Sikh marriages essays

Sikh relationships articles The Sikh Marriages Ravi General reason: Inform Explicit Purpose: To educate about Sikh Marriages. Allurement: Stereotypes. I realize that everybody has a type of sound system about a part of culture. The Sikh culture has its generalizations of orchestrate relationships. I realize that in the last 10-multi year this generalization has started to blur away. Im here to teach your brain on this generalization. v Most of the time the relationships are masterminded. v Its not simply not when two bodies are being joins its increasingly like the two spirits being unfastened v The wedding function (Anand Karage) is acted before Guru Granth (strict book of Sikhism). v They are being joined by the utilization of the Anand Karage. This is a manner by which the 2 spirits are being united. v Each section clarifies the four phases of adoration and wedded life. v This wedding Ceremony is preformed by perusing the 4 refrains called (magma) from the heavenly book, which is known as the, Guru Granth. Later we will examine the importance of the critical magma stanzas, and the noteworthiness it has on these organized relationships. With instructing you on mastermind relationships I might want to reveal to all of you parts of it. Which would remember divorces for some uncommon cases. Presently Sikh culture mind you doesn't support divorces. Sikh relationships are not rewarded as a damn implicit agreement but instead as a combination of 2 spirits into one. As indicated by the master the lady and lucky man should cherish each other above any other individual. 1.Arranged relationships and love marriage 1. Anand Karage meaning, function of favor. The fourth Guru, Guru Ramdas initially made Lava, the wedding tune, to commend a blessed joining between human spirit (Athma) and God (Parmatma). The Guru wishes that our wedded life ought to likewise be formed on the perfect set down for our association with the Parmatma (God). ... <!

The Making of the American Revolution in Virginia Research Paper

The Making of the American Revolution in Virginia - Research Paper Example As indicated by the exploration the individuals of Virginia were hesitant to cut off their ties with Great Britain. Having been administered and affected by a customary and prosperous gathering of ranchers for a significant part of the eighteenth century, the individuals of Virginia saw their social and financial riches helpless before good affiliations with the homeland. Be that as it may, with the intense changes after the Indian and French War, for example, out of line British assessments, quick expanding of multicultural and heterogeneous populace, settlement development in the inside, and the impact of an abusive work framework, countless Virginians got frustrated with the frontier government. As indicated by Woody Holton, the creator of Forced Founders: Indians, Debtors, Slaves, and the Making of the American Revolution in Virginia, the pilgrim privileged of Virginia, which is the most eminent respectability in America, didn't thoughtlessly partake in the transformation however was incited by different gatherings and people. The recorded record of Holton commends the Ohio Indians, whose endeavors in supporting a wide-extending confederation constrained Britain to actualize the 1763 Proclamation Line and complying with it, in this manner ruining the wants of land go getters like Thomas Jefferson and George Washington. Holton places the captives of Virginia into the image, who were convincing Governor John Dunmore to acknowledge their administrations before his arrival of the notable 1775 revelation and whose quest for autonomy drew the consideration of a huge populace all through the province, empowering supporters like William Byrd to join the patriots’ cause.... hites, tenants, and smallholders whose decision to keep down the selling of tobacco in 1773 set off the crusade for non-exportation and whose claims for opportunity strengthened a definitive division from the pilgrim government. It was the obstruction and battle of these individuals against the recently created and inconsistent sorted out minutemanâ€members of crews of picked people during the American Revolutionâ€businesses that introduced the principal idea of an alternate political framework in the province and that close by inhabitant clashes and uprisings over destitution and different hardships to produce a grassroots transformation. Holton’s Virginia Holton (1999) examines how the intentions of the rich Virginian respectability crashed into the premiums of the British dealers and the Indians. The honorability had since quite a while ago planned to broaden their territory property and along these lines wealth to contain the locale of Kentucky, a wellspring of resou rce for various Indian populaces. So as to oppose the invasion of the White individuals, the Cherokee, the Delaware, and the Shawnee triumphed over their past clash and shrewdly teamed up to manufacture an association. Extraordinary Britain, alarmed of an awful container Indian clash, at first discharged the 1763 Proclamation which prohibited each exertion toward further expansionism and a while later, sanctioned in Quebec Act in 1774, giving every single challenged an area to the locale of Quebec. The contention of the honorability with British dealers exuded from the Navigation Acts. This announcement obliged Virginians to sell their tobacco just to the homeland. The pioneers were profoundly obliged to the dealers to some degree because of their own indulgence, yet they additionally credited their immense obligations to the decline in income from selling tobacco (Holton 1999). The House of Burgesses proposed a

0% COLUMBIA UNIVERSITY - SIPA Admissions Blog

0% COLUMBIA UNIVERSITY - SIPA Admissions Blog I thought I would take the opposite tact of what you might expect today.   In past posts I have provided some information on the completion percentage of files in our office.   Rather than go that direction today, I thought I would try to put all of you in the same comfort zone by talking about our progress in reading files. Let me comfort all of you by saying the percentage of files read to date is basically zero.   Thats 0%, zip, nada, zilch. Classes just started this week and many members of the Committee just returned.   As you know, we have been busy in our office working as fast as we can to complete files, but we have sent out zero batches.   A very small number of applicants have a single read done on their file.   These individuals completed their applications well in advance of the January 5th deadline and a few staff members read these files over the winter break. However, rest easy everyone.   You are all in the same boat.   It does not matter if you received a your file is complete email last week or if you have yet to get one we have not started to send out batches yet so no one is behind.   Again, when a file is batched and sent out has no bearing upon the admission decision.   The admission file review process is not a race so do not fear. Thanks again for our patience.

Effect of Corporate Social Responsibility on Financial Performance of Financial Institution in Malaysia - Free Essay Example

Sample details Pages: 5 Words: 1405 Downloads: 2 Date added: 2017/06/26 Category Finance Essay Type Analytical essay Did you like this example? Effect of Corporate Social Responsibility on Financial Performance of Financial Institution in Malaysia Background of the study Corporate Social Responsibility (CSR) disclosure in Annual Report has been debated for a long time. Survey done by KPMG in 2013 show that 71 per cent of the 4100 companies undertake CSR reporting in the business practice. Furthermore, among the worldà ¢Ã¢â€š ¬Ã¢â€ž ¢s largest 250 companies, the CSR reporting rate is more or less stable at 93 per cent. Don’t waste time! Our writers will create an original "Effect of Corporate Social Responsibility on Financial Performance of Financial Institution in Malaysia" essay for you Create order The issue on CSR reporting is undeniable, however the question now is on the quality of the report itself and how the information be honestly communicated to stakeholders (M.-W. Wu, C.-H. Shen, 2013). Financial institution especially banks play an important role in economic development because its safety and soundness create several external benefits to society. By using substantial resources from society, banks are required to provide feedback to the community more often that other industries. For example, bank assets may mainly come from depositors. Therefore, as bank employ public resources paid for by society, they are highly scrutinize by the media, government and academician regarding their CSR activities. Prior study proved that CSR practices can be considered as effort to enhance the  ¬Ãƒâ€šÃ‚ nancial performance (FP) of PLCs in Malaysia (Mustaruddin, Norhayah and Rusnah, 2011). Keywords: Corporate social responsibility CSR), Financial Performance (FP), Finan cial Institution (FI) Problem statement Purpose: The current study purpose is to examine the CSR disclosure in Annual Report of the Financial Institution (FI) and to study the relationship between CSR with financial performance (FP) of the FI. Research questions: To what extend the CSR disclosure of FI? What is the relationship of CSR to FP of FI? Literature review Corporate responsibility is replacing corporate social responsibility as an increasingly important factor in how people regard the corporate reputation of organisations (Worcester, 2009). One way to incorporate CSR with modern banking theories is to relate it to the role of bank reputation. Thus companies use CSR to increase customer loyalty and build reputation. Accordingly, banks conducting CSR can attract more loans and deposits than non-CSR banks because CSR creates a brand name and a sense of identity among the customers (M.-W. Wu, C.-H. Shen, 2013). CSR must be appreciated as a set of actions that companies manage with harmony, when stakeholders have good responses to their CSR practices. The positive relation of CSR information towards CFP indicates that companies could increase their external reputation (Mustaruddin et al. (2011). Furthermore, CSR also been viewed as the continuing commitment by business to behave ethically and to contribute to economic development while improving the quality of life of the workforce and their families (Md Zabid Abdul and Saadiatul Ibrahim, 2002). Research Design CSR Measurement CSR will be the independent variable in the current study. A disclosure-scoring methodology will be adapted in the current study. It will be based on the content analysis. The content in CSR disclosure will be scored and the items selected will be categorised into four indicators which are employee relations, community involvement, product dimension, and environmental dimension. There will be sub-item in each category and it will be scored accordingly . List of CSR items: Employee relation: Employee health and safety. Training and education. Employeesà ¢Ã¢â€š ¬Ã¢â€ž ¢ bene ¬Ãƒâ€šÃ‚ ts. Employeesà ¢Ã¢â€š ¬Ã¢â€ž ¢ pro ¬Ãƒâ€šÃ‚ le. Share option for employees. Health and safety award. Community involvement: Cash donation program. Charity program. Scholarship program. Sponsor for sport activities. Supporting national pride. Public project. Product: Product development. Product safety. Product quality. Customer services. Environment: Pollution control. Prevention or reparation program. Conservation and recycled materials. Award in environment program. There will be three quality of classification for disclosing value for each item. Each item disclosed will be assign accordingly. (1) Quantitative disclosure classi ¬Ãƒâ€šÃ‚ cation. This classi ¬Ãƒâ€šÃ‚ cation refers to the greatest weight which has an assigned value of 3. It classifies as the  ¬Ãƒâ€šÃ‚ nancial disclosures. For instance, the CSR practices disclosed in the companyà ¢Ã¢â€š ¬Ã¢â€ž ¢s annual report are as follows: To promote access to healthcare, Maybank Islamic has made a five-year commitment via the Maybank Foundation to contribute RM1.7 million to Institut Jantung Negaraà ¢Ã¢â€š ¬Ã¢â€ž ¢s new Regional Paediatric Heart centre. This contribution not only provides support in terms of much-needed medical equipment but also assists in subsidising medical expenses for patients from low-income backgrounds. Since 2012, this collaboration has helped 30 children from around the region (Maybank Annual Report, 2013 pg 125). (2) Qualitative spe ci ¬Ãƒâ€šÃ‚ c disclosure classi ¬Ãƒâ€šÃ‚ cation. This classi ¬Ãƒâ€šÃ‚ cation refers to the next highest weight which is the non-quantitative disclosing but with particular information and it has an assigned value of 2. It classify as the non- ¬Ãƒâ€šÃ‚ nancial disclosures. For instance, the CSR practices which are disclosed in the companyà ¢Ã¢â€š ¬Ã¢â€ž ¢s annual report are as follows: The Group places strong emphasis on child safety and we uphold this diligently through our Missing Children Reuniting Families initiative which aims to ensure missing children are reunited with their families. The programme was launched in 2007 in partnership with Polis DiRaja Malaysia (à ¢Ã¢â€š ¬Ã…“PDRMà ¢Ã¢â€š ¬Ã‚ ) and offers an alternative channel of communication for members of the public to help locate missing children (RHB Banking Group Corporate Responsibility Report 2013 pg 11). (3) Qualitative non-speci ¬Ãƒâ€šÃ‚ c disclosure classi ¬  cation. This classi ¬Ãƒâ€šÃ‚ cation refers to the lowest weighted value due to its qualitative disclosing in which the description is in general, thus it is assigned as the quantitative value of 1. It classify as non- ¬Ãƒâ€šÃ‚ nancial disclosures. For example, the CSR practices which are disclosed in the companyà ¢Ã¢â€š ¬Ã¢â€ž ¢s annual report are as follows: Public Bank Group has always displayed a readiness to invest in its staff right from the onset of their career with the Group, equipping them with knowledge, skills, and attitudes that will enable them to make their mark in the organization. Strong induction and orientation programmes are among the training lined up for staff from day one to inculcate the right corporate values and a sense of belonging (Public Bank Berhad, 2005, p. 171). Companies that do not disclose any kind of information for the given categorises obtain a score of 0. Financial performance Measurement Accounting variable s use in the current study to assess the financial performance(FP) will be return on assets (ROA), return on equity (ROE) and return on sales .These are the dependent variables in the current study. Hypothesis development The first objective of the current study is to examine CSR disclosure in Annual Report of the Financial Institution (FI) H1. CSR will be positive, signi ¬Ãƒâ€šÃ‚ cantly related to FP The second objective is to study the relationship between CSR with financial performance of the FI. Based on the CSR items therefore create the four hypotheses below: H2. There is a positive relationship between employee relations dimension and FP. H3. There is a positive relationship between community involvement dimension and FP. H4. There is a positive relationship between product dimension and FP. H5. There is a positive relationship between environment dimension and FP. Data Sources This study will examine financial institution listed on main market of Bursa Malaysia and licensed with Bank Negara Malaysia (BNM). The research period is 5 years which covered from 2010 to 2014. The data will be collected from annual report of each company which will be downloaded from the Bursa Malaysia website. Companiesà ¢Ã¢â€š ¬Ã¢â€ž ¢ annual reports constitute the main data for the current study and were chosen because the annual report is the primary source of CSR disclosure, and, in Malaysia, annual reports of listed companies are the most accessible source of information, either in hard copies or electronic formats. Conclusions Although the issue on CSR has been debated for a long time and be studied by many academicians and researchers, the current study aims to look on the quality of the CSR disclosure. It is because the question on whether to disclose or not is not a matter anymore. Last but not least, the relationship between CSR and FP of financial institution need to be closely study. The extent of the study could be the motives behind the CSR activities. References The KPMG Survey of Corporate Responsibility Reporting (2013), KPMG InternatIonal Md Zabid AbdulSaadiatul Ibrahim, (2002),Executive and management attitudes towards corporate social responsibility in Malaysia, Corporate Governance: The international journal of business in society, Vol. 2 Iss 4 pp. 10 à ¢Ã¢â€š ¬Ã¢â‚¬Å" 16 M.-W. Wu, C.-H. Shen, (2013) à ¢Ã¢â€š ¬Ã…“Corporate social responsibility in the banking industry: Motives and financial performanceà ¢Ã¢â€š ¬Ã‚ , Journal of Banking Finance, 37 3529à ¢Ã¢â€š ¬Ã¢â‚¬Å"3547 Mustaruddin Saleh Norhayah Zulkifli Rusnah Muhamad, (2011),Looking for evidence of the relationship between corporate social responsibility and corporate financial performance in an emerging market, Asia- Pacific Journal of Business Administration, Vol. 3 Iss 2 pp. 165 à ¢Ã¢â€š ¬Ã¢â‚¬Å" 190 Sir Robert Worcester, (2009),Reflections on corporate reputations, Management Decision, Vol. 47 Iss 4 pp. 573 589 1

Midsummer Night’s Dream Analysis Free Essays

Illusions A Midsummer Night’s Dream Essay Is it a dream or reality? The connection between the real world and a world created by our own vivid imagination while we sleep is somewhat uncanny. A plethora of individuals cannot fathom how the brain can create such realistic scenarios in such little time. In A Midsummer Night’s Dream by William Shakespeare, the author uses his knowledge of dreams to create his play. We will write a custom essay sample on Midsummer Night’s Dream Analysis or any similar topic only for you Order Now A Midsummer Night’s Dream is not only the title of this play but the overall theme as well. In the story dreams bring many changes within the plot. Dreams change the opinion of characters and open their eyes to a different reality. A large connection between dreaming and theater is made at the end of the play in Puck’s famous final speech. Midsummer also plays a large role in the theme of this play as well. We will discuss all of these topics within the next few paragraphs. â€Å"Like dreams, love is foolish, crazy and driven by desires. † Says an article called The Meaning of the Title in  A Midsummer Night’s Dream  by Shakespeare. The relationship between the four lovers, Hermia, Helena, Lysander, and Demetrius is based on their dreams and desires. When Hermia had a nightmare depicting a snake eating her heart, â€Å"Methought a serpent ate my heart away,/And you sat smiling at his cruel  play† (pg. 64-65) it foreshadowed Lysander’s newfound love for Helena which was only temporary. Lysander was casted into a figurative dream as Puck placed the love petals upon Lysander’s sleeping eyes. When Lysander awoke and Helena was the first one he saw, Lysander began to long for her and fall in love with her. This is important to the plotline because it shows what a dream can do to a person. It also helps build Puck’s character as a careless trickster. Although Helena believes Lysander’s attempts to win her heart as merely a cruel joke the reader understands Lysander is trapped in a dream. Puck then with instruction from Oberon, the King of the Faeries places the love petals in the eyes of the sleeping Demetrius to let him fall deeply in love with Helena who loves him. At the same time Puck is instructed to put these petals into Titania’s, the Queen of the Faeries eyes so that she may hopefully fall in love with an â€Å"ounce, or cat, or bear† (pg. 55). This is so that Oberon can take the Indian boy away from Titania and use him as a servant. This will solve their marital problems and bring balance back to the mortal world. Titania falls in love with Bottom, of whom which was ironically transformed by the all magical Puck into an ass. â€Å"O Bottom, thou art changed! What do I see on thee? †(pg. 75) This shows the illusions of dreams and love. Titania was in love with what she thought to be the most majestic and absolutely wonderful mortal she had ever laid eyes upon while in reality the creature she fell in love with was an ass. This also shows irony connecting the stubborn personality of Bottom and what he was transformed into. The relevance of Midsummer in the theme of the play is that many things grow in the summer, thrive. It’s a wonderful time and usually what people think of when they think of love. It is the season for life and growth as winter is for death. The nice weather drives people out of their homes and into the open outdoors. This is appropriate because people like Lysander and Hermia wouldn’t normally in winter be traveling through the woods and stop to rest. It would be too cold. The setting also portrays a summer atmosphere. It also believed that the faeries come out to trick passing travelers in the nights of midsummer. They are known to play jokes on them and to get enjoyment out of mortals. This is probably why Oberon is so interested in Helena’s despair. He must feel sorry as well as want to have a little fun with the mortals. He then instructs Puck to fix her love problem. Puck, the trickster faery is very active during this time. He plays tricks on almost everyone in the play, finding enjoyment in transforming Bottom into an ass and making Titania fall in love with him. This play is based upon love, tricks, comedy, and dreams so the faeries coming out during this time was important to the main plot and in agreement with the legend of faeries coming out during midsummer nights. Lastly Puck’s final speech shows the connection between dreaming and theatre by stating â€Å"While these visions did appear. /And this weak an idle theme,/No more yielding but a dream†(pg. 172-173). This shows us that dreams happen in order to weave the importance of the main theme of A Midsummer Night’s Dream. Without the illusion that clouded Titania’s eyes she might not have fallen so deeply in love with Bottom, the ass. During the practice of the play Pyarmus and Thisbe Snout wouldn’t have noticed that Bottom had been transformed. Without the illusion of the love petals of the pansy flower Lysander might have seen through the weak shade of fake love for Helena. He would have realized his heart belonged to Hermia. Demetrius may have never moved on and loved Helena. The ending during Puck’s speech really ties together the whole play and helps us come to the conclusion that dreams were necessary for the plot and theme of the play. Puck wants us to feel as if it was all a pleasant dream, but at the same time he wants us to remember everything that happened, good and bad and learn from it. Nothing in this play is quite what it seems so it is ironic at the end to be trusting Puck who is such a tricky character. What we take from his final speech is to enjoy the happy ending and always be wary of dreams. Dreams and reality coexist in our lives as much as they do in A Midsummer Night’s Dream. We understand the theme of this play more closely if we examine key points that support the theme and title as one. Illusions and reality, Puck’s final speech, and the relevance of midsummer help us connect the title and theme. In A Midsummer Night’s Dream by William Shakespeare, the author uses his knowledge of dreams to create his play. A Midsummer Night’s Dream is not only the title of this play but the overall theme as well. As â€Å"honest Puck† (pg. 173) says before he departs â€Å"So good night unto you all. † (pg. 173) Bibliography â€Å"A Midsummer Night’s Dream: Analysis of Lines 5-20 of the Epilogue. †Ã‚  Article Myriad. N. p. , n. d. Web. 25 Nov. 2012. ;http://www. articlemyriad. com/midsummer-nights-dream-analysis/;. â€Å"The Meaning of the Title in A Midsummer Night’s Dream by Shakespeare – Yahoo! Voices – voices. yahoo. com. †Ã‚  Yahoo! Voices – voices. yahoo. com. N. p. , 10 July 2005. Web. 25 Nov. 2012. ;http://voices. yahoo. com/the-meaning-title-midsummer-nights-dream-6294754. html;. Shakespeare, William. A midsummer night’s dream. Washington Square Press new Folger’s ed. New York: Washington Square Press, 1993. Print. How to cite Midsummer Night’s Dream Analysis, Papers

Contribution of the Oman Court-Free-Samples-Myassignmenthelp.com

Questions: 1.Fraud, incompetence and dishonest are major problems in Agency Law. Analyse this statement in relation to universal agency law, its objectives and how these shortcomings can be overcome in business, quoting relevant Oman Royal Decree. 2.Analyse the structure and contribution of the Oman Court and Legal System, quoting relevant Royal Decree. Answers: 1.Oman Royal Decree stating Agency Law has major problems in cases of fraud, incompetence and dishonest(Al-Shaqsi, 2009). In cases of fraud a person might gain an unfair advantage over the other by omitting elements to do require intent. In cases of incompetence, the person lacks contractual capacity and cannot be appointed as agent. Incompetent persons within Agency relationships cannot be help for any liability or torts, hence can lead to problems in such contracting. In cases of dishonest, liability or tort cannot be established when cases does not involve civil wrong, leading to other party suffering. Oman Royal Decree no. 34/2014 Objectives of Agency Law is to perform duties of the principle by appointment of an agency lawfully. Agency law in the country was established to successfully to form contracts and execute them but there are various shortcomings in relation to attract. Shortcomings relative to fraud, incompetence and dishonest can be overcome in business by including terms that could lead to possible avoidance of fraud and dishonesty. Incompetence can be overcome in case of including terms such that contracting parties are competent. 2.The Sultanate of Oman in the Arabic Gulf constitutes a central Islamic Monarchy with Muscat as its capital. It has four districts Musandam, sohar, Al Barimi and Muscat with five areas. Since its independence gained on July 1970, it is governed by Sultan Qaboos(Baporikar, 2015). Legal system within the country is codified in the Constitution by Royal Decree n101/96. Primary legislation is termed as Royal Decree and secondary legislation is concerned with Ministerial body. The legal system in the country is a mixture of Islamic and Anglo-Saxon law. Conclusion The Oman Royal Decree legislation includes all relevant laws and regulations with connection to contract law, agency law, insurance law, labor law, Intellectual Property law and so on. All legislation are well organised within Courts and the Judiciary with codes of conduct. these codes acts as reference numbers and differs for political life, economic life, criminal affairs, civil matters, environment and so on. All decisions are taken by judicial entities and executed in name of His Majesty the Sultan. Reference Lists Al-Shaqsi, S. Z. 2009. EMS in the Sultanate of Oman. Resuscitation, 740-742. Baporikar, N. 2015. Effect of national culture on development of international business in the Sultanate of Oman. Handbook of Research on Global Business Opportunities, 268-288.

The Crusades Essay Research Paper Crusades were free essay sample

The Crusades Essay, Research Paper Campaigns were Christian military expeditions organized chiefly to recapture Palestine during the Middle Ages. Palestine, besides called the Holy Land, was of import to Christians because it was the part where Jesus Christ had lived. Palestine lay along the eastern seashore of the Mediterranean Sea, and Muslims had taken control of it from Christians. The reformers, who came from Western Europe, organized eight major expeditions between A.D. 1096 and 1270. This was a period when Western Europe was spread outing its economic system and increasing its military forces. The Crusades were a portion of a wide Christian enlargement motion. Kings, Lords, and 1000s of knights, provincials, and townsfolks took portion in the Crusades. They had two ends, to derive lasting control of the Holy Land and to protect the Byzantine Empire, a Grecian Christian imperium centered in southeasterly Europe, from the Muslims. But many reformers besides fought to increase their power, district, and wealths. We will write a custom essay sample on The Crusades Essay Research Paper Crusades were or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The reformers won some conflicts and established a reformer land along the eastern shore of the Mediterranean Sea, but their triumphs had no lasting consequence. However, the Crusades increased already bing contacts between the West and the East. These contacts led to extra trade and commercialism. The reformers failed to carry through their chief ends. They recaptured the Holy Land for a clip but could non set up enduring control over the country. Western and Eastern Christians united to contend the Muslims. But dealingss between the two groups of Christians, particularly as a consequence of the Fourth Crusade, became so acrimonious that they led to a heritage of hatred. The Byzantine Empire fell to the Ottoman Empir vitamin E in 1453. In add-on, the pope’s prestigiousness declined because some Catholic Popes used the Crusades for personal and political addition. However, the Crusades besides enriched European life. For illustration, they farther stimulated economic growing by conveying increased trade between metropoliss that bordered the Mediterranean Sea. The Italian metropoliss of Venice, Genoa, and Pisa prospered and grew powerful by transporting reformers and their supplies to the Middle East, where these metropoliss gained privileges in districts conquered during the Crusades. Goods from Asia passed through these districts on the manner to the metropoliss in Italy. Western Europeans besides learned how to construct better ships and do more accurate maps during the Crusades. They began to utilize magnetic compasses to state waies. The Crusades were of merely modest importance compared to the great commercial enlargement or the rise of monarchies in Western Europe. In the heads of the people of the crusading epoch, nevertheless, the Crusades seemed really of import. Historians one time thought the reformers who returned to Europe acquainted Westerners with the goods and ways of life in the East. The historiographers thought that this contact greatly influenced life in the West. As a consequence of the Crusades, historians one time argued, Europeans were introduced to such points as sugar, silk, velvet, and glass mirrors. Modern historiographers, nevertheless, reject these statements. They say that Europeans had known of sugar, silk, velvet, and glass mirrors before the Crusades. These historiographers point to a broad sum of interchange between Muslims, Byzantines, and Europeans many old ages before the Crusades. Venice, above all, had served for many old ages as a nexus between the East and West.

Cause and Effecf essays

Cause and Effecf essays When a child grows up he wants to live up to his parent's expectations. Sometimes when he fails to meet those expectations he gets discouraged and feels that he has let his parents down. As the child grows he feels that he needs to do the best he can. If he fails to meet the standard he has set, how could his parents be happy with him? Little children will do most things that their parents want them to. Little kids love to help out their parents. As they grow, they in some way want to impress their parents by achieving some great accomplishment, maybe something that could never be reached by someone of his age. They have set their standards so high that it is a big let down to them when they have not reached their goals. Sometimes they may want it so much they work until they get sick or start to drive people away from them. People start expecting a lot from themselves when it seems so simple. When they fail it hurts so much that they will not quit until that goal is met. Sometimes it is best for them to rethink a goal before it becomes too far out of reach that it will not matter if they achieve it or not. Parents sometimes expect a lot from their kids. They may want something for their child that they forget to ask the child if they want it. Then in the process the child doesn't meet what the parent wants and the parent may then tell the child to keep trying. The child may not want what they thought of getting from achieving their goal and may want to quit. The child then becomes angered by his parents' constant interference and starts to set himself apart. Pushing to the breaking point is not exactly helping the child, and sometimes it has a reverse effect. The parents need to see that when the child loses interest in something it is no longer fun for them. Instead, the parents should encourage them to find something that interests them and to strive for a reachable goal. At times it is difficult to know when the goal is u ...

To Live Movie Review Example | Topics and Well Written Essays - 1250 words

To Live - Movie Review Example The script of the movie is intentionally divided into several distinct parts which cover different periods of time. There are 4 decades represented in the movie. The 40-s are characterized by the civil war and revolution in China. They are changed by the 50-s and building communist industrial China. Cultural Revolution enters the country in 1960-s. The end of the movie covers a period after all these events. All these historical events are showed with the help of fiction story integrated in the narrative. It is a story of Fugui, a former landowner and a person who has to live. The story begins in 1940-s, which Chinese civil war unexpectedly changes lives of all people in the state. Fugui has already lost everything; his addiction to bargaining ruined his family and left his without a tile above his head. He manages to cope with poverty and his hard work brings his wife Jiazhen back to him. He is again inspired to live; he wants to ask for credit from the landowner who won his family mansion, but he gets a set of shadow puppets instead. The war enters his life accidentally; during one of the performances of his shadow puppet theater, the knife stubs the curtain and all actors are taken to the nationalist army. Fugui is adaptable to any change in his life; he happens to entertain people in the army by his performances. Eventually he misses the major attack and finds out that nationalists have been killed; only he and his puppet theater partner Chunsheng survive. They try to run away, but the Red Army catches them. They entertain people here again and get back homes alive. On the battlefield, Fugui says the most important words: â€Å"I want to live. There is nothing like family†. Having survived the war, Fugui’s family has a new challenge – to survive the building of Communism. They become very poor; his wife delivers boiled water to people to earn for living. Their daughter

FRANCE Essay Example | Topics and Well Written Essays - 750 words

FRANCE - Essay Example France has been an important model for religious freedom and thought in virtue of the Declaration of the Rights of Man and of the Citizen in the year 1789 and several significant religions are practices in this country, though Roman Catholicism has been the major religion. "In the past, France was a predominantly Roman Catholic country. Since the 1970s, France has become a very secular country. The Declaration of the Rights of Man and of the Citizen says that Freedom of religion is constitutionally a right." (France Principle Religion) Sub-point 1: The other religions practiced in the country include Protestantism, Islam, Judaism and atheism. According to the CIA World Factbook, about 88% of the population in France practices Roman Catholicism, 5 to 10% practice Islam, about 2% Protestantism and 1% of the French population practice Judaism. Sub-point 2: The religious background of France has contributed highly to the progress of the Europe and the world and it is a nation which has contributed the world some of the fundamental principles of secularism and religion including the 'freedom of religion'. A profound analII. Main Point: Cultural Background of France: Family structure A profound analysis of the family structure in France confirms that several social, religious and cultural elements as well as movements have influenced the progress of its culture. The traditional family structure of the French culture, an extended family structure, continued for a long time due, mainly, to the values of the Catholic Church and the rural communities. "The outbreak of the French Revolution created a potent space for questioning the customs, laws, emotions, power relations, and gender assumptions that informed family life. During the 1790s the French Revolution radically redefined the family, its internal dynamics, and its relationship to the state." (Desan, 1) Sub-point 1: The French Revolution created a potent space for questioning the customs, laws, emotions, power relations, and gender assumptions that informed family life and it radically redefined the family, its internal dynamics, and its relationship to the state. Sub-point 2: There has been a vital shift from the traditional family structure to the modern family structure in the French society and culture. III. Main point: Cultural Background of France: Traditions of Religion and Family The traditions of the religion are mostly connected with those of the family and people celebrate religious festivals with lots of enthusiasm and variety in their families and the most important traditions of religion as well as family in France are in connection with Christmas. "Family celebrations begin with the decoration of the Christmas tree a few days before Christmas; candles and lights, tinsel and many colored stars are attached to it. On Christmas Eve when the children are asleep, little toys, candies and fruits are hung on the branches of the tree as a supplement to the gifts Santa Claus has left in the shoes before the fireplace." (Holiday Traditions of France) Sub-point 1: The traditions of

Hybridity Concepts In Postcolonial Studies

Hybridity Concepts In Postcolonial Studies The flow of information and the movement of people in this ever evolving, interconnected and interactive world have been a profound reason in the creation of new cultures in the form of mixing of local and foreign ideas and values. This kind of mixing is a tiny part of the loose and slippery meaning of hybridity. The term hybridity is used in many areas such as hybrid economy (the mixture of private enterprises and government active participation in global economy) (Koizumi,2010); hybrid cars, hybrid language (creole and patois), and most importantly in relation to this study is in the arena of hybrid cultures (Tomlinson,1999; Coombs Brah,2000). Easthope (1998) contends that hybridity can have three meanings; in terms of biology, ethnicity and culture. In biological science, hybrid could mean the composition of genetic component in human being, animals or plants. In the second and third definitions, hybridity can be understood to mean an individual who possesses two or more ethnic and cultural identities. However de Toro emphasises that the meaning of hybridity in modern cultural theory has nothing to do with the biological and zoological origin of the term (de Toro, 2004). Hutnyk (2005) on the other hand reveals that the term hybridity and syncretism seem to serve the inner cultural aspects of colonialism and the global market. Several key thinkers in the realm of hybridity includes among others Homi Bhabha, Robert Young, Gayatri Chakravorty Spivak, Stuart Hall and Paul Gilroy, who draw upon related concepts from Deleuze, Derrida, Marx, Fanon and Bakhtin to name a few.(Ref) In particular, Bhabha has developed his concept of hybridity from literary and cultural theory to describe the construction of culture and identity within conditions of colonial antagonism and equity (Meredith, 1998; Bhabha, 1994; Bhabha, 1996). In socio-cultural milieu, hybridity is used as an explicative term and hybridity became a useful tool in forming a discourse of racial mixing which was seen as an aberration in the end of 18th century. The kind of hybrid during this era was largely referring to inter marriage of black and white and the offspring were identified as the hybrid product. It has also been referred to as an abuse term in colonial discourse for those who are products of miscegenation or mixed-breeds. Papastergiadis in Werbner Modood (2000) on the other hand asserts that the positive feature of hybridity is that it invariably acknowledges that identity is constructed through a negotiation of difference and that the presence of fissures, gaps and contradictions is not necessarily a sign of failure. (ibid:258). Therefore hybridity can be seen in both negative and positive forms. Ashcroft, Griffiths and Tiffin (2006) assert that hybridity occurs in post-colonial societies as a result of economic and political expansion and control and when the coloniser diluted indigenous peoples (the colonised) social practices and assimilate them to a new social mold. They also further explain that hybridity extends until after the period of imperialism when patterns of immigrations from rural to urban region and from other imperial areas of influence; such as Chinese and Indian labourers coming in into the Malay Peninsula during the labour intensive period. However, with the end imperialism, with the rising of immigration and economic liberalisation, the term hybridity has profoundly been used in many different dimensions and is one of the most disputed terms in postcolonial studies. It can take many forms including cultural, political and linguistics. It is important to note that hybridity can be interpreted in many different accounts from a slight hybrid to the extreme of culture clash. In the postcolonial studies the term hybrid commonly refers to the creation of new trans-cultural forms within the contact zone produced by colonisation (Ashcroft et al.,2003). One other dimension of this term is the hybrid talk which is associated with the emergence of postcolonial discourse and its critique of cultural imperialism.(elaborate) Easthope (1998) on the other hand asserts that in his discussions of hybridity, it has no fix definition except in relation to non-hybridity: à ¢Ã¢â€š ¬Ã‚ ¦that the opposition between difference and absolute presence needs to be relativised by introducing more than one concept of identity, that a coherent, speaking subject cannot live in the gaps between identities. (p.347). Pieterse (2001:221) maintains that New hybrid forms are significant indicators of profound changes that are taking place as a consequence of mobility, migration and multiculturalism. In addition, cultural diasporization (Hall, 1990) signifies a new form of identity as a result of interculturality and diasporic relations (Anthias,2010). However, Anthias (ibid:620) postulates that: If hybrid social identities are now the characteristic identities of the modern world, then struggles over cultural hegemony and the underlying mechanisms that support it, become increasingly empty signifiers; merely to occupy the space of the hybrid constitutes an emancipator human condition. In addition, de Toro (1991,1996a) contends that hybridity is always inherent to culture, identity and nations but it is the object of reflections and definitions of different settings and also applied in very different fields. Correspondingly, de Toro suggests that one has to understand the notion of hybridity in a broader metacontext and has to see hybridity as mixing systems at the base of the combination of different models and processes. The discussion of hybridity in this study focuses on the contemporary debate about culture, ethnicity and identity which underpins de Toros model of hybridity as a cultural category. The main argument of this study is the problematic nature of managing the differences of cultural, ethnical and religious groups in Malaysias plural society in the quest for the construction of shared Malaysian identity. The discussion of hybridity in the Malaysian context in this study therefore is not about finding a midway to the solution of differences in cultures and identity but to identify a space where cultural, religious and ethnic difference can be celebrated. In as much the arguments in the succeeding sections deal with ethnicity, culture and religion, this study does not attempt to explicate an in depth discussion of the cultural theory concept. However, cultural theory will be reviewed at a surface level. In the linguistics setting, Bakhtin (1981) puts forward the notion of linguistic hybridity. He, according to Young (1995) delineates the way in which language, even within a single sentence, can be doubled-voiced. Bakhtin affirms that linguistic hybridity mixes two social languages within the limits of a single utterance but differentiated by other factors of those social utterances. Simplistically, it describes the ability to be simultaneously the same but different (ibid:20). Young further postulates that for Bakhtin, hybridity describes the process of the authorial unmasking of anothers speech, through a language that is double-accented and double-styled. Bakhtin (1981) divides his linguistic hybridity into two; intentional hybridity and unconscious or organic hybridity. The former occurs when a voice has the ability to ironise and unmask the other within the same utterance. The organic hybridity , on the other hand occurs when two languages fused together: . the languages change historically primarily by hybridization, by means of a mixing of various languages co-existing within the boundaries of a single dialect, a single national language, a single branch, a single group of different branches, in the historical as well as paleontological past of languages. (Ibid:358). The language hybridity phenomenon is one of main discussions in this current study as the multicultural society evolves in Malaya then Malaysia respectively, languages evolve in tandem. The discussion involves the emergence of Malaysian English or Manglish in social interactions of the populace within ones own ethnic community or with the other communities at large. This is argued in the discussions and findings chapter of this current study. The section that follows discusses in greater detail of hybridity in the light of Bhabhas (1998) work on cultural diversity and cultural difference. Understanding Bhabhas concept of hybridity in relation to cultural diversity Bhabhas conception of hybridity is developed from literary and cultural theory by which he identifies that the governing bodies (coloniser) translate the identity of the colonised (the other) in tandem with the essentialist beliefs. This action of translation however does not produce something that is known to the coloniser or the colonised but essentially new (Papastergiadis, 1997). Bhabha believes that it is this new blurred boundaries or spaces in-between subject-position that are identified as the locality of the disruption and displacement of predominant influence of colonial narratives and cultural structures and practice. Bhabha (1994) claims that the difference in cultural practices within different groups, however rational a person is, is actually very difficult and even impossible and counterproductive, to try and fit together different forms of culture and to pretend that they can easily coexist. As he affirms: The assumption that at some level all forms of cultural diversity may be understood on the basis of a particular universal concept, whether it be human being, class, or race, can be both very dangerous and very limiting in trying to understand the ways in which cultural practices construct their own systems of meaning and social organisation (ibid:209) There is truth to a certain degree to the statement above in terms of the universality of cultural diversity applied in many pluralistic countries including Malaysia. However, to a larger extent, this present study, at a later stage would render the limitations of that statement amidst difficulties and multitudes of problems in inter-ethnic relationship; Malaysian society has proven its ability to be one of the select few which are able to prove that the differences in cultural practices could be the catalyst not hindrance or counterproductive amongst different groups to coexist. This concept of the third space is central and useful in analysing this current study in terms of its interstitial positioning between cultural and ethnic identity with that of a negotiated identity (shared identity) in the Malaysian context. Bhabha believes that the process of cultural hybridity gives rise to new and unidentifiable, a new era of negotiation of meaning and representation. For him controversies are inevitable and unavoidable in a multicultural society as negotiations happen almost in all circumstances including socio-politics and economy down to minute affairs such as in classrooms context. The implication of western colonial legacy which had changed cultural ideology of a former colonised nation is central to the modern discourse of negotiation and instead of questioning the legality of certain cultural status assigned to immigrant cultures, it is inevitable but to accept, admire and celebrate diversity in ways which are appropriately befitting the society as a whole. The significance of the hybridity concept Post-colonial cultural politics assertions: integration and assimilation to unification As a result of hybridisation, dominant culture becomes diluted and more dispersed; less integrated and can then be negotiated. The process of cultural hybridisation allows greater opportunity for local culture to be emphasised thus presents a greater likelihood for more people to feel the sense of belonging. (Canclini,1995;Pieterse,2004). Hybridity needs to be considered as a continuous transaction of renewals and compromise of the practices of identity A more analytical perspective that reviews the assumption about culture and identity from us-them dualism to a collective sense of both. Therefore acceptance and conciliation of both difference and similarity. 5.0. The Third Space Appropriation of The Third Space to the study Otherness Stereotyping in Post Colonial Studies 9.0 Applying hybridity, otherness and stereotyping to the construction of shared identity Identity in Plural Society Propagating and espousing a new conception of shared identity New opportunities, new challenges to develop a collective sense of identity Identity is multiple, overlapping and context-sensitive (Kwame Appiah in Koizumi) New conception of self hybrid self rejects singular identity and adopt a fluid context-dependent identity Classification of identity formation: inherited and acquired (social and psychological) The Construction Malaysian Identity Summary

Street Dreams and Hip Hop Barber Shops Critique

Brad Weiss’s ethnographic research on popular culture, hanging out in barbershops and bus stands, seamstress tables and video halls, was carried out in the northern Tanzanian city of Arusha. In â€Å"Street Dreams and Hip Hop Barber Shops† Weiss does a great job observing the everyday life of the people in Arusha. He explores how globalization and neoliberalism affect the mindset of a community and shows the reader how gender role, media, and self-fashioning can play a big role in a person life. Weiss’s fieldwork and observation is very accurate and informative for the most part but looses the reader in some of the topics that he presents. Brad Weiss does a great job in his chapter on gender and the role that it plays in the community of Arusha. Much of the book has been focused on the expressions of masculinity and the understandings of men that are concerned with gendered personhood, many young men in Arusha comprehend themselves and their relationships with one another in terms of what they imagine women and femininity to be like. But Weiss takes a chapter to turn to women’s practices to show how the cultural process of perception and embodiment allude to the iconography of western culture. Weiss revealed to the reader that women like to keep up with the times in Arusha just like men and they are very conscious about their look and the way they present themselves. Men use magazines and catalogues to keep up with the latest trends but women are one step ahead and use commercials and movies to stay updated. Weiss’s observation was very informative and accurate. This observation proves that globalization can influence people all around the world and have a big effect on a society. Weiss regularly shows the importance of globalization in his writing. His observation on the youth of Arusha was very precise and shows the reader how globalization and neoliberalism can shape a persons life immensely. Weiss tells the reader that through hip hop posters and magazines the younger generation of Arusha use it as a guide for fashion, music and lifestyle. This illustrates how the themes of inclusion and exclusion that shape popular practice-from the assertive modes gendered performances at bus stands and hair salons, to the fashion sense of tailors and their clients, to the viewing preferences of video audiences-operate in Arusha. He explains to the reader that the young men and women of Arusha are social actors who try to find a niche and struggle to participate in a world that is significant for them. I strongly agree with Weiss’s point and believe that every young person in any society are social actors who try to fit in a world that they feel is right for them and use popular culture and globalization as a tool to get there. Brad Weiss does a great job showing the reader that barbershops around Tanzania are more than just a place for getting a haircut. He explains to the reader in great detail that the people of Tanzania see barbershops as a place for obtaining news, catching up on the latest trends, gossip, discovering new music, or just simply hanging out. Barbershops provide men with a â€Å"chance†, an â€Å"opportunity† or a â€Å"place† during times of uncertainty. Weiss spends most of his time at barbershops because it is a great place for studying popular culture and allows him to see what the clients at these barber shops find interesting. There were some things that I found problematic in Weiss’s writing that can turn off some readers. Some parts of the book he tends to over analyze and bore the reader with useless facts. I found myself being turned off during some parts of the book where he begins to ramble on and on. In the introduction chapter he doesn't do a good job of catching the readers attention and takes a long time to get to his point. His writing sometimes ends up being very difficult to read and enjoy at the same time and I found some chapters extremely tedious. Weiss’s writing style can be very uninteresting and dull in the beginning of the book but he later compensates by providing interesting topics and arguments. One thing I really like about Weiss’s writing is that he interacts with the people of Tanzania and takes time to show the reader their story and what they go through in his writing. In one chapter he tells the story of two barbers named Hussein and Ahmed who cut hair at the â€Å"Bad Boyz† barbershop. He provides an ethnographic backdrop to the kinds of activities that go on in the shops and streets. This helps the reader better understand the thought process of the people that Weiss comes across and what they go through on a daily basis. It also gives the reader a different perspective on the effects of neoliberalism and globalization through the eyes of the people in Tanzania. Throughout the book Brad Weiss provides the reader with good background information about the people he observes and tells the reader their story. I find it very useful that he takes time in his writing to make sure the reader understands exactly what is going on instead of just presenting his observations. I was very impressed by how accurate Brad Weiss’s observations were about barbershops and the people that go there in Tanzania. I believe in third world countries barbershops serve as a place for great social activity and exposure to the western culture, people rely on barbershops keep up with the times. When I visited Bangladesh couple summers ago I noticed that most people who go to barbershops go there to socialize and keep up with the latest trends that are coming from the west instead of actually getting a haircut. Just like in Weiss’s writing about the people in Tanzania, Bangladeshi barbershops also have cut posters from magazines decorated around the shop of musicians and athletes and share many of the same characteristics. Overall I found â€Å"Street Dreams and Hip Hop Barbershops† very informative. For the most part I enjoyed reading about the topics and arguments Brad Weiss presented in his work. He did a good job informing the readers about the norms of the Tanzanian society and had a lot of interesting observations. I believe in his writing he had more strengths than weaknesses. Even though some chapters were dull and hard to read Weiss provides interesting information to the reader make up for his flaws. I learned from this book that globalization can integrate societies from all around the world more easily than I previously thought. Exposure to things like food, music, movies and fashion can have a great effect on a group of people from country that doesn't have much culture. Globalization is like a ripple effect that can change the thought process and way of life of an individual and â€Å"Street Dream and Hip Hop Barbershops† did a good job showing that effect.

Inflation and Cost-push Factor Essay

Cost-push factor inflation occurs when there is increase in cost of production of an item, which then gets translated into a higher price for that item in the market. Demand-pull factor inflation occurs when there is more money with the consumers compared to the total number of goods available in the market. With too much money chasing too few goods, prices rise because people are willing to pay more for the same item. This type of inflation generally happened when the demand exceeds supply. On the other hand, when prices fall it is known as deflation. However this is more of a theoretical concept as developing countries rarely experience deflation. Inflation in india: A combination of both cost-push and demand-pull factor exist in india. However cost-push factors are more apparent in the post liberalization period. Prices in india basically increase due to an increase in petroleum product prices, primarily because petroleum is vital input in many manufactured items and also an essential fuel for road transport, aviation and even the railways. As transportation costs rise, the prices of other products tend to rise in general. A noteworthy instance of price rise is the demand-pull factors that led to a steep rise in the price of onions in the year 2000, causing an artificial shortage in the market. In india inflation is calculated on the wholesale price index (WPI), representing the increase in wholesale price market. But it differs greatly if calculated on the consumer price index (CPI), which matters more to consumers. However, calculation of inflation is on wholesale price index because they are more or less same throughout the country, while the consumer or retail prices vary across the different regions (rural and urban) and also among different cities, depending on consumer preference for certain products, the supply and the purchase power. Taxes levied by different states also play an important role in the variation of prices of the same product from one state to another. Though wholesale prices rise at a slow pace (2-3%) comparatively, consumer prices tend to rise at a faster rate (8-9%), which is why we feel the pinch. One of the reason for this is the substantial retailer’s margin, which is built into what the consumer pays. Besides, the way the two indices are calculated differ both in terms of weightages assigned to respective products as well as the kind of item included in the basket of products. However, inflation is a necessary evil for developing and developed countries.

The Doctrine of Successor Liability and the Drift Towards the Assumption of Liability - Free Essay Example

Sample details Pages: 8 Words: 2534 Downloads: 2 Date added: 2017/06/26 Category Law Essay Level High school Did you like this example? Doctrine of Successor Liability: Tracing the drift from the `Traditional non-liability rule to `assumption of liability through judicial precedents AbstractTraditional corporate law has been applied over the years to deal with the liabilities arisen after one companys acquires another company The general rule says that an acquiring corporation doesnt assume any liabilities of the predecessor corporation. The courts over the years have evolved this traditional stance and laid down exceptions, making the successor corporations assume such liabilities. This paper has tried to trace and outline the diversion from the traditional rule of non-liability to the assumption of liabilities by the successor corporations. There are four exceptions to this general non-liability rule which shall be explained in detail with progressing contentions in the research paper. The non liability principle creates hurdles in seeking remedy for the injured. The claimant might lose an y right to damages if he fails to recover from the successor corporation. The liability can even be fixed in environmental issues, where companies will be fixed with `superfund liability and made to cleanup the environment. This principle of fixing liability on the successor corporation in various areas is known as `Doctrine of Successor Liability. This doctrine attempts to bridge the gap between general rule of no-liability and tortious liability. However, the doctrine also safeguards the interest of the successor corporation from assuming any liability for tort committed by the predecessor. This paper evaluates this doctrine through numerous case laws of multiple jurisdictions, with an insight from different governing statutes as well. IntroductionDoctrine of successor liability is a relatively new and evolving field of Jurisprudence. Legal systems around the world largely rely on common law in the area of application this doctrine. A `successor is defined as 1. A person wh o succeeds to the office, rights, responsibilities, or place of another; who replaces or follows a predecessor.2. A corporation that, through amalgamation, consolidation, or other assumption of interests, is vested the rights and duties of an earlier corporation.The Restatement of Tort (3rd.) (2000) Chapter 3 outlines the Libaility of Successor Manufacturers Whether a successor can be liable for defective product sold the predecessor is decided generally by traditional corporate law emphasizes on the type of corporate acquisition between the two corporations. A cash purchase of the predecessors assets, instead of a merger or a stock purchase will attract traditional corporate laws, which holds that the successor will not be liable.There are three ways through which a transfer can be done: (a) by statutory merger or consolidation; (b) through the purchase of the stock of a target corporation; and (c) through the purchase of assets of the target corporation. The traditionally, law of corporations governing the liability of a successor corporation is affirmed in many cases. Ifone corporation sells its assets to another corporation,then the later isnt tortiously liable for the formers conduct. This principle is contended by many courts. Its purpose is to prevent the successor corporations of any liability that arises. It can be traced to the notion that the law does not force the purchaser to assume such liability. American jurisdictions also weave around the general notion that a successorcorporation, which acquires the assets of another company,wont be legally responsible for the actions of its predecessor. Successor liability rule in New York holds that a purchaser is not liable for its sellers liabilities except where there is an express agreement between them governing otherwise. The New York Supreme Court also affirmed the already existing general rule. The logic seems equally applicable as the general rule regarding successor liability is well settled that a corporation does not assume its predecessors liabilities automatically.ExceptionsThere are four recognized exceptions to the general rule. First is applicable where the buyer agrees to assume, expressly or implicitly, the debts and liabilities. The second applies to the transaction where there isconsolidation or merger of the seller and purchaser. Thethird exception is attracted when the successor corporation is merely a continuation of the predecessor corporation. The fourth exception applies to a colorable transaction which is entered in order to defraud the creditors or the shareholders of the seller corporation. The courts over the years have developed thesefour exceptions to the general rule of non-liability forassetpurchasers. Theseexceptions are made with a purpose to ensure that corporations dont evade their liabilities through the use of transactional technicalities.Under the traditional approach, asset purchasers will be considered corporate successo rs if one of the following applies: Assumption- The purchaser expressly or impliedly agrees to assume the liabilities of the seller. The court has noted that an asset sale agreement amounts to a simple transfer, which establishes that the successor didnt attain any liabilities because the identity of the predecessor was not used, nor was any of supervisors hired by the successor. The Court thus held that the buyer did not assume any liabilities of the predecessor, neither expressly nor impliedly. Under the asset purchase agreement, the purchaser did not assume any of the liabilities of the seller, because of a similar reason. In addition, Minnesota Business Corporations Act mandates the presence of a provision in a contract or an agreement to hold the transferee liable. Now in case a situation arises where the language of such a provision in the agreement or a contract is found to be unclear or ambiguous, the courts assume that there is an implied liability on the buyer the fo r defective products, if any. Thus to avoid such discrepancies involving assumption of liabilities, it is best if such an agreement unequivocally states that there is no assumption of future products liability.De Facto Merger- The transaction amounts toa de factomerger or consolidation if the corporation assumes the liability of its predecessor. The important concept in this exception is not the continuation of the business operation but the continuation of the corporate entity. The New York Supreme Court, Appellate Division, First Department, in Van Nocker v. A.W. Chesteron, Co discussed the second successor liability exception. The court notes that asset purchases can be said to be a de-facto mergers if it includes the following four factors:(i) continuation of ownership arising from the use of the successors stock as payment rather than the use of cash(ii) after the transaction the predecessor dissolves as soon as possible,(iii) the buyer assumes liabilities necessary to c ontinue the business of the seller and;(iv) the buyer continues the using predecessors enterprise.The Court in Van Nocker v. A.W. Chesteron, Co. further explained that all of these factors may not be necessarily needed to prove a de-facto merger but presence of the first two is required. It also said that continuity of ownership exists ifthe shareholders of the predecessor corporation become direct or indirect shareholders of thebuyer. Continuity of ownership is a situation where the parties to the transaction become owners together of what formerly belonged to each.b The Van Nocker Court, failing to find either of the first two elements refused to evaluate the other factors. The Fourth Department of the New York Supreme Court, Appellate Division, while determining whether a transaction satisfied the prerequisites of a de-facto merger, held that [w]hile factors such as shareholder and management continuity will be evidence that a de facto merger has occurred, those factors al oneshall not be determinative. The U.S. District Court for the Southern District of New York examined the continuity of ownership element of de facto merger stated, [T]he de-facto merger doctrine creates successor liability when the transaction between the purchasing and selling companies is in substance, if not in form, a merger. The court further stated that the factors should be considered in a flexible manner and question the crux that whether it was the intent of the successor to absorb and continue the operation of the predecessor. It maintained `continuity of ownership as one of the pivotal requirements for a de facto merger. About the fourth factor the court stated that sheer hiring of employees of the seller was insufficient to conclude that there was continuity of management. In Kretzmer v. Firesafe Prods. Corp. the attorney had switched employers and brought along a secretary, an associate, and some cases, the Court held that such an instance didnt amount to a mer ger or consolidation and thus there wasnt a de facto merger. Hence, while dealing with the de facto merger exception, continuity of enterprise or ownership is considered prior to the tree other factors. Mere Continuation: If the corporation has the same shareholders, directors and officers, it will be eligible for this exception. In the Seventh Jud. Dist. the Court said that mere continuation is a type of restructure in which one entity gets dissolved and another survives. The dissolution should take place as soon as possible, but in this case the seller was not dissolved for more than a year, so the Court held it to be out of the ambit of mere continuation exception. In other jurisdictions this exception requires continuity of owners and/or directors. This exception is problematic of application because it has never been quite clear just in what sense a corporation must continue in order to trigger the exception.4. Fraudulent- The transaction was fraudulently entered into to escape liability. The New York courts have laid their emphasis on many fraudulent transactions but have not provided any exceptions for the same. If the creditors of the seller are being defrauded by the transaction, then also it will fall under this exception, Few of the instance can be; if the predecessor corporation holds the possession of the property but doesnt actually own it, making its creditors believe that it still owns the property, if the proceeds of the sale are sent away, and if the property is sold for an insufficient amount to an acquaintance. The malafied intention to defraud has to be proven including those jurisdictions that have adopted the Uniform Fraudulent Conveyance Act.While as other jurisdictions presume such an intention. In situations like these, both the seller as well as the buyer can be held liable.The Continuity of Enterprise Exception.In 1983 Salvativ. Blaw-Knox Food Chemical Equipment, Inc., NewYorks Court of Appeals recognized Continuity o f Enterprise exception, it defined it as a part of corporate reorganization, The Supreme Court of Queens County later explained that the this theory was originally introduced by the Supreme Court of Michigan in Turner v. Bituminous Cas. Co. Salvati noted the Michigan Courts rationale, that it to be unjust to allow the successor to avoid liability Salvati set forth the Michigan courts three criteria test, such continuity would be there if: there wasa continuation of the enterprise of the seller;the predecessor dissolved promptly after the transaction, and the buyer assumed liabilities and obligations of the seller. Salvati accepted the logic put forward in the case of Turner. So the tests laid down by Turner and later reiterated in Salvati are similar to the factors laid down in Van Nocker. The Michigan Supreme Court extended the de facto merger doctrine by eliminating the continuity of shareholder requirement and applying that exception to cash transactions. Product Line Excep tion.In 1977, the California Supreme Court created the product line exception. The Court said: We therefore, conclude that a party which acquires a manufacturing business and continues the output of its line of products under the circumstances here presented assumes strict tort liability for defects in units of the same product line previously manufactured and distributed by the entity from which the business was acquired. Anything to the contrary in Ortiz v. South Bend Lathe, supra, 46 Cal.App.3d 842, or Schwartz v. McGraw-Edison Co., supra, 14 Cal.App.3d 767 (see fn. 6, ante) is disapproved Different jurisdictions have different stands on the product liability exception. In Hickman v. Thomas C. Thompson both the buyer and the seller corporations were of Illinois, the buyer had bought the assets of the seller corporation. Later a resident of Colorado was injured by a product manufactured by this Illinois corporation. There was an arms length agreement, for the purchase of as sets, signed and executed in Illinois. In Illinois the product line exception doesnt hold good. The district court opined that: 1) successor liability is a tort claim, and not a contract claim; 2) As the injury occurred in Colorado so the Colorado law applies; and 3) The Product line exception would be accepted by the Courts. Hickman courts view was dissented in the Tenth Circuit in Florom v. Elliott Mfg., and held that Colorado would reject the product line exception. Comprehensive Environmental Response, Compensation Liability Act and Successor LiabilityCERCLASuccessor corporations are liable the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Thesubstantial continuity test under CERCLA is a continuation successor liability under any other asset purchase. The same general rule of non-liability and the exceptions to it are also applicable in case of successor liability under CERCLA. Many courts have included corporate successors liability w hile interpreting the act. In United States v Bestfoods, the Supreme Court did not make this aspect of superfund liability redundant and kept the substantial continuity test alive in CERLA as well. The Court has laid down CERCLAs purpose as: CERCLAs primary purpose is remedial: to clean up hazardous waste sites. . . . Because it is remedial statute, CERCLA must be construed liberally to effectuate its two primary goals: (1) enabling the EPA to respond efficiently expeditiously to toxic spills, and (2) holding those parties responsible for the release liable for the costs of the cleanup. In that way, envisioned the EPAs costs would be recouped, the Superfund preserved, and the taxpayers not required to shoulder the financial burden of nationwide cleanup. There are various factors which the courts apply while deciding whether a successor corporation should assume any liability Courts applying the substantial continuity test consider a range of factors to determine whether the buyer has substantially continued the predecessors enterprise these include; if any successor corporation continues retaining the following:same employees;same supervisors;same name;same production or service line;same production facilities;continuation of same assets;general business; andwhether the buyer continues the predecessors enterprise. It isnt necessary that a corporation should fulfill all these criteria for it to assume liability of the predecessor. In New York v. Westwood-Squibb Pharm Co. the court held liable the asset purchaser corporation when it satisfied six of the eight factors. CERCLAs purposes and principles of corporate successor liability are both in harmony with the substantial continuity test. However, there are discrepancies that may arise; e.g., sec. 113(f of CERLAprovides PRPs with a statutory right of contribution. 42 U.S.C. 9613(f)(1). Sec.113(f)(2) says that if PRPs enter into settlements with the federal government, it resolves its liability.Con clusionThe general rule of non-liability says that a successor corporation will not assume the liabilities of the predecessor corporation for defective products sold by the predecessor. But the courts over the years have developed principles holding the successor liable. The rift between the liability law and general non-liability corporate law has led to the evolution of such rules by the courts. Mere continuation, de facto merger and the product line doctrines broaden and specify the areas for fixing of liability. These rules have also firmed protection against colourable intent of corporations to avoid liability. Don’t waste time! Our writers will create an original "The Doctrine of Successor Liability and the Drift Towards the Assumption of Liability" essay for you Create order