Thursday, October 31, 2019

Online Application Ning - the Platform Allowing Users to Create and Cl Coursework

Online Application Ning - the Platform Allowing Users to Create and Close Their Own Social Network - Coursework Example This critical analysis functions to examine the role of social networking with a variety of diverse populations, arguing that the widespread social adoption of this technology has not simply been a tool to achieve greater efficiency, but is in actuality reshaping and formatting the nature of human culture and consciousness.A television program recently had a comedic skit where the internet went out in a home and the residents had to resort to a box-labeled ‘pre-internet’ – inside the box were a rubber duck, a barbell, and a fake plastic tree. While most of us recognize that there was a lot more going on in pre-internet times than a box full of trinkets, the absurdity of the skit draws one's attention to the fact that one of the great divides of culture, arguably on the scale of the Protestant Reformation, the Industrial Revolution, or even the Renaissance, is the contemporary occurrence of what has been deemed the Digital Age. Having died in 1980 Marshall McLuhan had only glimpsed its genesis when he proclaimed, â€Å"In this electronic age we see ourselves being translated more and more into the form of information, moving toward the technological extension of consciousness (McLuhan 1967).†With the explosion of Web 2.0 software and the use of social networking sites (SNS), it was certain that professional environments would begin to incorporate the technology. While previous conceptions of computer-mediated communication – video gaming, Facebook use, YouTube – have been characterized as detrimental, the technology is now being reconsidered for its functional value. Many varied corporations have implemented collaborative technology, including Google whose employees hold daily meetings with associates spread throughout the world. One of the most widespread uses of collaborative technology has occurred in education environments. Indeed, certain researchers even argue that this technology is expanding the very nature of the classroom room outside institutional walls.     

Tuesday, October 29, 2019

Representations of Either Male or Female Characters Essay Example for Free

Representations of Either Male or Female Characters Essay In the films I studied, (A clockwork Orange, From Russia with love, Carry on camping and a Hard days night) women are represented in similar ways but in very different circumstances. Firstly in A Clockwork Orange, women are seen as an objectified sexual obsession to the male gang. In almost every seen of the film women are presented in one way shape or form for example in the bar with the erotic, female shaped tables or the posters of women on the walls in Alex’s room. On the topic Kubrick has previously said â€Å"In the film, women are the ultimate harbingers of sexual desire, and it is only them who can suppress it. This power leaves the male ‘Droogs’ inwardly feeling threatened, which in part leads to cowardly rape.† I feel this quote explains the representation of females in the film perfectly as Alex, a man who feels he has great power over the rest of society, is surrounded by women and is always met with his sexual desire for them; Although the idea of sex in A Clockwork Orange is not an expression of love or intimacy, but rather an exhibition of power and violence. In this case Alex feels that to remain ‘powerful’ over everyone else he needs to use women as a object to satisfy his growing needs for power. In From Russia with Love, women are again seen as a object and are infamously named ‘the Bond Girls’ showing how in the larger scale there roles are minor compared to the ‘amazing’ Mr Bond. The opening title to the film shows barely clothed belly dancers dancing and parading there bodies to the Bond theme tune, showing how there bodies are more important then the woman herself. Throughout the film it is apparent that women are only good for a number of tasks: giving massages to the male characters, belly dancing and for casual sex and even then its when the man wants and not the woman. Despite this, in the film the female lead Tatiana played by Daniela Bianchi, shows womans slowly growing power and independence, for example Tatiana smoking representing the freedom that she perhaps now felt, although she is sitting down and Bond is standing over her, clearly in a position of more power. It is felt that the woman in the film are constantly being overlooked by men for example Tatiana killing the villain, which in normal circumstances would make her the ‘hero’ in the film, but this is undermined by the way Bond immediately takes the gun off her, as though it does not belong with her or she is not safe with it. In the film A Hard Days Night whenever the The Beatles perform, the members of the band are all distinguished as four individual, male characters. This massively contrasts with the role of women in the film, as there have been no main female characters; women are either portrayed as screaming, uncontrollable girls or again as sex objects. The idea behind this shows that women have no individuality in the film and are really only there to worship, flirt or to sexually satisfy the boys in the band. Finally the idea of women being perceived as objects is again mirrored in the final film Carry On camping, where the women are seen as objects for the men to flirt with and pursue in a sexual manner. Although Carry on camping differs from the previous films as there are several female characters which are seen to have hierarchy over certain male characters. For example the character Harriet Potter had the power in the relationship and often bossed her husband around in a comical manner. Overall in all the films it is obvious that women are often being represented as objects to satisfy mens needs and dont serve a real purpose in any of the films and if they do it is only in a comical manner to retrieve laughter from the audience.

Saturday, October 26, 2019

Factors Determining Layout And Design

Factors Determining Layout And Design Facility layout and design is an important component of a businesss overall operations, both in terms of maximizing the effectiveness of the production process and meeting the needs of employees. The basic objective of layout is to ensure a smooth flow of work, material, and information through a system. The basic meaning of facility is the space in which a businesss activities take place. The layout and design of that space impact greatly how the work is done-the flow of work, materials, and information through the system. The key to good facility layout and design is the integration of the needs of people (personnel and customers), materials (raw, finishes, and in process), and machinery in such a way that they create a single, well-functioning system. FACTORS DETERMINING LAYOUT AND DESIGN Small business owners need to consider many operational factors when building or renovating a facility for maximum layout effectiveness. These criteria include the following: 1. Ease of future expansion or change-Facilities should be designed so that they can be easily expanded or adjusted to meet changing production needs. Although redesigning a facility is a major, expensive undertaking not to be done lightly, there is always the possibility that a redesign will be necessary, Therefore, any design should be flexible. Flexible manufacturing systems most often are highly automated facilities having intermediate-volume production of a variety of products. Their goal is to minimize changeover or setup times for producing the different products while still achieving close to assembly line (single-product) production rates. 2. Flow of movement- the facility design should reflect recognition of the importance of smooth process flow. In the case of factory facilities, the editors of How to Run a Small Business state that ideally, the plan will show the raw materials entering your plant at one end and the finished product emerging at the other. The flow need not be a straight line. Parallel flows, U-shaped patterns, or even a zigzag that ends up with the finished product back at the shipping and receiving bays can be functional. However, backtracking is to be avoided in whatever pattern is chosen. When parts and materials move against or across the overall flow, personnel and paperwork become confused. 3. Materials handling-Small business owners should make certain that the facility layout makes it possible to handle materials (products, equipment, containers, etc.) in an orderly, efficient-and preferably simple-manner. 4. Output needs- the facility should be laid out in a way that is conducive to helping the business meet its production needs. 1. Space utilization-This aspect of facility design includes everything from making sure that traffic lanes are wide enough to making certain that inventory storage warehouses or rooms utilize as much vertical space as possible. 2. Shipping and receiving-counseled small business owners to leave ample room for this aspect of operations. While space does tend to fill itself up, receiving and shipping rarely get enough space for the work to be done effectively, 3. Ease of communication and support-Facilities should be laid out so that communication within various areas of the business and interactions with vendors and customers can be done in an easy and effective manner. Similarly, support areas should be stationed in areas that help them to serve operating areas. 4. Impact on employee morale and job satisfaction-since countless studies have indicated that employee morale has a major impact on productivity, owners and managers to heed this factor when pondering facility design alternatives: Some ways layout design can increase morale are obvious, such as providing for light-colored walls, windows, space. Other ways are less obvious and not directly related to the production process. Some examples are including a cafeteria or even a gymnasium in the facility design. Again, though, there are costs to be traded off. That is, does the increase in morale due to a cafeteria increase productivity to the extent that the increased productivity covers the cost of building and staffing the cafeteria? 5. Promotional value-if the business commonly receives visitors in the form of customers, vendors, investors, etc., the small business owner may want to make sure that the facility layout is an attractive one that further burnishes the companys reputation. Design factors that can influence the degree of attractiveness of a facility include not only the design of the production area itself, but the impact that it has on, for instance, ease of fulfilling maintenance/cleaning tasks. 6. Safety-the facility layout should enable the business to effectively operate in accordance with Occupational Safety and Health Administration guidelines and other legal restrictions. Facility layout must be considered very carefully because we do not want to constantly redesign the facility, Some of the goals in designing the facility are to ensure a minimum amount of materials handling, to avoid bottlenecks, to minimize machine interference, to ensure high employee morale and safety, and to ensure flexibility. Essentially, there are two distinct types of layout. Product layout is synonymous with assembly line and is oriented toward the products that are being made. Process layout is oriented around the processes that are used to make the products. Generally, product layout is applicable for high-volume repetitive operations, while process layout is applicable for low-volume custom-made goods. AN IDEAL LAYOUT 1. Transport: Movement of materials is a waste. Minimize the amount of movement by arranging processes in close proximity to each other. Factory layouts can often be the fundamental cause of excess transportation. When appropriate, re-laying out the machines within a factory from a functional to a cellular layout has been found by many companies to help not just reduce transportation waste but also reduce WIP and waiting. Items being moved unnecessarily incur a cost. 2. Inventory: Many companies produce above what is required to fulfill the order, this may be due to quality problems along the production process or the often mistaken belief that is saves money by manufacturing larger quantities. Too little inventory can lose sales; too much inventory can hide problems. 3. Motion: Generally, this waste applies to production personnel having to move out of their work area to locate tools, materials, etc. Remove unnecessary motion of the operations and improve the ergonomics of the workplace. People moving unnecessarily also incur a cost. 4. Waiting: Minimize waiting time (operators waiting for machines or products waiting around in factories either as finished goods or work in progress) Aim for a smooth flow. 5. Overproduction: Always aim to make exactly what the customer orders, just in time, to the correct quality standard. On the shop floor, this generally occurs because changeover times are high, equipment is unreliable, the process is unreliable (causes defects), and standard cost accounting metrics are used. However, probably the biggest reason for overproduction is poor information flow (communication) between facilities. 6. Over Processing: Use machines which are of an appropriate capacity and capable of achieving the required quality standard. This usually refers to using larger scale equipment than necessary; it also refers to building in rework to a process. It can also refer to using the wrong suppliers and/or the wrong process. 7. Defects: Reducing the number of defects directly reduces the amount of waste. Aim for zero defects. The efficiency of production depends on how well the various machines; production facilities and employees amenities are located in a plant. Only the properly laid out plant can ensure the smooth and rapid movement of material, from the raw material stage to the end product stage. Plant layout encompasses new layout as well as improvement in the existing layout. It may be defined as a technique of locating machines, processes and plant services within the factory so as to achieve the right quantity and quality of output at the lowest possible cost of manufacturing. It involves a judicious arrangement of production facilities so that workflow is direct. Plant layout refers to the arrangement of physical facilities such as machinery, equipment, furniture etc. within the factory building in such a manner so as to have quickest flow of material at the lowest cost and with the least amount of handling in processing the product from the receipt of material to the shipment of the finished product. The overall objective of plant layout is to design a physical arrangement that most economically meets the required output quantity and quality., Plant layout ideally involves allocation of space and Arrangement of equipment in such a manner that overall operating costs are minimized. IMPORTANCE Plant layout is an important decision as it represents long-term commitment. An ideal plant layout should provide the optimum relationship among output, floor area and manufacturing process. It facilitates the production process, minimizes material handling, time and cost, and allows flexibility of operations, easy production flow, makes economic use of the building, promotes effective utilization of manpower, and provides for employees convenience, safety, comfort at work, maximum exposure to natural light and ventilation. It is also important because it affects the flow of material and processes, labour efficiency, supervision and control, use of space and expansion possibilities etc. ESSENTIALS REQUIREMENTS An efficient plant layout is one that can be instrumental in achieving the following objectives: a) Proper and efficient utilization of available floor space. b) To ensure that work proceeds from one point to another point without any delay. c) Provide enough production capacity. d) Reduce material handling costs. e) Reduce hazards to personnel. f) Utilize labour efficiently. g) Increase employee morale. h) Reduce accidents. i) Provide for volume and product flexibility. j) Provide ease of supervision and control. k) Provide for employee safety and health. l) Allow ease of maintenance. m) Allow high machine or equipment utilization. n) Improve productivity. FACTORS INFLUENCING LAYOUT While deciding his factory or unit or establishment or store, a small-scale businessman should keep the following factors in mind: a) Factory building: The nature and size of the building determines the floor space available for layout. While designing the special requirements, e.g. air conditioning, dust control, humidity control etc. must be kept in mind. b) Nature of product: product layout is suitable for uniform products whereas process layout is more appropriate for custom-made products. c) Production process: In assembly line industries, product layout is better. In job order or intermittent manufacturing on the other hand, process layout is desirable. d) Type of machinery: General purpose machines are often arranged as per process layout while special purpose machines are arranged according to product layout. e) Repairs and maintenance: machines should be so arranged that adequate space is available between them for movement of equipment and people required for repairing the machines. f) Human needs: Adequate arrangement should be made for cloakroom, washroom, lockers, drinking water, toilets and other employee facilities, proper provision should be made for disposal of effluents, if any. g) Plant environment: Heat, light, noise, ventilation and other aspects should be duly considered, e.g. paint shops and plating section should be located in another hall so that dangerous fumes can be removed through proper ventilation etc. Adequate safety arrangement should also be made. Thus, the layout should be conducive to health and safety of employees. It should ensure free and efficient flow of men and materials. Future expansion and diversification may also be considered while planning factory layout. DYNAMICS OF PLANT LAYOUT Plant layout is a dynamic rather than a static concept meaning thereby if once done it is not permanent in nature rather improvement or revision in the existing plant layout must be made by keeping a track with development of new machines or equipment, improvements in manufacturing process, changes in materials handling devices etc. But, any revision in layout must be made only when the savings resulting from revision exceed the costs involved in such revision. Revision in plant layout may become necessary on account of the following reasons: a) Increase in the output of the existing product b) Introduction of a new product and diversification c) Technological advancements in machinery, material, processes, product design, fuel etc. d) Deficiencies in the layout unnoticed by the layout engineer in the beginning. APPLICABILITY OF PLANT LAYOUT Plant layout is applicable to all types of industries or plants. Certain plants require special arrangements which, when incorporated make the layout look distinct form the types already discussed above. Applicability of plant layout in manufacturing and service industries is discussed below. In case of the manufacturing of detergent powder, a multi-story building is specially constructed to house the boiler. Materials are stored and poured into the boiler at different stages on different floors. Other facilities are also provided around the boiler at different stations. Another applicability of this layout is the manufacture of talcum powder. Here machinery is arranged vertically i.e. from top to bottom. Thus, material is poured into the first machine at the top and powder comes out at the bottom of the machinery located on the ground floor. Yet another applicability of this layout is the newspaper plant, where the time element is of supreme importance, the accomplishment being gapped in seconds. Here plant layout must be simple and direct so as to eliminate distance, delay and confusion. There must be a perfect coordination of all departments and machinery or equipment, as materials must never fail. Plant layout is also applicable to five star hotels as well. Here lodging, bar, restaurant, kitchen, stores, swimming pool, laundry, shaving saloons, shopping arcades, conference hall, parking areas etc. should all find an appropriate place in the layout. Here importance must be given to cleanliness, elegant appearance, convenience and compact looks, which attract customers. Similarly plant layout is applicable to a cinema hall, where emphasis is on comfort, and convenience of the cinemagoers. The projector, screen, sound box, firefighting equipment, ambience etc. should be of utmost importance. A plant layout applies besides the grouping of machinery, to an arrangement for other facilities as well. Such facilities include receiving and dispatching points, inspection facilities, employee facilities, storage etc. Generally, the receiving and the dispatching departments should be at either end of the plant. The storeroom should be located close to the production, receiving and dispatching centers in order to minimize handling costs. The inspection should be right next to other dispatch department as inspections are done finally, before dispatch. The maintenance department consisting of lighting, safety devices, fire protection, collection and disposal of garbage, scrap etc. should be located in a place which is easily accessible to all the other departments in the plant. The other employee facilities like toilet facilities, drinking water facilities, first aid room, cafeteria etc. This can be a little away from other departments but should be within easy reach of the employees. Hence, there are the other industries or plants to which plant layout is applicable. The importance of a layout would be better appreciated if one understands the influence of an efficient layout on the manufacturing function: it makes it smooth and efficient. Operating efficiencies, such as economies in the cost of handling materials, minimization of production delays and avoidance of bottlenecks all these depend on a proper layout. An ideally laid out plant reduces manufacturing costs through reduced materials handling, reduced personnel and equipment requirements and reduced process inventory. The objectives or advantages of an ideal layout are outlined in the paragraphs that follow. The advantages are common to all the plants, irrespective of age; and whether a plant employs 50 workers or 50,000 makes no difference in so far as the applicability of the plant layout advantages is concerned. Some of these advantages are: Economies in Handling Nearly 30% to 40% of the manufacturing cost is accounted for, by materials handling. Every effort should, therefore, be made to cut down on this cost. Long distance movements should be avoided and specific handling operations must be eliminated. A cynic may say that the cheapest way to handle materials is not to handle them at all. But, in a factory, materials have to be handled; and therefore, it all depends on the layout. Effective Use of Available Area Every inch of the plant area is valuable, especially in urban areas. Efforts should therefore be made to make use of the available area by planning the layout properly. Some steps for achieving this end are: location of equipment and services in order that they may perform multiple functions; development of up-to-date work areas and operator job assignments for a full utilization of the labor force. Minimization of Production Delays Repeat orders and new customers will be the result of prompt execution of orders. Every management should try to keep to the delivery schedules. Often, the deadline dates for delivery of production orders are a bug-a-boo to the management. Plant layout is a significant factor in the timely execution of orders. An ideal layout eliminates such causes of delays as shortage of space, long-distance movements of materials, spoiled work and thus contributes to the speedy execution of orders. Improved Quality Control Timely execution of orders will be meaningful when the quality of the output is not below expectations. To ensure quality, inspection should be conducted at different stages of manufacture. An ideal layout provides for inspection to ensure better quality control. Minimum Equipment Investment Investment on equipment can be minimized by planned machine balance and location, minimum handling distances, by the installation of general purpose machines and by planned machine loading. A good plant layout provides all these advantages. Avoidance of Bottlenecks Bottlenecks refer to any place in a production process where materials tend to pile up or are produced at a speed, less rapid than the previous or subsequent operations. Bottlenecks are caused by inadequate machine capacity, inadequate storage space or low speed on part of the operators. The results of bottlenecks are delays in productions schedules, congestion, accidents and wastage of floor area. All these may be overcome with an efficient layout. Better Production Control Production Control is concerned with the production of the product of the right type, at the right time and at a reasonable cost. A good plant layout is a requisite for good production control and provides the production control officers with a systematic basis upon which to build organization and procedures. Better Supervision A good plant layout ensures better supervision in two ways: 1. Determining the number of workers to be handled by a supervisor and 2. Enabling the supervisor to get a full view of the entire plant at one glance. A good plant layout is, therefore, the first step to good supervision. Improved Utilization of Labor Labor is paid for every hour it spends in the factory. The efficiency of a management lies in utilizing the time for productive purpose. A good plant layout is one of the factors in effective utilization of labor. It makes possible individual operations, the process and flow of materials handling in such a way that the time of each worker is effectively spent on productive operations. Improved Employee Morale Employee morale is achieved when workers are cheerful and confident. This state of mental condition is vital to the success of any organization. Morale depends on: (a) Better working condition; (b) Better employee facilities; (c) Reduced number of accidents; (d) Increased earnings. Plant layout has a bearing on all these. Avoidance of unnecessary and costly changes. A planned layout avoids frequent changes which are difficult and costly. The incorporation of flexibility elements in the layout would help in the avoidance of revisions.

Friday, October 25, 2019

Auroville :: Philosophy Essays

Auroville The question often comes up, what environment would allow us to easily embody our beliefs and lead a life free of hypocrisy. Communities are an excellent, even if not the only solution. The gathering of diverse people based on a similarity in their aspirations and interests forms a whole that is greater than the sum of the parts. One of the most successful attempts at forming such a community is Auroville, located in southern India. Auroville came into existence in 1968 and, at that time, comprised largely of the followers of the Mother. The Mother was a French disciple of the Indian philosopher Sri Aurobindo who became a spiritual leader in her own right. The Mother wanted Auroville to be a city of human unity and international understanding and she formed the Auroville Charter: 1. Auroville belongs to nobody in particular. Auroville belongs to humanity as a whole. But to live in Auroville one must be a willing servitor of the Divine Consciousness. 2. Auroville will be the place of an unending education, of constant progress, and a youth that never ages. 3. Auroville wants to be the bridge between the past and the future. Taking advantage of all discoveries from without and from within, Auroville will boldly spring toward future realizations. 4. Auroville will be a site of material and spiritual researches for a living embodiment of an actual Human Unity. Although the Mother’s Charter is almost exclusively spiritual in its content, almost from the very beginning the citizens of Auroville added a strong earth-care focus to the founding ideals of the community. Today, Auroville has grown into a community of almost 2000 people from nearly 30 different countries. The main township consists of four zones at the center – the industrial, cultural, residential and the international. This is surrounded by an afforested green belt. The town is divided into about 80 ‘sub-communities’ of various sizes, separated by village and temple lands. The citizens of Auroville are encouraged to take part in any activity that is in accordance with the community’s ideals. This does include profit-making business as well. The activities of the people include afforestation, organic agriculture, educational research, health care, village development, renewable energy, town planning and cultural services. The township now organically grows about 40% of its food and generates 35% of its own electrical and thermal energy.

Wednesday, October 23, 2019

Criminal Law 9 Offences Against Property

Theft – The Theft offence is defined under S1 of the ‘Theft act 1968’. Where it provides that if ‘A person dishonestly appropriates property belonging to another, with the intention of permanently depriving the other of it,’ will be guilty of the offence. For this charge to be upheld, both the actus Reus and the mens rea have to be established. Actus Reus – Beginning with the physical element of the crime, the actus Reus it is made up of 3 elements – ‘appropriates, property, belonging to another. ’ Appropriation is defined in S3, ‘Any assumption by a person of the rights of an owner amounts to appropriation. This includes coming across the property innocently or not without stealing it and treating the property how the owner would. Examples of this would be using, eating, selling, destroying, lending/hiring the property. The case examples are: ? ‘Pitman v Hehl (1977)’ – ‘defendant sold propert y belonging to another. Offer of sale is an assumption of right. It didn’t matter whether the property was removed or not. ? ‘Morris, (1983)’ – At least one assumption of all the rights Switched price labels in shop. ? ‘Lawrence (1971)’ – With consent An Italian student paying for taxi ride, ? 6 instead of 50p. ‘Gomez’- Lied about cheques so friend could take supplied goods. Dishonestly appropriating goods, induced through fraud, deception or a false representation to consent. ? ‘Hinks’ – Consent without deception, got naive friend to put money in account. Said where gifts however also results to appropriation. Property has been defined under S4; this includes money, real property (buildings and land, personal property, things in action (bank accounts) and other intangible assets. (e. g. Patent) ? Kelly and Lindsay (1998) – Taken body parts from the royal college of surgeons to make casts.Normally dead bodies are not property however; belonged to the royal college. ? A-G of Hong Kong v Chan Nai-Keung- Stolen quota ? Oxford v Moss – Not intangible property , – knowledge of the questions on a exam paper ? Wild mushrooms and plants cannot be property unless it is taken for reward or commercial purposes. Not theft if creatures are wild, but theft if they are in captivity or owned. Belonging to another is defined under S5, ‘property shall be regarded as belonging to any person having possession or control over it, or having in it any proprietary right or interest. Therefore prosecution do not have to prove who the legal owner is. ‘Turner (no. 2) (1971)’ Stealing own car Garage was in control of the property as he left it with them to make repairs and pay thereafter. Guilty, when property may not belong to another. (1) Trust property, where trustee steals it (2) Property received under obligation – ‘Hall, (1972)’ – Travel agent, deposits for client tickets. Klineberg and Marsden,’ Obligation to make deposits in a certain way. Timeshare apartments. ‘Davidge V Bunnett’ Money for bill but didn’t. 3)Property received by another’s mistake – ‘A-G Reference (No 1 of 1983) (1985) – Salary overpaid through bank transfer, had an obligation to repay. Mens Rea – Within the offence of the theft the mental element of the crime the mens rea is the ‘dishonest intention’. Dishonesty, it has to be proved that they defendant appropriated dishonestly, there is no definition under S2 however it states that it is irrelevant whether it was made with a view of gain or own benefit. Therefore meaning if the other entire elements are present the defendant’s motive is not relevant.S2 provides 3 situations in which the defendant’s behaviour is not dishonest. If a genuine belief in one of the three below not guilty. A) He has in law the right to deprive the other of it, on behalf of himself of a third person. b) He would have the consent if the other knew of the appropriation and the circumstance of it. c) The person who the property belongs to cannot be discovered by taking reasonable steps. Willing to pay – it doesn’t prevent dishonest conduct. ‘A person’s appropriation of property belonging to another may be dishonest notwithstanding that he is willing to pay for the property. The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital, He claimed fees for operations he had not carried out. COA decided dishonestly has both objective and subjective element. 1. Was the action dishonest according to the ordinary standards of reasonable & honest people? Objective 2. Did the defendant realise that what he was doing was dishonest by those standards? Subjective Here the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted.Intention to permanently deprive this is the final element, which is defined in S6. ‘Velumyl’ – Company manager took ? 1050 from safe. He said owed money to a friend and would replace later. COA upheld conviction as he has intention of permanently depriving company of banknotes. Permanent e. g. destroys property ‘DPP v Lavender (1994) – took doors from council property at time of repair and used to replace damage door in girlfriend council flat. Borrowing is not theft unless it is for a period and in circumstances making it equivalent to taking it or disposal Lloyd’ – Not theft, film taken copied and brought back undamaged. ‘Easom’ – The defendant picked up a handbag in a cinema, rummaged through its contents and then put it back without having taken anything, condition intention, not guilty. Robbery is an offence defined under S8 o f the ‘Theft act 1968’, it provides’ A person is guilty of robbery if he steals, and immediately before or at the time of doing so, and in order to do so, he uses force on any person or puts or seeks to put any person in fear of being then and there subjected to force,’ will be convicted of robbery.This is basically aggravated theft, by the use or/and threat of force. For robbery, theft must be completed for robbery to be committed, all the elements of theft need to be present, and therefore if there is no theft, there is no robbery. The elements which have to be proved for the actus Reus of robbery are:- 1. Theft 2. Force or putting or seeking to put any person in fear of force. ( immediately before or at time of theft and must be in order to steal) Completed Theft – Where force is used to steal, the moment that theft is complete, there is a robbery.A case example is Corcoran v Anderton (1980) – Defendant hit woman in back and then tugged at her bag. She let go of the bag, however the defendants ran off without it, as the lady was screaming. It was held that theft occurred, therefore guilty of robbery, (temporary Appropriation). If she had not let go of the bag, theft would not be completed, but could be charged with attempted robbery, (s9 (2) Theft Act 1968). Force or threat of force – The prosecution must prove that there was a force or threat of force present. This is determined by the jury. It has been said the amount of force use can be small. In ‘R v Dawson’, one the defendant nudged the victim causing loss of balance so the other could take his wallet. Jury to decide if the force was present; charged with robbery †¢ In R v ‘Clouden’, the defendant had wrenched on the victim’s handbag from her hands. COA held that whilst taking of property without resistance from the owner, should not amount to robbery, the question of force ‘on any person’ should be left to the jury. The force must be immediately before or at the time of the theft. – It is decided by the jury the length of theft, but it has been held that theft is a continuing act. When theft is completed. ‘Hale (1979)’, the two defendants forced their way in. One defendant put his hand over her mouth to stop her screaming while the other went upstairs and took a jewellery box and then tied up her up before leaving. COA, force of hand over mouth and theft ongoing. †¢ ‘R v Lockley’, the defendant The defendant, with two others, was caught shoplifting cans of beer from an off-licence and used force on the shopkeeper who was trying to stop them escaping   The defendant appealed on the basis that the theft was complete when he used the force, but the Court of Appeal followed Hale and dismissed his appeal. On any person – This force or threat of force can be put on any; it does not have to be the person from whom the threat occurs. An exampl e situation is bank robbery and force on customers. – Force in order to steal – If force is not used in order to steal it is not robbery, example being fight between defendant and victim and then theft. The defendant charged with OAPA and also theft. For the mens rea of robbery it must be proved that the defendant had the:- 1. Intention for theft 2. Intended to use force to steal. Burglary offence is under S9 of ‘Theft act 1968. It defines 2 different ways to commit burglary. Common elements of both, (a) entry (b) of building or part of building, (c) as trespasser. Under S9(1)(a)‘A person is guilty of burglary if he enters any building or part of a building as a trespasser , with intent to steal, rape, do unlawful damage and inflict gbh. Under S9(1)(b)‘ A person is guilty of burglary if he enters any building or part of a building as a trespasser, he steals or attempts to steal anything in the building or inflicts or attempts to inflict gbh on any per son in the building. Actus ReusNot defined in ‘Theft act 1968’, but there are several cases of the meaning. ‘Collins’ – COA, Jury satisfied that D made ‘effective and substantial entry’ ‘R v Brown’ – ‘Effective entry’. D was outside shop window leaning in, looking through goods. ‘Ryan (1996)’ – D entered, trapped in window of a house at 2:30am, half body inside. The theft act gives extended meaning for the word building, but a basic definition is not given, however never really a problem with this. It includes houses, flats, offices, factories†¦ It also includes outbuilding and sheds.Large storage containers – ‘B and S v Leathley (1979) A freezer container had been in a farmyard and been used for storage. It had be held to be a building Part of building. This is where a defendant has permission to be one area of the building however not another. ‘Walkington (197 9) – D went to the counter of the shop and open the till. S (9) (1) (a). Defendant to be committed of burglary he must enter as a trespasser. If have permission – not a trespasser. ‘Collins’ – Drunken defendant wanted sex, he saw an open window and climbed a ladder to look. A naked girl was asleep in†¦ Entered the room.She thought he was her boyfriend †¦ they had sex. Charged under S9 (1) (a), Enter, trespasser with intent to rape. On appeal, conviction quashed as he was not a trespasser. A defendant can become a trespasser even if he has a permission to enter. This is when the defendant goes beyond the given permission. ‘Smith and Jones (1976)’ – Smith and friend went to smiths fathers house and took two television sets without his father’s knowledge/ permission. His father stated that his son is not a trespasser, (general permission to enter). However COA, guilty of Burglary, S9 (1) (b), ‘entering in acce ss of the permission given to him’.In line with ‘Barker v R (1983)’ Neighbour to look after property, told defendant that there is a key hidden if needed, but however entered property to steal. Mens Rea – 2 parts Both, S9 (1) (a) and S9 (1) (b), must intend or be subjectively reckless to enter as a trespasser. With S9 (1) (a) the defendant will also need the intention of committing at least one of the four offences stated when entering. He needs intention to steal or condition intention. For S9 (1) (b) the defendant must also have the mens rea for theft or gbh when committing or attempting to commit the actus Reus of burglary.Deception Offences (Fraud) and Making off without payment. Deception Offences ? Obtaining property by deception (s15 Theft Act 1968); ? Obtaining services by deception (s1 Theft Act 1978); ? Evading liability by deception (s2 (1) Theft Act 1978). Common Elements – (1) Deception (2) obtaining/evading (3) Dishonesty [pic]Basic de finition is stated in S15 (4) Theft Act 1968. ‘Any deception (whether deliberate or reckless) by words or conduct as to the fact or as to law, including a deception as to the present intentions of the person using the deception or any other person’.It applies to all 3 offences. It makes clear the deception can be words, silence, conduct†¦ Deception definition – ‘DPP v Ray (1973)’ – Lord Reid. ‘Deceive is to induce a man to believe that a thing is true which is false, and which the person practising deceit knows or believe it to be false’ Deception can be deliberate or reckless. Spoken or written words -‘Silverman- (1987)’ D gave excessive quotation to 2 elderly sisters, after building a good relationship from past. COA said it is deception. Quashed because jury. – Conduct (e. g. alse cards, uniform) – ‘Barnard- (1837)’ went in to shop in oxford worn student clothes, and stated that he w as a student, so could get sold products on credit. False pretent Silence– Can be implied in certain situations, ‘DPP v Ray’ – (1973). Went to restaurant with friends, he didn’t have enough money but friend agreed to pay, however they all decided not to pay and then ran out of restaurant. Circumstances Also when circumstances have changed – ‘Rai – (2000)’ – Applied for grant for downstairs bathroom for elderly mother. It approved but she died, did not tell council. Firth 1990)’ – Doctor who failed to inform the NHS hospital, that some patients were private, he avoided paying charged to the hospital. Use of cheques When a person writes a cheque, it implies that they have the bank account and money in this, to pay for the cheque, representations of fact. ‘Gilmartin (1983)’ D paid for supplies with a post dates cheque which he knew would not be met. Use of cheque guarantee cards – It i s issued by the bank on current accounts, which has a limit of ? 50- ? 100. The bank guarantees that a cheque up to a specific amount will be met by bank. ‘Charles (1976)’. D bank account had overdraft of up to ? 00. Has cheque guarantee card for up to ? 30. Not meant to use more than 1 a do. Wrote 25 of ? 30, also knew he no sufficient funds. HOL, false representation S16, Theft act 1968 (Obtaining a pecuniary advantage by deception. Credit cards. Representations, user of card is the name on card and has the authority of Card Company to use it. ‘Lambie (1981)’ D had a Barclaycard credit card which had a limit of ? 200; she exceeded limit and bank asked for card to be returned. HOL reinstated it. Deception as to fact, law intention. False statement about the law can be deception and also deception about the facts. King and Stockwell (1987)’ The falsely represented to woman that they were reputable firm of tree surgeon, and made false claims to make h er agree to pay for work. Attempting to obtain property by deception. [pic]As well as proving deception, it must be shown that a person was deceived and property/service/ evade liability as a result of deception. Common in all deception offences. Deception is not relevant to the person to whom it is made. ‘Laverty’. D changed number plates and chassis of car and sold to plaintiff. Not deception as plaintiff thought he was owner and no prove of deception. Etim v Hatfield’ D produced false declaration to PO clerk that he was entitled to supplementary benefits. Clerk gave him ? 10. 60. Without deception no payment would be given. Machines, not possible for deception to happen, however it may be charged as theft. Deception after obtaining is not deception. ‘Collis-Smith’ D filled car up with petrol and claimed that his company would pay for his petrol. Ownership of petrol passed to him. Led to new law of the theft act 1978 under, S2. [pic] It must be pro ved in all deception offences. The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital.He claimed fees for operations he had not carried out. COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? Objective †¢ Did the defendant realise that what he was doing was dishonest by those standards? Subjective Here the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. – Intention to permanently deprive, S15 (3) states that S6 shall apply to this offence, the word ‘‘appropriation’ is changed to ‘obtaining. – Makes the deception deliberately or to be reckless as to whether they are deceiving others Obtaining Property by Deception is defined in S15 of the Theft act 1968 it states that any deception made to dishonestly obtain property belonging to another, with the intention of permanently depriving the other of it. It is similar to theft however property must be obtained through deception. Most offences of obtaining by deception could also be charged with theft, since the case of Gomez which overlapped these laws. Actus Reus. Obtain – S15 (2), states that obtain means ‘obtaining ownership, possession or control of it.Any one is sufficient; makes clear that obtaining can be for another person or to enable another person or to keep it. Property – It has the same meaning as it theft. It includes money and all other property, real or personal, including things in action (bank accounts) and other intangible assets (e. g. Patents). The only difference being that it has no restrictions on obtaining land (limited situations) Belonging to another has the same meaning as in theft, therefore it means ‘any person having possession or con trol over it, or having in it any proprietary right or interest. ’Obtaining because of deception – As well as proving deception, it must be shown that a person was deceived and property obtained as a result of deception. Deception is not relevant to the person to whom it is made. ’ Laverty’. D changed number plates and chassis of car and sold to plaintiff. Not deception as plaintiff thought that defendant was owner, no proof of deception. ‘Etim v Hatfield’ D produced false declaration to PO clerk that he was entitled to benefits. Clerk gave him ? 10. 60. Without deception no payment would be given. Deception after obtaining is not deception. Collis-Smith’ D filled car up with petrol and claimed that his company would pay for his petrol. Ownership passed to him. Led to S2 theft act 1978 Mens rea – Dishonest – The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital. He cla imed fees for operations he had not carried out. COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? O †¢ Did the defendant realise that what he was doing was dishonest by those standards? SHere the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. – Intention to permanently deprive, S15 (3) states that S6 shall apply to this offence, the word ‘‘appropriation’ is changed to ‘obtaining. ‘ – Makes the deception deliberately or to be reckless as to whether they are deceiving others Obtaining Services by Deception is a offence under S1 of Theft act 1978, which states, ‘S1 (1) A person who by any deception dishonestly obtains services from another shall be guilty of an offence.S1 (2) It is an obtaining o f services where the other is induced to confer a benefit by doing some act, or causing or permitting some act to be done, on the understanding that the benefit has been or will be paid for. The defendant make the other person induce to confer a benefit by: AR Doing some act Causing some act to be done Permitting some act to be done This part of the actus Reus covers a wide range of situations of the ways that the offence can be committed. The act must cause a benefit to the defendant and must be proved that the benefit ‘has been or will be paid for. If the benefit is free there is no offence even if the defendant was dishonest. The victim doesn’t have to suffer any loss. Service – E. g. haircut, hotel stay, entertainment activity, film, repair of goods, cleaning and decoration etc. ‘Widdowson’ obtaining of hire purchases in order to buy a car was a service. ‘Halai’ Mortgage advantage not a service. But S1 (3) inserted into S1 by the the ft, (amendment) act 1996. Now contained in S1 theft 1978. ‘Sofroniou’ – Obtaining loans through a bank account or by way of overdraft was now, with the amending addition of S1 within the meaning of services.COA held that opening bank account and obtaining credit card is also a service. Understanding that the benefit has been or will be paid for. For there to be an offence they have to be shown that they were a benefit which had been or would be paid for. ‘Sofroniou’. D opened 2 bank accounts under false names, and then arranged for loans in both accounts causing account to become overdrawn. He then applied for store credit and exceeded limit. Convicted of S1 theft act 1978. Understanding of the payment Mens rea – Dishonesty, deception was made intentionally or recklessly – Dishonest – The Ghosh Test (1982) – Leading case on dishonesty.Ghosh a doctor, (a locum consultant) at hospital. He claimed fees for operations he had n ot carried out. COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? O †¢ Did the defendant realise that what he was doing was dishonest by those standards? S Here the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. – Makes the deception deliberately or to be reckless as to whether they are deceiving othersEvasion of Liability is under S2 if the Theft act 1978, it creates a number ways that evasion of liability can be committed2(1) (a) dishonestly secures the remission of the whole or part of any existing liability to make a payment, whether his own liability or another's; or 2(1) (b) with intent to make permanent default in whole or in part on any existing liability to make a payment, or with intent to let another do so, dishonestly induces the creditor or any person claiming payment on behalf of the creditor to wait for payment (whether or not the due date for payment is deferred) or to forgo payment; or 2(1) (c) dishonestly obtains any exemption from or abatement of liability to make a payment; shall be guilty of an offence. The liability is limited to legally enforceable liability Securing remissions of a liability – E. g. persuades creditor to let him off repaying all or part of debt, through untrue stories and deception. Jackson’ D paid for petrol using a stolen credit card, it was decided that he had an existing liability to pay for it by deception through the stolen credit card Inducing a creditor to wait or forgo payment, with (a) There must be an existing liability, but for (b) this offence it is enough if the defendant induces the creditor to wait for payment or forgo payment, the defendant must intend to make a permanent default. ‘Holt and lee’ – Two defendants had a meal i n a pizza restaurant, after they finished they made a plan to tell their waitress they had already made payment to another member of staff, so they could leave without paying. This was heard by an off duty police officer and they were arrested for attempting to induce a creditor to forgo payment. Turner’ (1974) – Defendant owed money for some work done, but the defendant said he had no ready cash and persuaded creditor to accept a cheque which he knew would not be met. Intent Obtaining an exemption from or an abatement of liability – Covers many everyday situations. E. g. People use invalid tickets or claim discounts that they are not entitled to. Leading case’ Sibartie’(1983) Defendant was a law student, bought two season tickets for daily journey, one ticket covering the beginning of his journey and the other ticket covering the end of his journey on; in between were 14 stations including an interchange station which had no valid ticked.At the in terchange station passing a ticket inspector, the appellant flashed ticked so fast so that she could not see what was on it. He with evasion of a liability by deception, contrary to section 2(1) (c) of the Theft Act 1978. ‘Firth 1990)’ – Doctor who failed to inform the NHS hospital, that some patients were private, he avoided paying charged to the hospital. Mens rea [pic]As well as proving deception, it must be shown that a person was deceived evaded liability as a result of deception. Common in all deception offences. Deception is not relevant to the person to whom it is made. ‘Laverty’. D changed number plates and chassis of car and sold to plaintiff. Not deception as plaintiff thought he was owner and no proof of deception. Etim v Hatfield’ D produced false declaration to PO clerk that he was entitled to supplementary benefits. Clerk gave him ? 10. 60. Without deception no payment would be given. Machines, not possible for deception to happ en, however it may be charged as theft. Deception after obtaining is not deception. ‘Collis-Smith’ D filled car up with petrol and claimed that his company would pay for his petrol. Ownership of petrol passed to him. Led to new law of the theft act 1978 under, S2. [pic] It must be proved in all deception offences. The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital. He claimed fees for operations he had not carried out.COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? Objective †¢ Did the defendant realise that what he was doing was dishonest by those standards? Subjective Here the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. – Intention to permanently deprive, S15 (3 ) states that S6 shall apply to this offence, the word ‘‘appropriation’ is changed to ‘obtaining. ‘ – Makes the deception deliberately or to be reckless as to whether they are deceiving othersMaking off without payment, is defined under S3 (1) of the Theft Act 1978, it provides ‘a person who, knowing that payment on the spot for any goods supplied or service done is required or expected from him, dishonestly makes off without having paid as required or expected and with intent to avoid payment of the amount due shall be guilty of an offence. ’ The goods supplied or service must be lawful, if not there is no offence. This offence was created as the Theft act 1968 had many loop holes which meant many defendants were getting off not guilty even if defendants conduct seen by many as ‘criminal’. One gap was seen in the case ‘Greenburg’ (1972) – D filled car up at garage and driven off without paying, not guilty as moment petrol was appropriated it belonged to him. Payment on the spot’ includes payment at the time of collecting goods on which work has been done or in respect of which service has been provided. Needs to be proved that POTS was required or expected. ‘Vincent’ (2001) – D stayed at two hotels and left without fully paying his bills, having persuaded both hotel owners, by deception, to postpone payment, so POTS was not required. The COA quashed his conviction under S3, because the hoteliers had agreed to postpone payment, which meant that the actus Reus had not been committed. Makes off – The defendant must make off for the spot that payment is required ‘McDavitt’- D refused to pay a bill after an argument with the manager. D walked towards the door but was told the police were called. D went to the toilet and remained there.Directed jury to acquit the defendant, as he had not made off without payment. ‘Brooks & Brooksà ¢â‚¬â„¢, D1 ran out of a rear door and D2 was caught having walked out of a restaurant. ‘The spot’ was treated as being cash register ‘the spot where payment is required. ’ Mens Rea – Dishonesty (Same as theft) -The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital. He claimed fees for operations he had not carried out. COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? Objective †¢ Did the defendant realise that what he was doing was dishonest by those standards? SubjectiveHere the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. Knowledge that payment on the spot is required. It must be established that the defendant knew payment was required or expected of hi m. Examples are restaurants where bill paid before leaving. Intention to avoid payment ‘with intent to avoid payment for the amount due ‘Allen (1985)’ HOL stated there must be an intent permanently to avoid payment. D left hotel without payment of ? 1,286, leaving behind his belongings. He phoned later to say he would pay as soon as he received sufficient money and arranged to collect his belongings and leave his passport as security.Basic criminal damage is set out in S1 (1) of the criminal damage act 1971 where it provides that ‘A person who without lawful excuse destroys or damages any property belonging to another intending to destroy or damage any such property or being reckless as to whether any such property would be destroyed or damaged shall be guilty of an offence. ’ Actus Reus – This phrase is not defined in the act, however old cases have stated that slight damage was sufficient to prove damage. ‘Gayford v Chouler’- Tra mpling down grass, no longer binding but a persuasive precedent. ? ‘Roe v Kingerlee’ – Smearing excrement on walls of a police cell; it cost ? 6 to clean up. ‘Matter of fact and degree,’ damage even if not permanent. ‘Hardman’ – Painting on pavements, removed with jets. None permanent ? ‘Blake v DPP’ – Biblical quotation on a concrete pillar, cost to clean, so held as damage ? ‘Samuel v Stubbs’ – Denting a policeman’s hat, causing a â€Å"temporary functional derangement† ? ‘A v R’ – D spat on policeman shirt, minimal effort to remove, therefore no damage. ? ‘Morphitis v Solmon’ – Scratch on scaffolding pole, doesn’t affect its usefulness or integrity. Defined in S10 (1) of criminal damage act 1971, ‘property’ means pr of a tangible nature, whether real or personal, including money and land; tamed wild creatures (or th eir carcasses); but not including wild mushrooms, fruit or foliage. Not intangibleBelonging to another is defined in S10 (2), provides that property belongs to any person having: custody or control of it; any proprietary right or interest; or a charge on it. Cannot be guilty of damaging or destroying own property. ? ‘Smith 1974’, D removed some electrical wiring . Not guilty, lacked mens rea. Mens Reus – ‘Pembliton (1874) – D threw stone at men who were fighting, missed and broke window. No intention even if he had intent to throw stone. No charge. – ‘Smith 1974’, Believed he was damaging own property. ‘Honest belief, negatives the mens rea. ’ ‘Stephenson (1979) D was tramp sheltering in a hay stack, lit a fire †¦ costs in damages.Would have been guilty if he was not schizophrenic, he didn’t realise the risk. Caldwell (1981), the HOL changed the law. Reckless – created an obvious risk to prope rty†¦.. It was used up to 2003. Gemmell and Richards reinstated the subjected test for recklessness. The two young defendants went camping without their parents' permission. During the night they entered the back yard of a shop and set fire to some bundles of they found and threw some it under a large plastic wheelie-bin and left. The fire spread and caused approximately ? 1m worth of damage. The defendants stated they thought it would extinguish itself because of the concrete, could not be charged as they didn’t realise the risk. 5 (2) (a) – D believed that the owner had consented or would have consented to destruction or damage. S5(2)(b) – D did it to protect some other property which he believed was in immediate need of protection and the means of protection were reasonable having regard to all the circumstances. (a) ‘Denton’, Thought employer had encouraged him to set fire to mill to make insurance claim. (B)’Hunt’ helped wife in duty as deputy warden in block of flats. Set fire to bedding to show alarms didn’t work. Conviction upheld as not for protection. (b)Conviction upheld – Baker and Williams, only for immediate danger. (Endangering Life) Aggravated criminal Damage is under S1 (2) of Criminal damage act (1971). A person who without lawful excuse destroys or damages any property, whether belonging to himself or another – (a) intending to destroy or damage any property or being reckless as to whether any property would be destroyed or damaged; and (b) intending by the destruction or damage to endanger the life of another or being reckless as to whether the life of another would be thereby endangered; shall be guilty of an offence. ’. Much more serious than basic, carries life sentence. The danger must come from the destruction/damage. ’ Steer (1987) – D fired 3 shots at the window of ex business partner, causing damage. Not guilty danger from shots. ‘We bster – D pushed large stone from bridge on to train, caused damage & showered passengers with debris, based on Recklessness. ‘Warwick’ – D rammed s police car and threw brick at it, causing damage and showered the officer with broken glass.Aggravated criminal damage the life doesn’t have to be endangered. ‘Sangha’ D set fire to mattress & 2 chairs in neighbours flat, however flat was empty and no one was at risk. Realised risk he would be guilty even if no actual risk. ‘Merrick’ – Employed to removed cables, life live wire out for 6 minutes, no one was hurt, but charged, if it was owner he would also be guilty. Mens Rea Intention or Recklessness as to destroying or damaging any property; and Intention or reckless as to whether the life is endangered by the destruction or damage. (Same meaning as basic offence). The prosecution must prove that the defendant was both aware of risk and danger.R( Stephen Malcolm) d was 15 years old, with friends thrown milk bottles filled with petrol at the outside of neighbour flat. This caused sheets of flame across window, thus endangering the lives of occupants, guilty. Arson – Under s1 (3) of the criminal damage act 1971, ‘an offence committed under this section by destroying or damaging property by fire shall be charged as arson. ’ the maximum penalty if life imprisonment. The basic offence of criminal damage must contain destruction through fire, thus the rest is the same. Aggravated Arson – Prosecution must prove that the defendant intended or was reckless as to whether life was endangered by the damage or destruction by fire. ‘Miller’ HOL held that arson can be committed through omission.

Tuesday, October 22, 2019

Hephaestus, the Greek God of Fire and Volcanoes

Hephaestus, the Greek God of Fire and Volcanoes Hephaestus is the name of the Greek god of volcanoes and a craftsman and blacksmith associated with metalworking and stone masonry. Of all the gods on Olympus, he is arguably the most human, having suffered abuse by the other gods, who by contrast are aloof, perfect, and remote from the frailties of men. Hephaestus is also connected to humanity by his chosen profession, sculptor, and blacksmith. Yet he is one of the children of the marriage of the powerful gods Zeus and Hera, also the most quarrelsome couple in the Olympian heaven. Some of the legends around Hephaestus suggest he was parthenogenic, the son of only Hera unaided by Zeus, an event caused by Hera in anger after Zeus produced Athena without the benefit of a female partner. Hephaestus is the god of fire, and the Roman version of Hephaestus is represented as Vulcan. Hephaestus Two Falls Hephaestus suffered two falls from Mount Olympus, both humiliating and painful- gods arent supposed to feel pain. The first was when Zeus and Hera were in the midst of one of their endless quarrels. Hephaestus took his mothers part, and in anger, Zeus threw Hephaestus off Mount Olympus. The fall took an entire day and when it ended in Lemnos, Hephaestus was nearly dead, his face and body permanently deformed. There he was tended by Lemnos human inhabitants; and when he finally as a wine steward to the Olympians, he was a figure of ridicule, particularly in comparison to the legendarily handsome wine steward Ganymede. The second fall from Olympus occurred when Hephaestus was still scarred by the first fall, and perhaps more humiliating, this one was caused by his mother. The legends say that Hera could not bear the sight of him and his deformed legs, and she wanted this reminder of a failed quarrel with Zeus to disappear, so she threw him off Mount Olympus once more. He stayed with the Neriads on earth for nine years, tended by Thetis and Eurynome. One myth reports that he only returned to Olympus by crafting a beautiful throne for his mother with a secret mechanism trapping her in it. Only Hephaestos could release her, but he refused to do so until he is made drunk enough to return to Olympus and set her free. Hephaestus and Thetis Hephaestus and Thetis Hephaestus is often associated with Thetis, another deity with human traits. Thetis was the mother of the doomed warrior Achilles, and she went to extraordinary lengths in numerous efforts to protect him from his foretold fate. Thetis tended Hephaestus after his first fall and later asked him to forge new weapons for her son. Thetis, the divine parent, begs Hephastus to craft a beuatiful shield for her son Achilles, a shield predestined to bring its bearer death. It was the last futile effort of Thetis; soon Achilles died. Hephaestus is said to have lusted after Athena, another crafts person; and in some versions of Mount Olympus, he was the husband of Aphrodite. Sources ​ Rinon Y. 2006. Tragic Hephaestus: The Humanized God in the Iliad and the Odyssey. Phoenix 60(1/2):1-20.

Monday, October 21, 2019

reform of the voting system essays

reform of the voting system essays There are 659 MPs who are members of the House of Commons. In order to have a majority and form a workable Government, a political party needs 330 MPs. Currently, the composition of the Commons is: Social Democratic Ulster Democratic Unionist Party 5 (Stands as "Speaker seeking re-election") 1 In practice, you can see that because there are quite a few smaller parties, it would be possible to form a strong government with fewer than 330 MPs; however, such a government would also be vulnerable if all the opposing MPs voted against it. MPs each represent a constituency, a local area, such as Loughborough, Charnwood, Hertlepool, North Norfolk, Leicester South. Roughly speaking, the same number of people live in each constituency. At the 2001 General Election, the Isle of Wight had the largest number of electors - over 104,000. The smallest number of electors - some 21,900 - was to be found in the Western Isles. The constituency of Ross, Skye and Inverness West was the largest by area at 918,319 hectares. The smallest by area was Islington North at 727 hectares. At an election voters place one vote in their home constituency for the candidate they choose such as, Labour, Conservative, Liberal Democrat, Monster Raving Loony Party, Independent etc. The candidate with the most votes is elected to serve as an MP until the next election. In most cases the turnout (those who vote) is around 60%. The party with the most MPs across the whole country forms the Government. However, in some constituencies one party has such a high level of support that the other parties have little chance of winning. For ...

Sunday, October 20, 2019

45 Synonyms for Road

45 Synonyms for Road 45 Synonyms for â€Å"Road† 45 Synonyms for â€Å"Road† By Mark Nichol This post lists synonyms for road and specific terms for various types of roads. It excludes words primarily of use in British English or in other languages, as well as other senses of the terms. 1. alley: a narrow street, especially one providing access to the rear of buildings or lots between blocks 2. alleyway: see alley 3. arterial: a through street or highway 4. artery: a major road 5. avenue: a road or street 6. backstreet: a street set off from a main street 7. beltway: a highway passing around an urban area 8. boulevard: a wide road, often divided and/or landscaped 9. branch: a side road 10. bypass: a road passing around a town 11. bystreet: see backstreet 12. byway: see backstreet 13. causeway: a highway, especially one raised across water or wet ground 14. circle: a curving street, especially one intersecting at both ends on another street 15. close: a road closed at one end 16. corniche: a coastal road, especially alongside a cliff face 17. corridor: a local or regional route in the Appalachian region of the United States 18. crossroad: a road that crosses a main road or runs between main roads 19. court: a road closed at one end, especially with a circular end 20. cul-de-sac: see court 21. dead end: a road closed at one end 22. drag: slang pertaining to a road often traveled on as a leisurely pastime (or, as â€Å"main drag,† slang referring to the principal road, or one of the principal roads, in a city or town) 23. drive: a public road 24. expressway: a high-speed divided highway with partially or fully controlled access 25. freeway: an expressway with fully controlled access 26. highway: a main road 27. interstate: an expressway that traverses more than one state 28. lane: a road, often narrow (also refers to the portion of a road set apart for a single line of vehicles) 29. Main Street: the principal street of a town 30. parkway: a landscaped road 31. pike: see turnpike 32. place: a short street 33. route: see highway 34. row: a designation sometimes given to roads in place of road, drive, etc. 35. secondary road: a road subordinate to a main road 36. shunpike: a side road used to avoid a main road or a toll road 37. side road: a road that intersects with a main road 38. side street: see â€Å"side road† 39. street: a road within a city or town 40. superhighway: an expressway for high-speed traffic 41. thoroughfare: a main road, or a road that intersects with more than one other road 42. through street: see thoroughfare 43. throughway: see expressway 44. turnpike: a main road, especially one on which tolls are or were collected 45. way: a designation sometimes given to roads in place of road, drive, etc. Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Vocabulary category, check our popular posts, or choose a related post below:When to use "on" and when to use "in"Yay, Hooray, Woo-hoo and Other AcclamationsLetter Writing 101

Saturday, October 19, 2019

Case study Assignment Example | Topics and Well Written Essays - 250 words - 15

Case study - Assignment Example Some basic product lines sold by TerraCycle include picture frames and line of clocks. Material which is conventionally considered non-recyclable like vinyl records is used to introduce new products. Bags also form an important product line which is pretty long. Bike pouches made from energy bar wrappers form an important constituent of this line. At this stage of the company’s growth, product line extension would make more sense for TerraCycle to stay ahead of the game and gain a competitive edge over rival organic manufacturers. The current products are topnotch and very reliable, but more variety is needed to fuel the business and address needs of a diverse line of customers. It should be remembered that the present day business environment is fiercely competitive. How well do TerraCycle’s bottles perform the four packaging functions discussed in this chapter? Compare TerraCycle’s products to Miracle-Gro’s (www.scotts.com). Do you think TerraCycle’s package design distinguishes their products well enough from those of the industry giant, or are they similar enough to cause customer confusion? TerraCycle does not distinguish its products well enough from those of the industry giant, the Scotts. This is why the Scotts had to sue TerraCycle for copying their labels and advertisement techniques. TerraCycle finally reached a settlement with its rival company and agreed to modify its packaging. Though the package design is not similar enough to cause customer confusion, it nevertheless hurts the

Friday, October 18, 2019

GUNNS AND THE AUSTRALIAN PULP AND PAPER MANUFACTURING INDUSTRY Research

GUNNS AND THE AUSTRALIAN PULP AND MANUFACTURING INDUSTRY - Research Paper Example This study highlights the strategic problems of the company and suggests measures that can be taken up by the company to ensure its sustainable growth in future. The external environment of the company has been analysed using PESTEL analysis and the various competitive factors affecting the company have been identified utilising the Porter’s five forces model analysis concerning the global paper industry. The strict environmental regulations and the strong supplier power in the paper industry are identified to be having a significant impact on the company. The internal environment of the company has also been analysed utilising SWOT analysis as the strategic tool. The core competencies of the company have been identified to be its diversified products portfolio and it is trying to attain competitive advantage in the market through the strengthening of its core competencies. The financial analysis of the company shows that indebtedness is a major problem of the company and it i s facing difficulty to source its fund for future investments. Based on the in-depth analysis of the company and its environmental conditions the best strategic alternative for the company has been identified to restructure its business model, focusing more on plantation based business and accepting the proposed investment proposal related to Bell Bay pulpwood mill. 2. External Environmental Analysis Gunns Ltd. is engaged in the business activities related to forest management, processing, milling, exportation and merchandising of wood products (Bloomberg, 2012). The company operates its business in the global paper industry and the external environmental analysis of the company has been done in this study utilising various strategic tools like PESTEL analysis and Porter's Five Forces Model. 2.1 PESTEL Analysis PESTLE stands for Political, Economical, Social, Technological, Legal and Environmental factors. It is an external environmental analysis tool which helps the organisations t o determine the external trends (Knowhownonprofit, n.d.). Hence Gunns Ltd. which is an Australian company, the country’s business environment can be better understood through the PESTEL analysis presented below: (Source: Businessmate, n.d.). a. Political: Different types of social welfare policies have been undertaken by the Australian government in the recent years like lending support to the aging people and the introduction of the scheme of paid parental leave. Apart from this the carbon tax was enacted by the Australian government recently but had to face protest from different industrial sectors of the country (BBC News Asia, 2012). b. Economical: There has been a steady growth of the Australian economy in the past 10 years. It is likely that the economy would continue to be strong paving way to further industrial growth and development in the nation. On the other and the indebtedness of Australia has increased which is evident from the rise of external debt as a percent age of GDP. At the end of the year 2011, Australia's debt from foreign countries grew to around 94.58% of GDP (Marketline, 2012). c. Social: In accordance with Central Intelligence (CIA) World Factbook the Gini coefficient of Australia ranges from 0 to 100, i.e. from perfect equality to inequality were 30.5 in 2006. The aging population of the country is also on

Network Topology Assignment Example | Topics and Well Written Essays - 750 words

Network Topology - Assignment Example OSPF and EIGRP and RIP routers functions as the interface between the laboratory fund raising and biology laboratory (Shoniregun, 2007). File servers will be storing the files of volunteer’s data, which include network-attached storeroom. The figure indicates an outline of the internetwork routing system. RIP network EIGRP-Network Router-EIGRP Router OSPF Router RIP Router-EIGRP, RIP and performs route redeployment amid the EIGRP and RIP networks. Similarly, router OSPF, RIP redistributes routes amid biology lab and fundraising office (Shoniregun, 2007).    The tangential router of Fund raising and research lab requires redistribution amid EIGRP and OSPF. 2. What information will you redistribute between routing protocols? When we have a network where multiple routing protocols are present, we    go through a process of route redistribution. The diverse segments of network erudite routes based on the protocol that is configured on them (Shoniregun, 2007). Route redistribut ion aids in the spread this knowledge in an understandable manner, by other segments. The roue leaned by EIGRP to RIP should be redistributed in a way that it is explicit by RIP and vice versa. Default-metric or definition of a metric is applied for specific posting. 3. Identify the problems you expect to encounter (with different metrics, security, etc.) when you redistribute. Essentially, efficiency is fundamental in any network. Single metrics pose a challenge in the attainment of optimal performance. Multiple metrics should be integrated into the internet protocol system to ensure, apt internet performance. On the other hand, the concept of security is primarily connected to the exigency of protecting sensitive data from unauthorized access (Shoniregun, 2007). It is notable that, significant security issues arise during the designation of an internet protocol due to minimal or non-existent of authentication mechanisms In addition, the ad hoc routing protocols used in designing i nternet protocols systems are susceptible to security issues due to lack of security design features (Shoniregun, 2007). This renders the protocols vulnerable for attacking. It is noteworthy that, poor security measures during internet designing may lead to an inefficient network, for instances, chances of wrong messaging and redirection to unintended nodes is likely to occur. 4. Explain how you will overcome the problems. This concept of network protocol security is significant for any network to perform. The ever-changing technological trends in commercial applications have complicated the approach of solving protocol security issues (Shoniregun, 2007). It is imperative to note that quality of service (QoS) in the internet has emerged as a cornerstone for numerous network services (Shoniregun, 2007). The data origin authentication and data veracity for IP, control, and routing protocols remains paramount in ensuring a secure and efficient network. The language used in designing an internet protocol has remained a key challenge in ensuring internet protocol security (Shoniregun, 2007). The security issues can be easily avoided by ensuring high standards of authentication of identity of IP and routing protocols. More over, the language used should be apt in integrating with the internet protocol specifications and the with the authorization policy. To solve problems arising from metrics, the designer should ensure usage of fixed metrics. This is because, the

Impact of engineering on natural and social environment Essay

Impact of engineering on natural and social environment - Essay Example This paper discusses some of these issues and focuses on the implications for natural and social environment. Technological growth has given rise to huge cities and many people from villages are moving towards cities looking for new opportunities. In earlier day’s people in the villages were comparatively more self-sufficient than when they reached the cities. For instance, farmers grew the necessary food for their family and the remaining was sold. Today, the agricultural technologies have entered the fields and have made this an expensive affair. Farmers are forced to buy seeds especially the genetically modified seeds [1], pesticides, synthetic fertilizers and machines. Besides, the land, water and atmosphere are contaminated with the over-use of chemical pesticides. In other words, these technological revolutions in the field of agriculture have made it an economical burden for the farmers and are becoming more and more unsustainable. The technological development has incr eased the gap between the rich and the poor. The benefit of technology is only for the rich people in the society [1]. Genetic engineering is another field that has resulted in serious changes in the natural environment. Genetic modification of plants and animals has raised several ethical questions. For instance, the use of transgenic flora for the preparation of vaccines is a recent research.

Thursday, October 17, 2019

Article summary Example | Topics and Well Written Essays - 750 words

Summary - Article Example finally that CBPR would seek balance between community members and researchers/practitioners through shared co-teaching, leadership, co-learning opportunities and therefore benefit from the expertise of both community practitioners and researchers. Participatory action research was suitable for this patient population because this kind of research is especially appropriate for public health nurses working with populations and communities since it offers a framework that builds upon local community knowledge, enabling the public health nurses as well as their community partners to be sensitive not only to the culture but also ecological context. Secondly participatory action research also serves as a useful guide in development of programs suitable for promoting healthy communities and health equality. Thirdly, this kind of research also allows socio-cultural contexts, systems, and meaning to emerge through a collaborative process between community members and public health nurses. Fourthly, early research in substance use provided a firm foundation for community participation .Participation action research is also very important in the acquisition of local community’s knowledge of substance nonuse and use so as to provide a richer understanding of the health-related needs and assets of the community, environment and circumstances surrounding substance-related illness and health, population and community conditions, beliefs, attitudes as well as traditions directed toward substance nonuse or use-related health risk behaviors. Some of the unique benefits of this study revolve around the unique strategies utilized in the community participation such as mapping (Geographic Information Systems) (GIS), and Photovoice (picture-taking by members of the community as well as researchers and practitioners).GIS as a tool enables assessment and analysis of the ecological context of a population together with phenomena such as youth substance nonuse and use within a

Homosexuality in Britain Essay Example | Topics and Well Written Essays - 500 words

Homosexuality in Britain - Essay Example According to the article, the orientation for preference to same sex relations remain covert as it was categorized as criminal in nature to expose homosexual acts, in private or in public, even by consenting adults prior to 1969. There was no organization in England promoting for any homosexual reform that it waited for American ideals of homosexual liberation to emerge. Despite the British laws prevailing to be predominantly homophobic, homosexual content in English literature still remained sporadic, depending on the creativity and restraint of the writer. British literature had patiently waited for fourteen years since the Wolfenden Report of 1953 recommending that homosexual behavior between consenting adults in private no longer be criminalized in England, before they can freely express homosexual content in their literary works. It is my personal contention that the issue of homosexuality remains to be controversial in other parts of the world until contemporary times. What American culture had promoted in terms of liberalizing homosexual behavior was readily accepted in other Western civilizations. Some Eastern culture remains to be still conservative in openly accepting homosexual acts given the cultural values and beliefs, especially pinning on religious orientations. In literature, however, I support freedom of creative expression including the writing of homosexual content conforming to ethical frameworks. Wanton disregard for the readers’ morals would render their literary work utterly improvident. I share Jeremy Bentham’s belief that in writing about homosexuality, one must weigh â€Å"the pleasure of consensual homosexual relations against the pain or harm it causes the general public†¦ by causing no harm to others, homosexuality is justified by the pleasures of those who practice it.† (glbtq, 2002,

Wednesday, October 16, 2019

Impact of engineering on natural and social environment Essay

Impact of engineering on natural and social environment - Essay Example This paper discusses some of these issues and focuses on the implications for natural and social environment. Technological growth has given rise to huge cities and many people from villages are moving towards cities looking for new opportunities. In earlier day’s people in the villages were comparatively more self-sufficient than when they reached the cities. For instance, farmers grew the necessary food for their family and the remaining was sold. Today, the agricultural technologies have entered the fields and have made this an expensive affair. Farmers are forced to buy seeds especially the genetically modified seeds [1], pesticides, synthetic fertilizers and machines. Besides, the land, water and atmosphere are contaminated with the over-use of chemical pesticides. In other words, these technological revolutions in the field of agriculture have made it an economical burden for the farmers and are becoming more and more unsustainable. The technological development has incr eased the gap between the rich and the poor. The benefit of technology is only for the rich people in the society [1]. Genetic engineering is another field that has resulted in serious changes in the natural environment. Genetic modification of plants and animals has raised several ethical questions. For instance, the use of transgenic flora for the preparation of vaccines is a recent research.

Tuesday, October 15, 2019

Homosexuality in Britain Essay Example | Topics and Well Written Essays - 500 words

Homosexuality in Britain - Essay Example According to the article, the orientation for preference to same sex relations remain covert as it was categorized as criminal in nature to expose homosexual acts, in private or in public, even by consenting adults prior to 1969. There was no organization in England promoting for any homosexual reform that it waited for American ideals of homosexual liberation to emerge. Despite the British laws prevailing to be predominantly homophobic, homosexual content in English literature still remained sporadic, depending on the creativity and restraint of the writer. British literature had patiently waited for fourteen years since the Wolfenden Report of 1953 recommending that homosexual behavior between consenting adults in private no longer be criminalized in England, before they can freely express homosexual content in their literary works. It is my personal contention that the issue of homosexuality remains to be controversial in other parts of the world until contemporary times. What American culture had promoted in terms of liberalizing homosexual behavior was readily accepted in other Western civilizations. Some Eastern culture remains to be still conservative in openly accepting homosexual acts given the cultural values and beliefs, especially pinning on religious orientations. In literature, however, I support freedom of creative expression including the writing of homosexual content conforming to ethical frameworks. Wanton disregard for the readers’ morals would render their literary work utterly improvident. I share Jeremy Bentham’s belief that in writing about homosexuality, one must weigh â€Å"the pleasure of consensual homosexual relations against the pain or harm it causes the general public†¦ by causing no harm to others, homosexuality is justified by the pleasures of those who practice it.† (glbtq, 2002,

Medea Greek Mythology Essay Example for Free

Medea Greek Mythology Essay When Medea decides to take matters in to her own hands, about punishing the people who have done wrong to her, she is accused of wanting not justice—vengeance. Because I am not a native of neither Corinth nor Colchis, I have my own view about her motives. However, I would agree with the Corinthian Women, Medea is seeking vengeance; not justice. Some people might argue that Medea is seeking justice. When in actuality, Medea wants vengeance. The opposition would say justice took place because the Gods allowed Medea the time to perform her various acts. Although these things happened Medea turned to vengeance when she took it upon herself to kill Creon and his daughter Creusa. Even the chorus, the â€Å"ideal spectators†, implies that Creon is a poor king when, after he banishes Medea, the First Corinthian Woman sympathizes, â€Å"I am of Corinth and I say that Corinth is not well ruled. †(1. 214-216). This quote gives us proof that Medea has some sort of reason to seek revenge on Creon. However she lets her hatred exceed its boundaries and allows herself to take the lives of the King of Corinth and its Princess all because they chose Jason over her. In addition, her actions all prove that she wants Jason to do more than pay for hurting her. She wants him to suffer at the fate of her own children. Her revenge was selfish. Medea involved the two things she knew would hurt Jason the most—her own children. According to the First Corinthian Woman, â€Å"It would be better for you, Medea if the earth opened her jaws and took you down into darkness. But one thing you will not do, for you cannot, you will not hurt your own children, though wrath like plague-boils aches, your mind in a fire-haze bites the purple apples of pain. No blood-lapping beast of the field, she-bear nor lioness, nor the lean wolf-bitch, hurts her own tender whelps; nor the yellow-eyed, seythe-beaked, and storm shouldered eagle that tears the lambs has ever made prey of the fruit of her own tree. †(2. 115-126). Keep in mind that the Corinthian Women are the conscious of Corinth. Through this quote the First Corinthian Women has stated that Medea could not harm her own children. She even gives examples of the most dangerous predators that don’t even harm their own young. This is evidence that Medea went beyond the state of justice; but she went well into the state of vengeance. Medea knew what she was doing and quite frankly she could care less about anything other than what she thought of what was seeking revenge on Jason. In conclusion, vengeance was sought by Medea. She went above the fact of teaching Jason a lesson; she even stated she hated Jason more than she loved her children. Answer this question is what Medea has done entertaining or morally instructive?

Monday, October 14, 2019

Importance of Financial Management

Importance of Financial Management INTRODUCTION The modern thinking in financial management accords a far greater importances to the management decisions and making policy. Today financial managers occupy key positions in top management areas and play dynamic role in solving complex management problems. The main object ive of accounting is to provide the necessary information, which is useful for the person within the organization i.e.; owners, management, employees and also outside the organization i.e.; investors, creditors, government, consumers, etc. Financial accounting is concerned with record keeping directed towards the preparation of income statement and financial position statement. It provides information regarding profit and loss of the enterprise and also its financial position as on that particular date. This information is helpful to management to control the major functions of the business i.e.; finance, administration, production and marketing, but details regarding operating efficiency to their lacking financial statements are mainly concerned with the managements interest in future of the organization. Thus the financial performance valuation involves the determination of the companys ability In mobilizing the funds required for the business and utilizing the funds in the business. Therefore, the financial performance is concerned with the appraisal of the following: Capital formation Capital structure Profitability and profit allocation Working capital and liquidity management FINANCIAL ANALYS Financial analysis is the process of determining the significant operating and financial characteristics of a firm from its accounting and its financial statements. The goal of such analysis is to determine the efficiency and performance of the firms management, reflected in the financial records and reports. This analysis will help us to measure firms liquidity, profitability and other indications that determine whether the business is conducted in a rational way or not. METHODS OF FINANCIAL ANALYSIS: There are 7 methods of financial analysis. Such are: Comparative statement Comparative income statement Comparative balance sheet Common-size statement Trend analysis Fund-flow analysis Cash-flow analysis Ratio analysis Cost-volume profit analysis RATIO ANALYSIS: Financial statement plays a decisive role in setting the frame work of managerial decisions for the financial statements viz; income statement and balance statement are prepared to help the management in taking decisions. The Ratio analysis is the most power tool of financial analysis. Meaning: A ratio is simple arithmetical expression of the relationship of one member to another. Accounting ratios are relationships expressed in mathematical terms between figures which are connected with each other in some manner. Ratio analysis shows inter-relationship between the different items in the data. Current ratio: Current ratio = Current assets / Current liabilities The current ratio is calculated by dividing the current assets by the current liabilities. Current assets include cash and those assets which can be converted into cash within year such as inventories, sundry debtors, marketable securities, loans and advances and prepaid expenses. Current liabilities are obligations maturing within a year, including creditors, bills payable, accrued expenses, bank overdraft, income tax liability, loans and advances and provisions. The companys liquidity position was very low in the initial years where as it is very high in the later years. Quick (or) Acid test ratio: Quick ratio = (Current assets Inventory) / Current liabilities The ratio is really at the rate of current ratio and is found out by dividing the total current liabilities. From the analysis, it can be interpreted that the companys liquidity position to pay for current liability is high. This result is higher interest cost on networking capital which affects the profitability of the firm. Debtors days: Debtors days = (Debtors / sales) * 365 The liquidity position of the firm depends on the quality of the debtors to the great extent. This resulted in higher balance in debtors for which company had to pay more interest charges which affected profitability of the company. This can be improved 3 times better as observed in the ratios of well doing firms. This will result in big reduction in interest charges as well as increase in profits. This possible only through better debtors management and optimum credit policy of the firm. Creditor days: Creditor days = (Creditor / Cost of goods sold ) * 365 This ratio is a variation of the credit ratio and gives similar indications. It measures the portion of the firms assets that are financed by creditors. A very high ratio indicates a greater risk to creditors as also to the share holders under adverse business conditions. On the other hand , a low ratio is for the creditors in extending credit. Net income ratio: Net income ratio = (Net profit / sales) *100 This ratio measures the rate of the net profit earned on sales. It establishes a relationship between net profit and sales in overall measure of the firms ability to turn pound of sales into net profit, this ratio also indicate the firms capacity to withstand adverse economic conditions. Gross income ratio: Gross income ratio = (Gross profit / Sales) *100 The gross profit has been arrived by adding the closing stock and subtracting the materials, excise duty, wages and other manufacturing expenses to sales. This ratio reflects the efficiency with which management produces each unit of the product. When the gross margin in subtracted from 100% we get the ratio of cost of goods to sale. Return on equity: Return on equity = Net income / Share holders equity The amount of net incomereturnedas a percentageof shareholders equity.Return on equitymeasures a corporations profitabilityby revealing how muchprofit acompany generateswith the money shareholders have invested. Net income is for the full fiscal year (before dividends paid to common stock holders but after dividends to preferred stock.) Shareholders equity does not include preferredshares. Cost of sales to sales ratio: Cost of sales to sales ratio = Cost of sales / Total sales Through the manufacturing expenses percentage of company is less than the industry average the Cost of sales is slightly more than the industry. This can be, because of more depreciation charges or difference in excise duty. Therefore company has to produce goods by effective utilization of foxed assets to bring down the depreciation cost of sales. Stock turnover days: Stock turnover days = sales / inventory The higher the stock turnover the better, because money is then tied up for less time in stocks. A quicker stock turnover also means that the firm gets to make its profit on the stock quicker, and so the firm should be more competitive. However, it will vary between industries and so it is important to compare within an industry. Return on net assets: RONA = net income / (Fixed assets + Networking capital) Here, Networking capital = Current assets Current liabilities. It is the useful measure the profitability of all financial resources invested in the firms assets. It evaluated the use of total funds without any regard to the sources of funds. Higher the ratio more effective is the firm is using the pool of funds. Sales to net assets employed: Sales to net assets employed = sales / net assets Here, Net assets = Fixed assets + Current assets Current liabilities. This ratio is also called the earning power of the firm and represents the return of the funds. It indicates how well management has used funds supplied by the creditors and owners. Higher the ratio better is the position of the firm and more efficient of the management in utilizing funds, entrusted to it. CONCLUSIONS In the overall of a business is to earn a satisfactory return on funds invested in it, consistent with maintaining a sound financial position. The position of the company according to ratio is satisfactory in the year 2008 2010. That means each year profit had been increased. BIBLIOGRAPHY Financial management M Y Khan P K Jain http://www.investopedia.com