the heat wave that New York in the year eighteen sixty seven (1867) after being dogged by controversies over his great discovery of ether and its administration during surgery. During the 19th century and there before surgery on the stomach and inside the skull was a no- go zone, some cases surgery speed was the only determinant of a successful surgery but many were unsuccessful. (Wolfe 2001). From that time of William Morgan, anesthesia has been revolutionalized and today it is very safe. There are no death cases from anesthesia with specially trained anesthetists who are only specializing in this field. There are no toxic and dangerous agents in the present anesthetics which have proven the advancement that has been marked in this field. In today’s surgery, for instance, a patient operated in the lower abdomen, nerves can be blocked near the lower part of the spinal cord and there is no need of inducing sleep as the operation goes on well while talking with the patient. (Taffe and Samuels 2003). Conclusion. The evolution of anesthesia has been very controversial from the side of William Morton but he achieved what his rivals were not near to achieve but only popped up when he (William Morgan) had made many sacrifices to achieve what was so important in the nursing world. Anesthesia has been one of the most advanced discoveries which was dangerous and today it is very safe.

Peer pressure Essay

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It can help you reflect on yourself. Peers may teach you good things and encourage you to follow them. Looking at what others do, can help you bring a positive change in your way of thinking. If you can pick selectively, peer pressure can push you towards something positive. For example, when a child knows that some of his friends regularly read storybooks or that they have  subscribed to a library, even he feels tempted to do so. He may get into the habit of reading because of his peers. Seeing that some of your friends exercise daily, even you may take up the habit. Positive peer pressure can lead you to adopt good habits in life. Your peers, their choices and ways of life give you a glimpse of the world outside the four walls of your house. What they think about things in life, how they perceive situations, how they react in different circumstances can actually expose you to the world around. Being part of a larger group of peers exposes you to the diversity in human behavior. This makes you reflect on your behavior and know where you stand. Peer pressure can lead you to make right choices in life. If you are fortunate enough to get a good peer group, your peers can influence the shaping of your personality in a positive way. Their perspective of life can lead you to change yours. It’s not pressure every time; sometimes it’s inspiration, which makes you change for good. For example, positive peer pressure can make you quit smoking or give up bad habits that you may have. Your peers can inspire you to become more optimistic or more confident. Your peers may influence you to change and make you a better human being. If the peer group happens to be in school, you will discover a lot of positive changes happening in your teenager. Since the urge to ‘belong’ to a peer group is all about feeling included and accepted, there is also this natural tendency to behave and become ‘like’ other members of a peer group. Therefore when the members of the peer group believe in doing well in class and doing their regular lessons with care, you will find your child also following suit. The direct effect can be observed in the grades. The teenager will not only learn to focus on his studies but will also show an inclination in getting involved and participating is several extra-curricular and sports activities in school. Whether the peer group comprises of school friends, neighborhood friends or cousins of an extended family, the effect can always be seen on your child. Amongst the other apparent effects, you will find that the communication skills of the teen improving significantly. His approach, attitude and behavior will always be positive. He will learn to value relationships and will learn that it is important to become and responsible individual. Pure s peer pressure beneficial or harmful. Opening statement: My point of view on this subject area is simple and straightforward; peer pressure can be beneficial. Facts and supporting evidence: 1. Peer pressure can be beneficial because it can help you achieve things in life. For example: You’re about to audition for something that’s been your dream forever, then you all of a sudden get too scared so you decide your not going, but then your friend pressures you into doing it. And because of your friend giving you peer pressure, you achieved your goals, and you’ve succeeded. Without this type of peer pressure not many people would be successful in our world. 2. It can also be beneficial because it can help you get out of bad habits. Peer pressure is very well known for getting people into drugs, but nobody ever thought about peer pressure getting you out of them, and peer pressure can get you out of many habits. Last year I used to be late†¦ A lot, but then my mom pressured me into getting up earlier in the morning, and getting ready faster. If it wasn’t for her, I would not be a good student. 3. Peer pressure can lead you to making the right choices. Say you’re in a bad situation your friend wants you to do something that you really don’t feel like doing, so you talk to your other friend, they also think the idea is bad. So he/she pressures you to not do it, later on you somehow find out that your friend was setting you up, if your friend didn’t help you in that situation, you had the chances of ending up in jail or being dead. Facts: 89.5% of the teens in high schools haven’t been pressured into trying cocaine 80% of teenagers haven’t been pressured into trying a cigarette Peer pressure can even start at kindergarten Closing: I know peer pressure can also be harmful, but many people don’t realize how beneficial it can be. When people hear the words â€Å"Peer Pressure† usually the first thing they think is peer pressure involving drugs, and that can happen too, but there are many ways of good peer pressure. My personal motto is: CHOOSE YOUR FRIENDS WISELY! See, first of all i would like to mention that, a fact which clearly reports that there are approximately more benifits than harms of peer pressur. Also it have an appropriate reason:- In our Society, there are more good citizen than bad ones. People mostly have good friend cirlce, than having bad friend circle. Yes there are some bad groups, which involves drug case, robbery etc. But the Fact is clear that there are less cases in which a person gets harm due to peer pressure. Good friends persuade us to do good thing, even we too advise our friends to do good things. I agree with 1st argument with my support. What he/she said is true. People when hear this word † Peer Pressure† they usually thinks of situation involving drugs robbery etc. But As i said , there much more benifits than harms.