Stanley Milgram experiment

Stanley Malaria experiment Could you deliver electroshocks to a person you do not know? In addition, having someone behind you coaxing you the whole way until you get to 450 volts? That was Stanley Amalgam's idea. He wanted to find out how obedient one could be if they were in a position to harm another human being with an administrator in the same room. The administrator would coax the men to administer electroshock to another human being, being unseen, until the learner stops screaming.How far could you go before topping yourself or killing another human being VIA electroshock? Summary of the study and how it was conducted In the sass's, Stanley Malaria conducted a study to see how far a person could go by shocking an unknown individual with heart problems. The study was to show if someone of authoritative position told an individual to deliver an electrical shock to another human being for being wrong on a question. Malaria put an ad into a newspaper that recruited close to 40 men and they were to be paid $4. 50 for their participation. The experiment was conducted in a laboratory at Yale University.There was the administrator, a teacher, and a learner. The teacher had an electroshock machine that went from 15 volts to 450 volts. When the teacher asked a question to the learner and the learner knew the answer there was to be no shock. When the learner got the question incorrect, the teacher would press the buttons in sequential order on the electroshock machine (which was already hooked up to the learner). This would then deliver a current of electroshock to the learner. This was to teach him no to get the questions incorrect. Each time the learner got the question wrong the voltage went up.The learner and teacher only saw each other once and that was before the test. The learner, after a few incorrect answers, started to kick, scream, and protesting the shocks that is being delivered to him. The teacher started to be concerned about the learner, but the adm inistrator would say, â€Å"Please continue† or â€Å"please go on†, â€Å"this experiment requires that you continue†, â€Å"It is absolutely essential that you continue†, muff have no other choice; you must go on. † (Fiske, 2010, Para. 50). What the teacher did not know was that the learner was not really being shocked.This was to see how far the teacher would go before calling t quits on the learner. The learner would be screaming and pleading for his life saying, â€Å"please no more, my heart cannot take it anymore, please stop. † After the 300- volt shock, the room went quite. The administrator told the teacher to take the silence as an incorrect answer and shock again. There still was no voice on the other side. The teacher fell silent and felt stressed and tension. An explanation of the study results: What happened? Were there any unexpected findings? What did the authors conclude? What did the results mean, and what are their implica tions?The results of he Amalgam's study was found to be shocking and appalling. â€Å"The core findings showed that 65% of participants progressed up the shock generator past Danger: Severe Shock to 450 volts labeled simply XX. Only 35% resisted† (Fiske, 2010, Para. 51). The breakdown of the 40 study participants, 26 delivered the maximum amount of shocks to the learner, while only 14 participants quit when the learner was screaming in pain. The majority of the teachers went to the maximum amount of voltage due to the administrator telling them to keep going with the experiment.There was not any unexpected finding with the Amalgam's experiment. However, the numbers for those who went all the way was extremely high. â€Å"Malaria later surveyed the participants and found that 84% were glad to have participated, while only 1% regretted their involvement† (Cherry, n. D. , Para. 10). Malaria concluded that people will comply with orders either out of fear or to cooperate e ven when they are scared or know better. Those who complied through the duration of the experiment struggled with power. Those who participated in the study felt coerced by the administrator. They felt guilt, remorse, and anxiety.If a person of power says meeting is okay, majority of individuals that will continue will be few, but the show will go on. The results from Amalgam's experiment meant that most individuals put into a stressful situation as so; they comply and obey with orders. The select few that did not comply, knew when it was time to stop. They had more of a conscious to stop then to â€Å"kill† a person by shocking them over questions. This study was all about power and obedience. Malaria expected most of the participants to stop when the learner was yelling and screaming in pain. However, that was not the case. After the study was over there was a debrief.The teacher finds out the learner is not injured. Most were relieved to find the learner alive and not hurt . The implications for the Amalgam's experiment are showing that of dangers and obedience. Amalgam's experiment is one of the most psychological studies. If the original variable is not the outcome, then it is time to take a step back and rulebook at the experiment. If the study was reproduced a second time and the same results occur, then that is the purpose of the study would be Justified. An explanation of how the concept situations applies to the study results Situations played a major role in the Amalgam's experiment.The circumstance that was around the teacher was the administrator that was in the same room as the teacher. The administrator was coxing the teacher to keep going even after the yells and screams for help. Most of the teachers went along with the plan even if personal ethics told them not to or to stop. This author believes that if there were not an administrator in the room with the teacher, they would not have gone as far as they did with the electroshock machin e. There were many mitigating circumstances as to why the teacher did not stop when they knew they should have.Do you think the study results might have been different if the participants were from a different cultural, ethnic, or gender group? How so? This author does not believe that the results would have differed if the participants were from different cultures, genders, or ethnic groups. This author saw an updated Amalgam's experiment with females and males and the females was Just as ruthless as the males were in 1960. This author believes that it does not matter where you are from or who you are, but rather what kind of conscious that individual has. Could you be cohered into shocking an individual who said he has a bad heart?That would stop many people, or would it? Do you think the results of the study are important and relevant to contemporary society? Explain This author believes that the results are important. This way when and if the study is conducted again, there is a basis to go by. Does this author believe the results are relevant to contemporary society? This author believes the results were relevant in sass's, but not today. Amalgam's views are out of today's ethical standards. Regardless if the learner was getting shocked or not, many questions still would surface. How would individuals act today?Would the number that takes it all the way be higher? Society would be interested, but not maybe people would report to the study. Conclusion The Malaria study did not go as planned and the results were unexpected. Malaria â€Å"The Malaria studies are a paradigm for understanding evil, but opinions differ as to whether the actual participants were necessarily behaving in an evil manner† (Fiske, 2010, Para. 63). Amalgam's experiment has become a topic in not only Psychology, but also other areas. His experiment has gone down in the books as one of the most studied topics.His experiment shows how obedience is dangerous in this case. The teach ers were being cohered by the administrator to keep going even while the learner was saying, â€Å"his heart hurt to stop. † Luckily, no one was harmed during this experiment and the individuals that went to 450-volts felt remorse.

Answers: Risk Aversion and Security

Your assistant, Thomas, is briefing you on the current portfolio and states â€Å"We have too much of our portfolio in Alpha. We should probably move some of those funds into Gamma so we can achieve better diversification. † Is he right? Hint: Feel free to use spreadsheet statistical functions. ] Here is the data on all three stocks. Assume, for convenience, that all three securities do not pay dividends. Alpha, Current Price 40; Current Weight 80%; Next Year's Price: Expansion 48, Normal 44, Recession 36; Beta, Current Price 27. 0; Current Weight 20%; Next Year's Price: Expansion 27. 50, Normal 26, Recession 25; Gamma, Current Price 15; Current Weight 0%; Next Year's Price: Expansion 16. 50, Normal 19. 50, Recession 12. It depends. No. Yes. Answer : Yes Question 10 (15 points) Suppose there are two mortgage bankers. Banker 1 has two $1,000,000 mortgages to sell. The borrowers live on opposite sides of the country and face an independent probability of default of 5%, with the banker able to salvage 40% of the mortgage value in case of default.Banker 2 also has two $1,000,000 mortgages to sell, but Banker g's borrowers live on the same street, have the same Job security and income. Put differently, the fates and thus solvency of Banker g's borrowers move in lock step. They have a probability of defaulting of 5%, with the banker able to salvage 40% of the mortgage value in case of default. Both Bankers plan to sell their exceptive mortgages as a bundle in a mortgage-backed security (MBPS) (I. E. , as a portfolio). Which of the following is correct?Banker g's MBPS has a higher expected return and more risk. Banker Xi's MBPS has a higher expected return and less risk. Banker Xi's MBPS has a higher expected return and more risk. Banker g's MBPS has more risk, but the expected returns on both MBPS are the same. Banker Xi's MBPS has more risk, but the expected returns on both MBPS are the same. Banker g's MBPS has a higher expected return and less risk. The sam e. In accordance with the Coursers Honor Code, I (Oddity Vats) certify that the answers here are my own work.

Strict Liability in Business Law

The American common law adopted the concept of strict liability in early 1960’s. They began to adopt the view that the sellers should bear the cost of injuries or defects in their products as they are in the best position to distinguish the risks associated with their products. The courts of modern times also provide the sellers the indisputable liability for their defective products without the negligence or fault on the part of the seller. The American law institutes call for the various state law departments to recapitulate the developments in strict liability in Section 402A of the Restatement (Second) of Torts in 1977.In 1997 ALI approved the Restatement (Third) of Torts products liability, which expands the general language of Section 402A into over 20 different sections addressing specific applications of the strict liability ground for recovery. In 1999, the ALI approved Restatement the apportionment of Liability, completely succeeding and expanding upon comparable pro visions of Restatement (Second) of Torts. This Restatement gives paramount importance to the principles of law governing apportionment as liability in cases where there are multiple actors who may have differing degrees of liability.(1)The application of strict liability is important in various segments of business law. Here we shall discuss the scope of strict liability, its essentials and exceptions etc. Moreover we shall try to explore the relationship and contrast of the strict liability with other dimensions in the business law like Rule in Rylands Vs Fletcher, mens rea, negligence, product liability and contract. ———————————————————————————————————— 1. Restatement (Third) of Torts products liability, 1999 Strict Liability 2 Intro ductionâ€Å"He can excuse himself by showing that the escape was owing to plaintiff’s default; but as nothing of this sort exists here, it si unnecessary to inquire to what excuse would be sufficient. – Blackburn J Sec. 402A of Restatement (Second) of Torts, 1977 enunciates that seller of any defective product which is unreasonably dangerous to the user or consumer is subject to liability for physical harm thereby caused to the ultimate user or consumer, or to his property, if the product is expected to and does reach the user or consumer without substantial change in the condition in which it is sold.It does not matter that the seller has exercised all possible care in the preparation and sale of his product; and the user or consumer has not bought the product from or entered into any contractual relation with the seller. Moreover the claim under rule of strict liability can be made against Property damage, Compensation for wrongful death, Physical and mental pain a nd suffering Loss of consortium for loss of love and affection, Past, present and future medical bills and Lost past and future wages, DefinitionStrict liability is a legal doctrine that makes some persons responsible for damages their actions or products cause, regardless of any â€Å"fault† on their part. There are situations when a person may liable for some harm even though he is not negligent in causing the same or there is no intention to cause the harm or sometimes he may even have made some positive efforts to avert the same. In other words the law recognizes such type Strict Liability 3 of â€Å"no fault â€Å"liability. (Salmond,1996)(2)The liability arises when a person or company sells a defective product which is unreasonable and dangerous to the user.The defect may in the products design or manufacturing, in the instructions or warning necessary for the product’s safety or in the container or packaging. The main feature of this aspect is, here the injur ed is excluded from proving the negligence of seller. Scope Generally our legal system typically imposes liability for money damages only upon a showing that a person was negligent (i. e. , failed to use due care) or somehow intended to bring about an injury or damage to another. There are cases, however, where a defaulter can be held responsible for an injury even where no negligence or evil intent can be shown .The doctrine of strict liability imposes legal responsibility for injuries sustained by or as a result of an actor's conduct, whether or not the actor used reasonable care and regardless of the actor's state of mind. Strict liability cases are limited to certain narrowly-defined areas of the law, including products liability, ultrahazardous activities, care of animals and certain statutory offenses. ( Faegre & Benson, 2003) (3) The rule of strict liability is mainly attributed to rule in Rylands Vs Fletcher (4) in which the House of Lords well founded the principle of as st rict liability.In this case, the ———————————————————————————————————— 2. Salmond , Heuston (1996) , Law of Torts, , publisher: Sweet & Maxwell; 21Rev Ed edition , ISBN-13: 978-0421533509 3. Faegre & Benson, (Nov. 2003) UK Trade and Investment, US product liability law 4. Rylands Vs Fletcher (1868) L. R 3 H. L 330 Strict Liability 4 defendant got a reservoir constructed through independent contractors, over his land for providing water to his mill.There were old disused shafts under the site of the reservoir, which the contractors failed to observe and so did not block them. When the water was filled in the reservoir, it burst through the shafts and the plaintiff’s cold mines on the adjoining land. The defendants did not know the shafts and had not been negligent although the independent contractors had been. In this case the court found that even if the defendant was not negligent or rather, even if the defendant did not intentionally cause the harm or he was careful, he could still be made liable under the rule.The defendant may excuse himself by showing that the occurrence was owing to the plaintiff’s default or that was the consequence of vis major or the act of good. But in this case the court firmly asserts that it is unnecessary to inquire what excuse would be sufficient. Normally in these cases, the liability arises not because there was ant fault or negligence on the part of persons, but because he kept such defective products and the same was caused some sort of personal damage to another. In Smedleys Vs Breed, (5)a large manufacturing company of tinned peas was convicted as there found the carcass of a caterpillar.On dismissing the appeal of company the court held it was offence of strict liability, therefore it was not sufficient show that the company had taken all reasonable care to avoid the event. ———————————————————————————————————— 5. Smedleys Vs Breed,(1974) Strict Liability 5 The same view was taken in the famous case Donogue Vs Stevenson (6) in this case A purchased a bottle of ginger beer from a retailer for the appellant.While pouring to the tumbler the appellant found a decomposed body of a snail floated out with her ginger beer. The appellant alleged that she seriously suffered in her health in consequence of having drunk the beer which contains the contaminated contents. On her claim for damages, the court declared that a person who is for gain engages in the business of manufacturing articles of food and drink intended for consumption by members of the public in the form he issues them, is under a duty to take care in the manufacture of these articles.That duty must be to whom he intends to consume his products. The fact is that he manufacturers his commodities for human consumption. Due to this informal nexus he places himself in a relationship with all the potential consumers of his commodities, and that relationship which he assumes and desires for his own ends impose upon him a duty to take care to avoid injuring them. † Hence the manufacturer owed her a duty to take care that the bottle did not contain any noxious matter and that he would be liable for the breach of the duty.Moreover the law looks into the scope of strict liability while it is arising out of indeed consumer’s case. In Berrier v. Simplicity Manufacturing, Inc (7), the leg of four years old was amputated as the result of injuries sustained when her grand father unintentionally backed over her foot wh ile shearing the lawn with ———————————————————————————————————— 6. Donoghue v Stevenson [1932] AC 562 (HL) (Sc) 7. Berrier v. Simplicity Manufacturing, Inc. , (3d Cir. Jan. 17, 2008) Strict Liability 6 a riding mower.Her parents moved a case against the manufacturer of the riding mower on the basis of strict liability and negligence based on design defect and inadequate warning theories. But the court followed the decision of Phillips v. Cricket Lighters, (8)and held that since the intended user or consumer is limiting the wide application of rule of strict liability the issue still remains that the child is neither user nor intended user or consumer of the mower. Strict liability and mens rea So the offences of strict liability, we ca n say, are those crimes which do not require mens rea with regard to at least one or more elements of the actus reus.In R Vs Storkwain (9) the defendant supplied drugs for which a prescription was required, after being handed a forged prescription. There was no evidence of any negligence or wrong doing on the part of the pharmacist.. On appeal against conviction, it was held that the statute created an offence of strict liability; therefore no proof of mens rea was required. In Gammon (Hong Kong) Ltd vs Attorney-General for Hong Kong (10) following points has been laid down to determine the circumstances to which strict liability to be imposed.(1) There is a presumption of law that mens rea is required before a person can be held guilty of a criminal offence; ————————————————————————————â⠂¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€ 8. Phillips v. Cricket Lighters, 841 A. 2d 1000 (Pa. 2003) 9. R Vs Storkwain (1986) 10. Gammon (Hong Kong) Ltd v Attorney-General for Hong Kong [1984] 2 All ER 503 Strict Liability 7 (2) The presumption is particularly strong where the offence is â€Å"truly criminal† in character;(3) The presumption applies to statutory offences, and can be displaced only if this is clearly or by necessary implication the effect of the statute; (4) The only situation in which the presumption can be displaced is where the statute is concerned with an issue of social concern; (5) Even where a statute is concerned with such an issue, the presumption of mens rea stands unless it can be shown that the creation of strict liability will be effective to promote the objects of the statute by encouraging greater vigilance to prevent the commission of the prohibited act.Essentials of strict liability For the application of this rule the foll owing three essentials should be there: 1) Injury by a defective product: In order to succeed the strict liability under the law the plaintiff must show that the injury must be caused by a defective product whose defect existed at the time of injury and the product should be plaintiff’s control. In the recent case of Ceiba-Geigy (Pty) Ltd v Lushof Farms (Pty) Ltd en ‘n Ander (11) it was held that the liability arising from the defective products not only related to the personal injury but financial loss also.It was further confirmed that when a manufacture undertakes or market the production without any prior tests and ———————————————————————————————- 11. Ceiba-Geigy (Pty) Ltd v Lushof Farms (Pty) Ltd en ‘n Ander, 2002 (2) SA 447 (SCA) Strict Liabilit y 8 consequently it turns hazardous to the consumer such negligent activities expose a liability to the consumer. Here a contractual nexus between the manufacturer and the consumer is not required. (Weir, Tony 2006), (12)2) The goods must be dangerous or defective in nature: Here the plaintiff must show that due to the dangerous nature, such goods can not be used for the ordinary purpose or for some other reasonably foreseeable purpose. Thus, a manufacturer owes a duty to supply a product fit for the ordinary purposes and it is to be used and safe notwithstanding a reasonably foreseeable misuse that could cause injury. The decisions in famous cases like Batcheller Vs Tunbrige Wells Gas co. ,(13) National Telephone Co. Vs Baker (14)and West Vs Bristol Tramways Co.(15)manifests that the defective products are whatever in form ,whether it is gas, electricity noxious fumes ,the rule of strict liability can be applied. 3) The goods should leave the manufacturer: It is essential that the thing caused injury to the plaintiff must leave from the possession and control of eth defendant. So those defective goods are still with the manufacture is safe from the claim of compensation. In Read Vs Lyons (16) (text) the plaintiff was the employee in the defendant’s munitions factory. While performing her duty a shell was exploded and she was injured . Even———————————————————————————————————– 12. Weir,Tony,( 2006),an introduction to Tort law,2nd edn. , Oxford University Press 13. Batcheller Vs Tunbrige Wells Gas co. 84 L. T 765 14. National Telephone Co. Vs Baker (1893) 2 ch 186 15. West Vs Bristol Tramways Co. (1908) 2 K. B 14 16. Read Vs Lyons (1947) A. C 156, 161 Strict Liability 9 though the shell exploded was dangerou s in nature it was held that defendants were not liable as the shell was not left from outside the defendant’s premises and the rule of strict liability could not be applied in this case.4) Breach of warranty: Generally, the law imposes certain warranties (or guaranties) on the sale of products. Such warranties include that the goods are in proper condition for use and free of defects and that they are fit for a particular purpose. Since the court doesn’t disregard the liability of the waivers against the policy and the warranties are limited, the manufacturers and retailers are always held responsible for injuries from the defective and dangerous products. The aspect of breach of warrenty enables the plaintiff to act against the defendant with his complete freedom.Here he need not assert that the defendant is fault. Usually the product claims under the breach of warranty are in quasi contractual nature. Any factual statement or promise about the product ,a description of the product made ,any sample or model provided constitutes the warranty upon which the buyer rely to purchase the goods. ( Faegre & Benson,. 2003)(17) Exceptions/limitations The following are the exceptions to the rule of strict liability. 1) Plaintiff’s own default: Damage caused due to the plaintiff’s own default was considered to be good defense in rule of strict liability.If the plaintiff suffers damages by ———————————————————————————————————— 17. ibid 3 Strict Liability 10 his own intrusion into the defendant’s property he can not complain for the damage so caused. When the damage to the plaintiff’s products/property is caused not so much by the escape of eth thing s collected by the defendants as b y the unusual sensitiveness of plaintiff’s property itself, the plaintiff cannot recover anything. In Eastern and South African Telegraph C. Ltd. Vs Capetown Tramways Co.(18) the plaintiff submarine cable transmissions were disturbed by escape of electric current from the defendant’s tramways . It was found that the damage was due to the unusual sensitiveness of the plaintiff’s apparatus and such damage will not occur to person carrying on the ordinary business and the defendant held not liable for the such occurrence. 2) Act of god: Act of god or Vis Major was also considered to be a good defense to an action under the rule of strict liability. If the defect is unforeseen and it is without any human intervention the defense of cat of good can be pleaded.In Tennent Vs Earl of Glasgow (19) the court has framed a well maintained definition for the act of god as the circumstances which no human foresight can provide against and of which human prudence is not bound to recognize the possibility. 3) Consent of plaintiff: In cases of volunti non fit injuria i. e where the plaintiff has consented to the accumulation of the dangerous /defective product in defendant’s possession, then such liability does not arise. But such consent must arise for the common ———————————————————————————————————— 18.Eastern and South African Telegraph C. Ltd Vs Capetown Tramways Co. (1936) A. C 381 19. Tennent Vs Earl of Glasgow (1864) 2M (H. L) 22, 26-27 Strict Liability 11 benefit of both plaintiff and defendant. For eg: when two persons are living on the different floors of eth same building each of them is deemed to have consented to the installation of things of common benefit such as the water system, gas pip es or electric wiring . When water has been collected for the common benefit of the plaintiff and the defendant will not be liable for any defects happened to such system unless there is negligence on his part.In North Western Utilities Vs London Guarantee,etc Co. Ltd (20) ,the concept of consent for the common benefit had been formulated as there is no such common benefit between a gas or other public utility undertaking and its consumer’s . 4) Act of third party: If the harm has been caused due to the act of a stranger who is neither defendant’s servant nor the defendant has any control over him, the defendant will not be liable under this rule. But if the act of the stranger is or can be foreseen by the defendant and the damage can be prevented, the defendant must by due care prevent the damage.If not so, the defendant may be held liable for his act. This principle is laid down in Richards Vs Lothian (21). In this case, some strangers blocked the waste pipes of a wa sh basin, which was otherwise in the control of the defendants, when opened the tap, and the overflowing water damaged the plaintiff’s goods. The defendants were held not liable. 5) Statutory authority: Generally an act done under the authority of a statute is defense ———————————————————————————————————— 20. North Western Utilities Vs London Guarantee,etc Co. Ltd (1936) A.C 108 21. Richards Vs Lothian (1913) A. C 263 Strict Liability 12 to an action for tort. But it cannot be pleaded as a defense when there is negligence. In Green Vs Chelsea Waterworks Co. (22) the defendant co. had a statutory duty to maintain continuous supply of water. A man belonging to the company burst without any negligence on its part, as a consequence o f which plaintiff’s premises were flooded with water. It was held that the company was not liable as the company was engaged in performing a statutory duty. ( Salmond,1996)(23) In practice, the defendant may argue the defenses adopting the following claims.1) The defendant may forward an argument on the basis of misuse of the product sold. But it is to be remembered that the misuse of products can not be forceeble or there is a chance of rebut this argument by the plaintiff that there should have some kind of anticipation on the part of the manufacturer and prevented such misuse by its product design or in its warning. 2)Secondly the defendant can claim that the product has been altered and modified . In order to prove this he has to take adequate measures to provide warnings in connection with the alteration of the products.3) If there is any complaint by the buyer about the defective design, then the defendant may rebut his claim by demonstrating that the product was at sta te of art at the time of manufacture. 4) A manufacturer might be allowed to adduce the evidence on the basis of industry ———————————————————————————————————- 22. Green Vs Chelsea Waterworks Co. (1864) 70 L. T 547 23. ibid 2 Strict Liability 13 custom and standards and government standards related to the manufacture and design. ( Faegre & Benson, 2003)(24)Before the buyers of tacky products were not allowed to sue a manufacturer of or seller of a harmful product in commerce. The decision owes to the principle of â€Å"caveat emptor† â€Å"let the Buyer beware†. Now the burden to prove a products sticks on the other claims of product defect, inadequate instructions, or warnings. Here the plaintiff must prove that that the product caused him harm when it was used for its intended purpose as well. More he has to prove that the manufacturer knew or should have known the product would be used in such a way that would cause harm. Strict liability and NegligenceNegligence is an important element to determine the strict liability of a defendant. Negligence is considered to be the oldest theory of product liability as well as the strict liability. As a general rule it is for the plaintiff to prove that the defendant was negligent. The initial burden of making out at least prima facie case of negligence as against the defendant lies heavily on the plaintiff, but once this onus is discharged, it will be for the defendant to prove that the incident was the result of inevitable accident or contributory negligence on the part of the plaintiff.(Jones,2007)(25) There are some elements should be proved by the plaintiff in order to make claim against the defendants under the rule of strict liability. ——— ————————————————————————————————— 24. ibid 3 25. Jones, A . Micheal (2007), A text book on Tort, Ch. 2, 9th ed. , publ. by Oxford University Press Strict Liability 14 Duty of care: The plaintiff must prove that a duty of care was owed by the defendant to the plaintiff. Mere carelessness on the part of defendant doesn’t entitle the plaintiff to sue him.He has to establish that the defendant owed to him a specific legal duty to take care of which he has made a breach. In this connection, in famous case of Donogue Vs Stevenson it was held that a manufacturer of the products which he sells in such a form as to show that he intends them to reach the ultimate consumer in the form in which they left him with no reasonable possibility of intermediate examin ation and with the knowledge that the absence of reasonable care in the preparation of putting up of the products will result in an injury to consumer’s life or property, owes a duty to the consumer to take that reasonable care.(26) Breach of duty: Breach of duty means non observance of due care which is required in a particular situation. But here the defendant acted like a reasonable prudent man there is no negligence. In Blyth Vs Birmingham waterworks Co(27). it was clearly explained that negligence is the omission to do something which a reasonable man ,guided upon those considerations which ordinarily regulate the conduct of human affairs, would do or doing something which a prudent and reasonable man would not do.) Proximate cause: The plaintiff should prove that the breach of duty proximately caused the plaintiff’s injuries. Finally there should be lawful and sufficient injury happened to the plaintiff due to the defective /dangerous product. ——â⠂¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€ 26. ibid 6 27. Blyth Vs Birmingham waterworks Co (1856) 11Ex. 281Strict Liability15 The manufacturers always have the duty to exercise reasonable care in manufacturing the products.Poor assembling the products, difference in use of component parts and its design specifications, failure to inspect the finished products, component parts and failure in correction in any defective products are some examples to lead the plaintiff to claim under the rule of strict liability. ( Faegre & Benson, 2003) (28) In R Vs Lemon (29)the publisher of a gay news were charged with blasphemous libel against Christ through a poem which was considered as an slur to Christianity.The court held that it is the pure case of blaspheme as they ha d intention to publish so they are responsible for their act. Moreover in Alpha cell Vs Woodward,(30) the company was accused of causing polluted water to enter river by using equipment to prevent any overflow in to the river. But due to the collapse of the machine, the polluted things leaked out to the water. There was no evidence that the defendant is negligent but the court held that the defendant had caused the pollution in the water and they held liable. Strict liability in product liabilityThe â€Å"product liability† defined as the liability of manufacturer, during the chain of distribution, for personal injury, economic loss or property damage caused by sale or use of the product. Here the term ‘product’ denotes the finished goods as well as those items which may have some impact on the consumer expectations, product safety etc. In order to brought the action under strict liability the plaintiff must prove that injury occurred by ———à ¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€ 28. ibid 3, 24 29. R Vs Lemon (1979)30. Alphacell Vs Woodward, (1972) Strict Liability16 a defective product whose defect existed at the time of injury and at the time which the product left the control of manufactures control. Such product liability is the legal responsibility of the manufacturer to the buyers. It can be occurred at time of the transaction. Generally there are three defects in the product make defendants liable for their act. 1) Manufacturing: even though a few products turns in to the fault during the process of a manufacturing the plaintiff may held liable under rule of strict liability.2) Marketing: In the case of lack of product warning or instructions, the plaintiff can bring an action against the def endant under such liability. 3) Design: A fault in design from previously mentioned might enable the plaintiff to claim for damages against the defendants. ( Miller, Goldberg 2004)(31) Usually the defective and unreasonably dangerous product denotes the desirability or usefulness of the product, the availability of safer goods in same need, likelihood of injury and its possible seriousness and danger.In such cases entitles the plaintiff to recover from the defendants for the injury caused by the product. Here he need not prove any misconduct on the part of the defendant. The law framed such a provision to make the manufacturer vigilant about their production in safe manner. It is the duty of the manufacturer to produce the goods which will not create an unreasonable risk of injury to the consumer at any cost. Such claim can be made against the—————————————————â€⠀Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€Ã¢â‚¬â€ 31. Miller C. J, Goldberg R. S (September 30, 2004) Product liability 2 edition Publisher: Oxford University Press, USA; ISBN-13: 978-0198256786 Strict Liability17 manufacturer, wholesaler, distributor, retailer and the maker of component parts. (Restatemet,1999)(32) In recent case of Escola v. Coca-Cola Bottling Co. ,(33) 24 Cal. 2d 453 (1944) (Traynor, J., concurring) it was clearly stated that on the demand of public policy the responsibility should be fixed even though there is no element of negligence under the circumstances of hazardous and dangerous to life and health due to the defective products. In cost of the cases the injured would be such persons who are not aware and unprepared to meet the consequences. It is to the public interest to discourage the marketing of defective products that are a menace to the public. It is to th e public interest to place the responsibility for whatever injury they may cause upon the manufacturer, who, even if he is not negligent in the man

Media influences in sociology Essay Example | Topics and Well Written Essays - 500 words

Media influences in sociology - Essay Example This is a social problem because media influences the world perception and priorities of people. It is used to manipulate and organize habits and opinions of the society through false values and beliefs of the dominant social group. It manipulated the social machinery controlling the opinions and habits of middle and low classes. It is often assumed to be normal that a latent group, provided it does not encounter any obstacle or resistance and that it has sufficient 'consciousness' of the common interest, will act 'naturally' in advancing its interests. Latent groups are aware of their interests, and such awareness leads 'normally' to collective action aiming to advance the common interest. The sole obstacles which might prevent this collective action are, on the one hand, a delay in the appearance of an awareness of common interest, and, on the other hand, a resistance which derives from divergent or contradictory interests of other groups (Schmidt 363). Competition between groups w hose interests are both legitimate and at least partially in opposition is a basic means of a concentration of power in modern societies. To start from the conflict between a value system and a norm system is to suppose that one or other is coherent when taken by itself. "Media reproduces the structural components of systems of interaction" (Schmidt 241). Advertising is one of the most powerful media tools which popularize

My educational goals and career plans Research Paper

My educational goals and career plans - Research Paper Example Likewise, it is my work as an assistant cook at the Especially 4 U Restaurant which tops my impressive list of community service and work experience.   Very simply put - I love to cook. Every dish I cook is an expression of my creativity and my caring, and there is no greater satisfaction than that of watching people relish my food. My dream is to become a top chef. I believe that the best path towards achieving this goal is to earn top notch educational credentials in food and nutrition, and simultaneously gain as much hands-on, practical knowledge as possible. I then hope to travel round the globe, work under the master chefs of various countries, and go on to become a cordon bleu chef. My ultimate goal is to open my own restaurant, exhibiting my individualistic, distinctive style of cooking: a style rooted in the warmth and love of home-cooked food. I am confident that my strengths, which include the determination to excel in whatever I do, my committed work ethic, my extroversion and love of social interaction, and, above all, my passion for cooking will help me to achieve my goal. As a person who is dedicated to community service, I also hope to harness my future education and career to provide succor to the lesser privileged and contribute to the food needs of those in

Marketing Principles Assignment Example | Topics and Well Written Essays - 2250 words

Marketing Principles - Assignment Example It is only when these principles are adhered to, will a business organization be well placed to experience the maximum benefits of marketing. There are four core principles of marketing that will be expounded in this paper. The marketing presumption is that in the absence of these marketing principles effective and complete marketing would essentially be impossible. The success of any business venture is significantly hinged on the comprehension and effective execution of these marketing principles. Main Body In context to marketing endeavours, business organizations would rather revert to conventional forms of advertising deals and marketing ideas. This is hinged on the assumption that since these ideas been proven to work since time immemorial. As such, these are safe strategies whose risk is as low as it can get. However, business organisations must exercise caution and restraint when implementing strategies that are not in line with common conventional strategies. If caution is n ot observed, the huge amounts of funds that are dedicated towards product marketing will be lost. The art of learning how to market effectively is one of the biggest hurdles for an upcoming business venture or launching a new product. The risk of encountering failure is more than real. As such, the following basic principles must be used to avert failure. ... This is hinged on the rationale that it is important for buyers to understand what is being offered if significant sales are to be experienced (Barcharts, 2010). In respect, this is one of the most vital aspects of marketing. If the product that is being offered is not clearly understood, in terms of functions or benefits of the product or service, by the impending clients then they will simply pick up and move on from the product. As such, in an endeavour to avert such catastrophic eventualities, a few measures can be instituted. The measures are hinged on ensuring the public are in full comprehension of the respective products that are being offered. These measures can best be exemplified by including warranties, efficient customer service, adequate instructions, company name, and visual illustrations of how your product or service functions. Prior to the launch of the product into the market, there are a number of product decisions that have to be made. The first is deciding on br and name. This is an especially important process in an endeavour to maintain the uniqueness of the business organization. The chief risk is that the business venture will be successful, and then an imitator will come into the market with a similar name. In the event whereby the name assigned to the product or service was descriptive of some feature of the product or service, it might be futile to prevent that particular name from getting into the market. The impact of this is far reaching; this is sourced from the fact that this imitation of the product or service name might grab a share of the market position which the business organization has already established. This is the rationale behind the adoption of invented names for unique products and services. A

Problem Organization Essay Example | Topics and Well Written Essays - 2000 words

Problem Organization - Essay Example This paper hereby describes the historical context of CBHF referring to its vision and mission along with various other factors to assess the actual problem inherent to its discontinuation suggesting remedial measures which could have assisted in neglecting such a consequence. Introduction Clinton Bush Haiti Fund (CBHF), which was established as a non-profit organization to rescue the victims of 2010 earthquake in Haiti, was on a verge of closing down its operations on December 31, 2012. The reason behind closing the organization of CBHF Bush Haiti Fund was reported to be the insufficiency of adequate funds for the development of individuals in the socio-demographic region of Haiti. It has also been observed that there is further requirement of nation building in the regions of Haiti; however, an insignificant numbers of members are observed to be interested in providing hard work for the organization. In addition, the inadequacy of funds that had been raised for the development of t he region and to execute other necessary operations of the non-profit organization can also be regarded as a threat to the sustenance of CBHF. Owing to its deteriorating financial stance, the organization also had to face bankruptcy risks which again caused severe threat to its existence and effectiveness or success in delivering the intended facilities to the community people in Haiti (Daniel, 2012). To make the matter worse, the organization has been disregarded to be eligible to acquire funds in terms of donations from its stakeholders since 31st December, 2012 thus contributing towards its financially deteriorating health (Foundation Center, 2013). Moreover, the organizational members were heavily criticized for inefficiency in providing effective decisions for the betterment of Haiti people in the society along with lacking any report for substantial progress which accumulatively caused the problems for CBHF (Weisbrot, 2013). With reference to this case example, the paper inten ds to discuss on the history, outcomes, law in practice, and solutions for the problems witnessed by CBHF. The paper also discusses on ethical issues of the organization providing rational recommendations for future avoidance of such problems. History CBHF is a non-profit organization established in the year 2010, with a vision and mission to assist the population in Haiti and therefore contributing towards building the country in a better way. As per its norms being a non-profit organization, CBHF has been utilizing the donation gathered through grants, loans and investments in equity for promotion of growth of job along with sustainable development of the entire economy. On its establishment, the organization envisioned towards fostering diversity and competitiveness of the economy of Haiti with the support of prevalent nonprofit organizations and focusing on partnering with profit entities (Clinton Bush Haiti Fund, 2010). Mission The mission of the organization had been to delive r consistent assistance to the people living in the society of Haiti in deprivation of adequate basic amenities. Moreover, promotion of economic opportunities was also considered as an important mission of the organization (Clinton Bush Haiti Fund, 2010). Key Individuals The key individuals, associated with the organization since its establishment, were reported to be the two former US Presidents, Mr. Bill

No topic Essay Example | Topics and Well Written Essays - 500 words - 11

No topic - Essay Example God is viewed holy and perfect and as a person who has established high standards for perfection for humanity. The reformers saw it insufficient due to the fact that it was referenced to God’s honor as opposed to his holiness and justice. The medieval notion was that punishment of sin had to involve bloodshed. The reformers believed that Christ died for man as he took his sins and bore them for him. Through bearing of man’s sins, Christ is believed to take the punishment from them and deliver the believers free from the demands of the law. This is a clear indication that the holiness of God and the righteousness of the law are satisfied by his substation. There are relevant scriptures including Isaiah 53: 12 â€Å"yet he bore sins of many, and mistakes intercession for the transgressors.† And Isaiah 53: 6 â€Å"the lord has laid equality of us all.† The Penal substitution theory assumes that God is infinite, minor human sins are an infinite debt to him. This can only be cancelled through infinite satisfaction through the death of Jesus Christ. The belief that God’s need to seek justice is so strong that he would only demand satisfaction through the death of an innocent person is an assumpt ion that modern readers would reject. With reference to John Scott’s classic work â€Å"The cross of Christ†, he tries to offer a deeper understanding of satisfaction with his fifth chapter â€Å"satisfaction for sin†. He argues that the cross was necessary due to the fact that God had to satisfy himself in the way of salvation. Scoot uses this chapter to analyze that the death of Jesus Christ on the cross was necessary for satisfaction. This is a statement that most people affirm to. However, the nature of satisfaction has been a subject of debate throughout the history of the church. He looks at different methods to which the theologians believe as the method God used to forgive the sins of mankind (Stott 120). Other speak of satisfying God’s law,

Public Defense v. Private Defense Research Paper

Public Defense v. Private Defense - Research Paper Example (Hoffman,2004) The main hurdle in respect of a public defender is the fact that since there would be a huge load of cases, the time spent on individual cases would be lesser. Further, contrary to the private defense there would lesser access to important tools, like private investigators. Even though, this can be curtailed by the funding of the public defender’s office. (Hoffman,2004) Clearly, in respect of the private defender there would significant time as well as resources to spend on a client; since the client would be willing to pay the private defender would be willing to pay for the same. (McDonald, 1983) Another important element which needs to be taken into account is the fact that the amount which would be received by a public defender would be significantly lesser than that paid to the private defense. It is important to point out that it is generally said that such a difference in pay would not affect the quality of service, however, it is important to note that i f the lesser time being given to each client, plus the resources that are available to a public defense are taken in their collectivity, it would mean that there would be an adverse effect on the case which is inevitable. There are public defenders that are more than willing and considerate to take into account the fact that the client is unable to pay and therefore provide him effective services. Another problem in respect of a public defender is the fact that cases cannot be rejected by them and so if a case qualifies it cannot be refused unless there is a good legal reason to it, one of them being conflict of interest. On the contrary private attorney do not have to assign a reason for refusing the case and can do so even if he decides on the basis of chances of success. (Harmon, 2002) It is important to point out to the fact that the monetary element is also to be taken into account in respect of public and private defense. (Hoffman,2004) There have been various surveys which ha ve been conducted in order to evaluate which one is better. On the basis of an evaluation private lawyers have been found to be handling more serious cases that is, cases concerning severe crimes. (Beattie, 1935) The general phenomenon in respect of the pros and cons is the fact that the general act of the people is to secure money and get legal representation if the concerned offence is a serious one and/or the conviction is on the higher side. (McDonald, 1983) As far as a minor offence is concerned the general pros and cons are not taken into account, contrary to when a person who is facing a long prison sentence, who would prefer the time that is given by private defense and therefore arrange for the money. (Hoffman,2004) Another important element of lack of resources is the fact that the public attorney due to the lack of time cannot put adequate amount of research as well as detailed study which can be evaluated and analysed upon by the private defense. (Beattie, 1935) However, an important edge that can be cited to have been attained by general public defense is that of the experience and the repetitive amount of cases in which the general notion and the legal principles remain the same whereby most of the contentions that are to be raised by the defense can be easily prepared for and be presented and the practical experience can be seen as well as cited in respect of the same by the

Peter Singer's All Animals are Equal Essay Example | Topics and Well Written Essays - 1250 words

Peter Singer's All Animals are Equal - Essay Example I am urging that we extend to other species the basic principle of equality that most of us recognize should be extended to all members of our own species.† (Singer, 1989) In my opinion, Singer would better communicate his point if he preached on the necessity of compassion for animals, but in this instance, he suggests a quality of rights with humans. To show how quickly Singer’s logic contradicts itself or quickly spirals to the absurd, we can begin with the innumerable treaties that exist in international law that define the extent of Human Rights as decided among humans themselves at the United Nations and other locations. First, we must ask ourselves – can even one animal read the â€Å"Universal Declaration of Human Rights†? We can accept that any human being, in any human culture on the planet, generally save instances of abnormal injury, can learn to read and understand the document. In comparison, of what may be anywhere from 30 to 230 million different species of animals on the planet, depending on the number of insects, and the number of individual animal beings literally exponential and uncountable to human mind or science – not one of these animals can read. In recognizing that some higher mammals can be taught, should one extend the right of education and free speech to insects? It is not in my interest to encourage in any way cruelty to animals, nor to belittle animal intelligence, and dismiss animal culture. I understand the ways in which speciesism may unfold, as defined by Skinner, and support vegetarianism. However, I would suggest that Singer spend years in a jungle or forest location and teach vegetarianism to animals. It may be possible, and I have seen cats for example raised as vegetarians by their owners but not renounce killing by their own choice.

Strategic Management Essay Example | Topics and Well Written Essays - 1750 words - 2

Strategic Management - Essay Example The company’s fleet consisted of 245 aircraft and 40,627 employees at the end of 2009 (Datamonitor). The company earned approximately  £9 billion in revenue at the end of fiscal year 2009, 2.7% higher than the last year. 87% of this revenue came from passengers’ traffic while 7.5% and 5.4% came from cargo and other activities respectively (British Airways Annual Report, 2008/09, Data-monitor). The PEST analysis of British Airways highlights major influences on the airline industry. According to Sanderson and Luffman (2001), this environment analysis indicates â€Å"current strategies of competitors, the potential of new competition to enter the market, the behavior of suppliers and buyers, and the availability of substitute products† (2001, p.20). The competitive marketing environment continuously changes, therefore a well thought-out, composed, detailed and consistent analysis is necessary for best evaluation. The distressing incidents at the start of 21st century have turned out as the most difficult times for the airline industry. These incidents included the terrorist attacks in New York on September 11, 2001 and in London on July 7, 2005. Moreover, wars in Iraq and Afghanistan have caused an extraordinary political instability in different parts of the world. Due to such political instability and security situation, European Union and United States formulated new security regulations which came into effect in summer 2006. Although governments have taken essential safety and security measures and controlled the activities at the airports effectively along with pricing and planning policies but even then the new political strategy reduced the customer’s traveling confidence on airline. During last few years, substantial regulatory reforms have taken place which has given more opportunities to British Airways and such other airlines. As far as, UK political

City and Farm Life Essay Example for Free

City and Farm Life Essay Comparing and contrasting city and farm life has been a common theme of situation comedies, movies as well as novels for decades. Many people find themselves, at some point, questioning the advantages of living on a farm life to living in the city. While a case can be made for both locations as to which is the best place to live, it is vital to consider how the options, farm life versus city life, are similar as well as different. There are a number of ways to make such comparisons that include firsthand experience of each type of the city and farm living environments. One such contrast is that people living farm lives and those living city lives have different social constructs as far as health and physical activities are concerned. This is as a result of the various social circumstances of the communities in addition to the locations in which they reside. People living farm lives, live a typical farming or country life as compared to those living in the cities (Smith 1). Living a city life often has the advantage of sufficient access to health services, recreational facilities in addition to having relatively sufficient health education in comparison to farm life. see more:city life vs country life essay People living in the city have therefore an advantage of health benefits, developed knowledge of physical activities, are exposed to health promotion campaigns in addition to having higher socio-economic status. All these factors have contributed to people living a city lives experiencing superior health compared to those living farm lives (Recomparison 1). Another key issue to be considered in any comparison between city and farm life is the quality of life. People living city lives have many more choices they can make regarding various aspects of their day-to-day lives. For example, people living city lives are more likely to find various kinds of foods and this could probably result in overall good health as there is greater diversity in terms of diet. Moreover, those living city lives enjoy opportunities to take a great number of social events since they always have a long list to choose from. As a result of this, they always have an opportunity to get more cultured and therefore more likely to meet other people from other cultural and ethnic groups. Parents have also many options available for their childrens education and can always pick from a long list of both private and public schools, which results in potential for better education. It is also important to note that city life offer their residents the opportunity to choose from a wide range of job options in a number of companies or organizations. On the other hand, people living farm lives do not enjoy same level of choices and in very remote areas one may forced to walk for long distances (Recomparison 1). Another contrast between city and farm life is their surrounding environment. Farm life is often best described as a more peaceful as well as a healthy way of living. For example, farm life offers residents an opportunity to take pleasure in the natural world instead of having to go to places such as parks. Individuals are surrounded by the gifts of nature such as trees, sun, wind, animals, natural cycles etc. Moreover, people living farm lives do not have to struggle with the every day stresses associated with city life, for instance getting stuck in traffic, coping with high crime rates, and in most cases, having to pay higher taxes. The absence such stressors are known to have a significant effect on the overall quality of life. Alternatively, city life is often portrayed as fast-paced, modern, polluted, and full of work pressure as well as financial pressure (Recomparison 1). On the whole, if there is any testimonial to be made regarding the quality of life in the farm, it is that, there is high probability to connect with the people as well as the landscape. However, one similarity between farm life and city life is that both entail a high level of socialization, even though on a cursory level E-how 1). The discrepancy of what an individual wants and needs has also something to do with where they are to be found. Individuals living a farm life identify as well as prioritize their needs much more than their wants. They are therefore familiar with what is essential for them to live a standard of living further different from others and closer to natural cycles that gives priority to things that are of greater im portance. Their wants are simple and they do not cling to the life they cannot afford. On the other hand, with the attractive as well as the competition inducing advertisements they watch on television along with the peer persuasions that urge them to acquire specific items, one cannot avoid feeling pressured to possess the items. City is therefore more complicated as compared to the farm life (E-how 1). Lastly, a contrast between city and farm life can be seen in the types of housing available. In general, city residents have choices of living in apartments, townhouses and condominium. In contrast, those living farm lives often have housing options that includes mobile homes, single family detached homes in addition to the low-rise apartment building.Moreover; housing is more often than not cheaper for those living farm lives due to decreased demand (Herlihy 1). Conclusion As a conclusion, both city and farm lives have their own draw backs which form the basis of their contrasts. Thus, individuals ought to think carefully before making decisions to live in the city or live a farm life since its their decisions that bring differences in their lives.

Future Trends In Wireless Sensor Networks Information Technology Essay

Future Trends In Wireless Sensor Networks Information Technology Essay With the advances in the technology of micro-electromechanical system (MEMS), developments in wireless communications and WSNs have also emerged. WSNs have become the one of the most interesting areas of research in the past few years. Here, we look into the recent advances and future trends in WSNs. WSNs are usually composed of small, low-cost devices that communicate wirelessly and have the capabilities of processing, sensing and storing. The development of WSNs was motivated by military applications such as battlefield surveillance. WSN are being used in many industrial and civilian application areas, including industrial process monitoring and control [1, 2], machine health monitoring [3], environment and habitat monitoring, healthcare applications, home automation, and traffic control [1, 4]. A WSN generally consists of a base-station (also called as gateway sometimes) that can communicate with a number of wireless sensors via a radio link. Wireless sensor nodes collect the data, compress it, and transmit it to the gateway directly or indirectly with the help of other nodes. The transmitted data is then presented to the system by the gateway connection. This paper discusses the recent advances in WSNs that enable a wide range of applications and future development in applications like underwater acoustic sensor systems; sensing based cyber-physical systems, time-critical applications, cognitive sensing and spectrum management, and security and privacy management. Rest of the paper is organized as follows. Section 2 describes the recent advances in WSNs. We discuss future trends in WSN in Section 3. Section 4 describes the research challenges for WSN. Finally Section 5 presents the conclusion. RECENT ADVANCES Recent advances in wireless and electronic technologies have enabled a wide range of applications of WSNs in military sensing, traffic surveillance, target tracking, environment monitoring, healthcare monitoring, and so on. Here we describe such type advances in WSN and their applications in various fields. Sensor Localization and Location-Aware Services Smart Home/Smart Office Smart home environments can provide custom behaviors for a given individual. Considerable amount of research has been devoted to this topic. The research on smart homes is now starting to make its way into the market. It takes a considerable amount of work and planning to create a smart home. There are many examples of products currently on the market which can perform individual functions that are considered to be part of a smart home. Several useful applications which take advantage of information collected by WSN are presented in [5]. Military New and emerging technologies, such as networks, support military operations by delivering critical information rapidly and dependably to the right individual or organization at the right time. This improves the efficiency of combat operations. The new technologies must be integrated quickly into a comprehensive architecture to meet the requirements of present time. Improvement in situation awareness [6] is must requirement. Other important application is detection of enemy units movements on land/sea, sensing intruders on bases, chemical/biological threats and offering logistics in urban warfare [7]. Command, control, communications, computing, intelligence, surveillance, reconnaissance, and targeting systems are well described in [8]. Industrial Commercial Since the long time wireless transmission of data is being done in industrial applications, but recently it has gained importance. Successful use of wireless sensors in systems such as supervisory control and data acquisition has proved that these devices could effectively address the needs of industrial applications. The critical process applications of WSNs in industry are monitoring temperature, flow-level, and pressure parameters. With the rapidly increasing technological advances in wireless technology and its subsequently decreasing prices, numerous wireless applications are being developed in industry. WSN in manufacturing industries can monitor and optimize quality control. Traffic Management and Monitoring Every big city is suffering from traffic congestion around the world. A sincere effort is being made to solve the traffic congestion. Congestion can be alleviated by planning managing traffic. A real-time automatic traffic data collection must be employed for efficient management of rush-hour traffic. Research on this topic is considered as part of the Intelligent Transport System (ITS) research community. ITS is the application of the computers, communications, and sensor technology to surface transportation [9]. The vehicle tracking application is to locate a specific vehicle or moving object and monitor its movement. This work also describes design of WSN for vehicular monitoring. As the power source (battery) is limited, it is important that a design of sensor node is power efficient. Structural Healthcare Structures are inspected at regular time intervals, and repairing or replacing based on the time of use, rather than on their working conditions. Sensors embedded into structures enable condition-based maintenance of these assets [10]. Wireless sensing will allow assets to be inspected when the sensors indicate that there may be a problem. This will reduce the cost of maintenance and preventing harmful failure. These applications include sensors mounted on heavy duty bridges, within concrete and composite materials [11], and big buildings. Agriculture Agriculture can also be benefited by the deployment of WSN to get the information regarding soil degradation and water scarcity [12]. With help of WSNs we can check the clean water consumed in irrigation and manage it. Topology and Coverage Control Topology control is one of the fundamental problems in WSNs. It has great importance for prolong lifetime, reducing radio interference, increasing the efficiency of media access control protocols and routing protocols. It also ensures the quality of connectivity coverage and increase in the network service as well. A significant progress in research can be seen in WSNs topology control. Many topology control algorithms have been developed till date, but problems such as lack of definite and practical algorithm, lack of efficient measurement of network performance and idealness of mathematical model still exist. Several graph models used in topology control, the present hot spots and the future trends on the research of topology control are presented in [13]. Quality of Service (QoS) Provision QoS support is challenging due to severe energy and computational resource constrains of wireless sensors. Various service properties such as the delay, reliability, network lifetime, and quality of data may conflict; for example, multi-path routing can improve the reliability, however it can increase the energy consumption and delay due to duplicate transmissions. Modeling such relationships, measuring the provided quality, and providing means to control the balance is essential for QoS support. There are various research opportunities in enhancing the QoS of WSNs. One of the researches is the project described in [14] that analyzes and enhances the performance of a WSN by deploying a simple max-min fairness bandwidth allocation technique. Mobility management Mobility is one of the most important issues in next generation networks. As WSNs are becoming the next elements of the future Internet, it is crucial to study new models that also support mobility of these nodes. WSNs are applicable in variety of cases that make it difficult to produce a standard mobility scenario. Following are some cases where the mobile support is necessary [15]. Intra-WSN device movement is probably the most common scenario in WSNs architectures, where each sensor node has the ability to change from its local position at run time without losing the connectivity with the sensor router (SR). In the case of inter-WSN device movement, sensor nodes move between different sensor networks, each one with its SR responsible to configure and manage all the aggregated devices. A research project of IETF working group NEMO [16] is an example of WSN movement. Sensor network deployed in a moving bus is a real scenario of this type. It is possible to have a scenario where a sensor network can use another sensor network in order to be connected through Internet. MANEMO [17] project is also an example. Security and Privacy Concern The field that paid less attention is the privacy concern on information being collected, transmitted, and analyzed in a WSN. Such private information of concern may include payload data collected by sensors and transmitted through the network to a centralized data processing server. The location of a sensor initiating data communication, and other such context information, may also be the focus of privacy concerns. In real world applications of WSNs, effective countermeasures against the disclosure of both data and context-oriented private information are indispensable prerequisites. Privacy protection in various fields related to WSNs, such as wired and wireless networking, databases and data mining, has been extensively studied in [18]. Effective privacy-preserving techniques are needed for the unique challenges of WSN security. Biomedical/Medical The uses of WSNs in biomedical and medical are in growing phase. Biomedical wireless sensor networks (BWSNs) show the future opportunities for supporting mobility while monitoring vital body functions in hospital and home care. There is a requirement for BWSN to develop in order to cover security handling, improved signal integration and visualization. They can also be used to achieve extended mobility outside the surgery room, monitoring of several patients/persons at the same time, and further adaptations to medical experts needs for information. As the Internet usage has become popular among people, e-services for the healthcare which is commonly known as e-Health, have recently attracted significant attention within both the research society and industry. Followings are several ongoing projects for healthcare using WSN: CodeBlue [19] an architecture proposed for tracking and monitoring of patients. ALARM-NET [20] a WSN built for assisted-living and residential monitoring. AMON [21] a Wireless Body Area Sensor Network System GlucoWatch G2 [22] use WSN to research wearable personal health system that will monitor and evaluate human vital signs. FUTURE TRENDS The future developments in sensor nodes must produce very powerful and cost-effective devices, so that they may be used in applications like underwater acoustic sensor systems, sensing based cyber-physical systems, time-critical applications, cognitive sensing and spectrum management, and security and privacy management. In this section we will look into all possibilities of further development in WSN applications. Cognitive Sensing Cognitive sensor networks are used for acquiring localized and situated information of the sensing environment by the deploying a large number of sensors intelligently and autonomically. Managing a large number of wireless sensors is a complex task. A significant research interest can be seen in bio-inspired sensing [23] and networking. Two well known examples of cognitive sensing are swarm intelligence and quorum sensing: Swarm intelligence is developed in artificial intelligence for studying the collective behavior of decentralized, self-organized systems. Quorum sensing is an example of bio-inspired sensing and networking. Quorum sensing is the ability of bacteria to communicate and coordinate behavior via signaling molecules. Spectrum Management As application of low-power wireless protocols is increasing, we can envision a future in which wireless devices, such as wireless keyboards, power-point presenters, cell phone headsets, and health monitoring sensors will be ubiquitous. But the pervasiveness of these devices leads to increased interference and congestion within as well as between networks, because of overlapping physical frequencies. Cognitive radios and multi-frequency MACs are some approaches that have been developed to utilize multiple frequencies for parallel communication. A generic solution is provided by SAS [24]: a Self-Adaptive Spectrum Management middleware for WSNs, which can be easily integrated with an existing single frequency. The inherent nature of WSNs makes them deployable in a variety of circumstances. They have the potential to be everywhere, on roads, in our homes and offices, forests, battlefields, disaster struck areas, and even underwater in oceans. This paper surveys the application areas where WSNs have been deployed such as military sensing, traffic surveillance, target tracking, environment monitoring, and healthcare monitoring as summarized in Table 2. The paper also surveys the various fields where WSNs may be deployed in the near future as underwater acoustic sensor systems, sensing based cyber-physical systems, time-critical applications, cognitive sensing and spectrum management, and security and privacy management. These application areas are being researched extensively by various people across the industry and academician [7, 9, 22, 24, 28].

Case Study of Business Strategy Of Marks And Spencer

Case Study of Business Strategy Of Marks And Spencer Marks and Spencer is one of the biggest traders having inheritance of more than one hundred and twenty years. It has more than 895 stores in more than 40 regions all over the world. Its head office is in U.K, in the city of Westminster. Michael Marks from Slonim, Russia and Thomas Spencer a cashier from Yorkshire are the pioneers of this U.Ks biggest retailers. At Leeds (Kirkgate market) in 1884, Michael Marks started his own business by opening a penny bazaar stall. Then to develop his business he opened a shop at Manchester with the partnership of Thomas Spencer. H:st college assingmentsMS assingq no 51201445_MarksSpencerSheffieldHistory.jpg After the death of both the pioneers of the company Michael Marks Simon became the chairman of company while William Chapman took the helm until 1960. During the Era of Michael Simon Company touch the highest point .The business was floated as a public limited company after 10 years. In 1998 it was the first company of U.K who earned the profit of one billion pounds after tax deduction. Marks and Spencer prohibited smoke first time in store that later on became a legal offence to smoke at public places. Marks and Spencer mainly deals in Clothing, Home Ware, Food, Technology, Beauty, Financial Services, Energy and Hospitality. PLAN A: The Customers are becoming more conscious about natural and environmental issues, so for this Marks and Spencer launched plan A, which consists of 180 commitments to overcome the challenges. Many problems are related with Climate Change, Waste Reduction, Ethical Trading, Sustainable Raw Material and Health. To tackle these changes Marks and Spencer is doing much effort. C:UsersFaisalDesktopimagesCAXD7DW8.jpg In March 2010 Marks and Spencer expanded plan A introduced 80 more commitments and added them up with the existing ones. In these commitments their primary focus is on climate changes, waste, natural resources, fair partner, health and well being. These five main pillars are described below: C:UsersFaisalPicturesimagesCAV6T6WW.jpg CLIMATE CHANGE: Due to an increase in greenhouse gases produced by the human activities the earth is getting warmer day by day causing many damaging consequences. In 2006/07 Marks and Spencer cut their carbon emissions to 8% by reducing the usage of energy. Marks n Spencer also committed that up to 2015, they will improve their energy efficiency by 35%. C:UsersFaisalDesktopimagesCA3FRFRV.jpg WASTE: Every year the U.K has to throw away 400 tonnes of waste that comes from construction, industry, households and discarded packaging. The waste that is not recycled ends up in landfill sites which take many years to decompose. Marks and Spencer claimed that in the year of 2009/10 they have achieved the recycling level to 88% while reducing the amount of waste to 16%.They have reduced the food waste by 29% as compared to the years 2006/07.Marks and Spencer collected 133 million clothes hangers and reused 76% of them and recycled the rest. C:UsersFaisalPicturesimagesCAM1CR39.jpg They have also recycled their construction waste up to 89%.Marks and Spencer are committed to do that by 2015 they want to landfill help their customers to recycle or reuse their packaging and products. They will also help their suppliers to reduce the waste and to gain zero rates as well. NATURAL RESORCES: In plan A Marks and Spencer aimed to get as much of their raw material from their natural resources as possible. It is the U.Ks first company who has signed the WWF sea food charter, with 62 % of their wild sea food. Marks Spencer also purchased Green palm certificate to cover all the palm oil to use their Marks and Spencer product. C:UsersFaisalPicturesimagesCAG3OZ2S.jpg Fair Partner: Marks and Spencer has a vision that they are very strong in their communities and ensure good working conditions. Marks and Spencer has the lowest employee turnover rate in UK retail i.e. 14%.Marks and Spencer is offering competitive salaries, discount to their employees, bonuses and share save options to their employees. It provides different training programmes to the employees. Every employee has to undertake Marks Spencer Career Path Training and learning programmes .While the managers have to attend the different workshops to boost their capabilities. Marks and Spencer is trying to provide the best salary packages for the employees. C:UsersFaisalDesktopimagesCAF15VPV.jpg Health and Wellbeing: Unhealthy food is one of the main factors of many health problems. According to the part of the commitment of Plan A Marks and Spencer encouraged its customers and employees to get healthy and nutritious food by developing new product ranges. Marks and Spencer has launched online diet forums and health newsletters to allow active dialogue with the customers on nutrition and health. Marks and Spencer has removed artificial flavours and colours from all of its food products and soft drinks. It has also removed 90% of salt in its products. Very few of the products still does not meet the required standard of health and nutrition but Marks and Spencer is working hard to bring it in line according to the required standard. C:UsersFaisalPicturesimagesCACFVO3Z.jpg Analysis of the external environment: According to plan A Marks and Spencer has also taken into consideration the external environment of the company. External environment means the factors that directly or indirectly affect the internal function and perhaps business strategy and objectives as well. Most common factors of external environment are political, social, economic and technical. These factors are totally out of control of the organisation, but the company could be able to take some steps to overcome these challenges. Basically the external environment defines the competitive situation of an organisation and potentially can have both positive and negative impacts on businesses. Target analysis has four major categories of external factors that affect the companys capability to grow. Based on operation region, external environment is divided into three interactive segments which is remote, industrial and operational environment. External factors produce different influences on the companys productivity. On the ot her hand some influences are inter-linked with each other. For example information technology completely changed the way of work, customer behaviour and life style as well. Based on PEST analysis four major factors are going to be discussed in detail. Political Environment: Political stability in a country attracts the investors to do investment and that is a very key factor to grow business. Secondly, government trade policy, is either flexible or hard. Every organisation operates under the government policy about trade and within the legal frame work. The legal frame work covers many areas like tax rates, employees benefits, wage legislation, trade regulation and tariff. Suppliers, customers and competitors are also affected by the political environment. Economical Environment: Economic conditions also affect organisations external environment. In this regard some factors that influence business are tax rates, inflation, money supply, government need, economic growth rate and the tendency to spend at international and national level. Social Environment: In social context, normally Britain customers lean towards a specific product. In every transaction product quality matters a lot, but it could easily be beaten by offering lower pricing of the same brand. Some fresh analysis about Britains customers is that they prefer some fashionable styles over classic trends. This can be seen in Marks Spencers case because they are still struggling to get a bigger market share. This indicates that British buyers are very keen about their wealth. Technological Environment: Now a days a large number of the population is able to use the internet. It means that by using e-commerce many organisations can widen their horizons and do many more operations. This can be seen in foremost companies like Sainsbury, Tesco and ASDA as well. These days most of the trading and purchasing is done through the internet, and it has also become a competitive advantage of Marks and Spencer. Analysis of External Environment of MS: The U.K retail market is very eye-catching. The company has full support from the government. Because Marks Spencer has rich historic values and has become a very powerful organisation in the business world, new competitors are finding it very challenging to keep up with the quality of products and services that Marks Spencer provide. Analysis of the organisations internal environment and identification: In Plan A Marks and Spencer has taken internal analysis, which is also called SWOT analysis. This is a very important part of business development. SWOT analysis is a simple structure for generating strategic alternative from a situation analysis. SWOT is an abbreviation for Strengths, Weaknesses, Opportunities and Threats. In late 1960, Edmund defined SWOT structure. Learned, C. Roland, Christiansen, Kenneth Andrews and William d Goth in Business Policy, Text and Cases (Homewood, IL; Irwin 1969).In the 1980s General Electric Growth Council used this form of analysis. Basically, it throws light on thecompanys strengths weaknesses. The strengths highlight the different aspects that bring results in market value and the weaknesses draw the attention to those areas which need improvements. SWOT analysis is fruitful where you have to tackle a complex situation in a limited time frame. Organisation of an effective strategy is based on a clear definition of the organizations mission. For the success of an organization it requires some necessary ingredients which are listed below: Strategy must be carefully verbalized, applied, manageable and accomplished. Internal analysis of the organisation is an essential part in the strategic planning process. During 2005-06 Marks and Spencer had seventy thousand employees globally. The Company changed the employees structure according to the nature of the customers that used the products and services of Marks Spencer. Marks and Spencer also pledge to promoting equal opportunities regardless of age, disability,race, views about politics, working hours and religion. Marks and Spencer arrange flexible working schedules for fatherhood, adoption and IVF treatment, child and career break to boost their employees uniformity. Marks and Spencer also runs Business Involvement Group (BIG), which is a work demonstration forum in all their stores and offices that inspire their work force to share information and develop discussion about the companys business. If we talk about salary and welfare, the company has some incentive packages that include fundamental fixed pay. As for training, in 2005-06 more than 102,000 days were fixed for training purpose in which Marks and Spencer try to develop inner aptitude and skill of their workers. Marks and Spencer proved that they have great concern about health and safety of their employees by providing a wide range of work related health services. The companys code of ethics is also developing to give guideline to their member concerning their responsibilities towards customers, workers, stockholders, dealers, societies, government and the environment. Identification of the major issues challenging Marks Spencer: Marks and Spencer is one of the UKs biggest traders, giving different services to their customers in the field of food, clothing, and house hold products. They tried at their best level to give good customer service at an affordable price, but it is not always very easy. Marks and Spencer are losing their trend towards the youngstersand their other opponents in the market are taking advantage of this weak point. This is the biggest challenge that Marks and Spencer is facing nowadays. To overcome this weak point Marks and Spencer is also taking steps to provide cheaper products to their customer, but for this they have to import their raw materials, which also lessen the Marks and Spencers image of British Goods Seller. Cards and cash methods have been used for payment since 2001. Marks and Spencer have seen very tough times during the period of recession, but now it seems as though everything is going back to normal. The companys thirteen weeks before the start of OCT (2010) was very hope full. Homeware made an astonishing growth in sales up to 7% and food stuff which was last year 3.6%, this year it increases up to 3.7%.The clothing section is also growing and is the most rapidly expanding sales item of Marks and Spencer. During the autumn the women shoes sales touched a record, which Marks and Spencer claims that it was because of their strong advertisement. External environment and the impact on the strategic direction of the organisation: Strategic direction means those incentives that a company adopts for the achievement of its target i.e. how to produce, develop and sell its products. Basically strategic direction is the planning that an organisation follows for the marketing of its products. Marks and Spencer introduced a plan that they named as PLAN A the purpose behind which is to become worlds most sustainable retailer. For the success of any organisation it is very necessary to keep an eye on the environmental changes that occurs outside the organisation. As these changes affect the strategy of any organisation, it has to alter its rules and regulations according to the environmental changes. There are four main external environmental factors that effect the strategic direction of any organisation. a) Political b) Economic c) Technological d) Social The political condition plays a vital role to put an impact on the strategy of an organisation as it refers to the government policies. If the government introduces new laws and the organisation has some policies or rules and regulations that conflicts with the existing government laws, it has to alter its rules and regulations and make them according to the governments policy. The change in the political condition can affects the strategic direction of the organisation as every government has its own policies and the organisation cannot work against the laws of the country. Economic condition has also a deep effect on the strategic direction of an organisation. The economic condition of any country has a deep rooted effect. It includes taxation rates, economic growth rate and capability to invest at national and international levels. The rapid change in technology is another factor that can affect the strategic direction of an organisation .With the passage of time new techniques and machines are coming up and it is very important to adopt new techniques for the development of a business. In the social environment the consumer plays a vital role to affect on the strategic direction of the organisation. The organisation has to provide the products and services according to the requirements of the consumer. The lifestyle trends, ethical issues, media views, law changes, buying access, brand, religion beliefs, demographics and fashion are the social factors that can affect the strategy of the organisation. What should the organisation do to achieve or maintain competitive advantage in its industries? Competitive advantage: A companys competitive advantages are the features that give permission to do best even in average industry extensive performance and free entry into the industry as a whole. Every company has some definite abilities which make it different from other companies in the same industries. It has some unique competences that cannot be replicated by the opponents. Many companies complete their management price by using effective use of skills to organise their jobs. One example of such a company is Marks and Spencer. This company use technology to locate their goods. The company also use technology to coordinate between different departments. It brings more proficiency and less expenditure, and as a result production cost is low. On -the-counter payment was also introduced by Marks Spencer. It was very beneficial for the company as they need only a small amount of employees, so as a result labour cost was minimized and profit margin were increased. Marks and Spencer with more than 100 years of experience have a competitive advantage over most of their counter parts, because the company earn the trust and reputation among the customers, their workers and suppliers. Their customers have an extensive collection and are fully confident about the companys products and services.They also get value for money as well. Marks and Spencer demonstrates a shared sense of doing things, with their strong inner structure that moves around permanent employment relationships and strong organisational routines. In the external environment Marks and Spencer fully focus on product specification and design to continue their relationship with the customer, which lasts for many years. As part of their business accountability the company has strong conservational and communal responsibilities. TSE Stated that Marks and Spencer use modern methods of management like consumer research, planning, personal management, product innovation, staff training and many more and has proved itself as a founder and outshined among all other companies (1985).Marks Spencer maintain a strong organisational structure that is run by comparatively normal employees who get excellent results over many years, although many changes have occured in the economic environment (1995). Although, over the recent years, due to the big recession the company has had to face downfalls in some of their retailing areas, but they have managed to overcome all their uncertain hurdles through flexibility, that their opponents view as unnerving. According to an analyst Terhi Halme (2008) ,Even though Marks and Spencer has carried out extensive reformation over the past years, the companys competitive advantage has not been fully revived, so the firm could be able to answerable to the current down turn in British retail market. The decline rate during the past few months has been increased in their food unit and as a result revenue has dropped. Because of this, the food sector is also losing its market share. The management have to step up marketing and promotional spending to protect the market share. Additionally the team confidence is also diminish because of changed management, and therefore not been able to generate sustainable improvements. It is possible that Asian and Middle East companies that are in search of western products will take a look at the market shares of Marks and Spencer as presenting buying opportunities at the present price, especially during this recession. Conclusion: Marks and Spencers main aim is to become the worlds most sustainable retailer by 2015. To achieve this target Marks and Spencer introduce Plan A in which it has highlighted five factors to achieve their business goal that is climate change, waste, sustainable raw material, fair partnership and health. There are some internal and external environmental factors that affect the business strategy of the organisation. Internal factors are under the control of the organisation that deals with the strengths and weaknesses. But the external environmental factors are beyond the control of the organisation. Marks and Spencer has also taken initiative to maintain and improve its position. It provides good customer services, using modern techniques, and provides products according to the demand of the customers.

Tess of the DUrbervilles :: essays research papers

Tess of the D'Urbervilles Throughout the novel, Tess of the D'Urbervilles, Hardy focuses on the life of Tess Durbeyfield. Starting out as a young, innocent girl, Tess matures throughout the book to become a powerful woman who was capable of thinking for herself. Furthermore, she was also intelligent enough to realize her importance as an individual. At the beginning of the novel, Tess was portrayed as a young girl with too much responsibility for her age. She was sent out into the world at a very young age, and was unable to see the danger in life around her. Tess was the one who had to fetch her parents from the inn because they stayed out too late. In addition to that, she was forced to do her father's work because he was too drunk to realize what the current situation was. Neither parent cared much about Tess: her mother was always thinking about getting Tess married, and her father was thinking of ways to restore their social order. Due to the negligence from her parents, Alec was able to take advantage of her physically and mentally. By giving Tess's father a horse, Alec was able to exert mental control over Tess in such a way that Tess was obliged to obey. Yet, Tess was able to overcome her affair with Alec because she possessed a keen sense of justice and morality. She realized that she had sinned, but also came to the conclusion that she should not be punished eternally for one mistake. This realization also reflects upon Tess's maturation mentally. Moreover, because her affair with Alec also resulted in a child, she was forced to mature much more quickly than she would have liked. Tess also had the habit of blaming herself for everything that would not go as planned. The whispering that Tess endures during her visit to Church after her affair with Alec only serves to strengthen her feelings that she was constantly at fault. Tess's maturation also continued during the period when Angel deserted Tess. Throughout this time, she refused to let anybody criticize Angel. Tess also hides the truth about their separation from either set of parents, for the fear that she will have to endure further criticism. Her simplicity of faith in him is such that, "even the most perfect man could have hardly deserved it." Tess's love for Angel is permanent.