A Critical Analysis of Accomplice Witness in India Essay Example

A Critical Analysis of Accomplice Witness in India Essay A Critical Analysis Of Accomplice Witness In India A predicament has remained to exist as to whether a court deciding on the fate of an accused should consider the testimony of a friend in crime. The courts have struggled long to settle down on a practical and prudent solution so that the guilty does not go unpunished and the innocent stays unscathed. It is from this prospective that the courts have made an unceaseth attempt through hoard of judicial decisions to come up with a rule of prudence read into the law of evidence to guide the minds whenever an accomplice renders an account of the crime committed. The writing is an attempt to critically analyze the need for receiving accomplice evidence and the approach of caution adopted in such instances. It aims at simplifying the law with regards to accomplices and approaches it from a practical point of view. It makes an effort to endorse the idea that the flexibility engrained should be retained and the law on the point in India should be modified to suit the need of the hour which is indefinitely the speedy disposal of cases so that justice is rendered for justice delayed is justice denied. WHO IS AN ACCOMPLICE? The Indian Evidence Act, 1872 does not lay down the definition of. An accomplice is a person who has concurred in the commission of an offence 1-2 and the maxim â€Å"participes criminis†3 is included in the term. An accomplice is a person who is guilty-associate in crime or who sustains such a relation to the criminal act that he can be jointly indicted with the principal criminal. A witness concerned may not confess to his participation in a crime and may deny his being an accomplice but it is for the courts to decide on a consideration of the entire evidence whether he is an accomplice. 5 The burden of proving that an accomplice is definitely on the party alleging it for the purpose of invoking the rule while the duty to bring the accomplice character of the evidence to the notice of the court rests upon the prosecution and the court needs to believe by a preponderance of probabilities. We will write a custom essay sample on A Critical Analysis of Accomplice Witness in India specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on A Critical Analysis of Accomplice Witness in India specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on A Critical Analysis of Accomplice Witness in India specifically for you FOR ONLY $16.38 $13.9/page Hire Writer The essential prerequisite is participation in crime willfully and this can be done in various ways7. The term in fullness includes all persons concerned in the commission of the crime, whether they in the strict legal aptness are principals in the first degree8 or second degree9 or merely are accessories before10 or after11 the commission. 12. In India two categories of offenders are recognized- persons who are principals and abettors or instigators and the term accomplice includes both of them i. e. the principal and the privy. 3 The three conditions that need to merge are 1) the felony must be complete 2) the accessory must have the knowledge that the felony has been committed 3) the accessory must harbour or assist the principal. 14 WHEN IS AN ACCOMPLICE COMPETENT WITNESS? Section 118 of the Indian Evidence Act speaks about competency of witness. Competency is a condition precedent for examining a person as witness and the sole test of competency laid down is that the witness should not be prevented from understanding the questions posed to him or from giving rational answers expected out of him by his age, his mental and physical state or disease. 5 At the same time Section 133 speaks about competency of accomplices. Further more in case of accomplice witnesses, he should not be a co-accused under trial in the same case and may be examined on oath. 16 Let us consider the following propositions suggested by courts. First, courts have opined that such competency, which has been conferred on him by a process of law, does not divest him of the character of an accused and he remains a participes criminis17 and this remains the genesis of the major problem surrounding the credibility of such evidence. Secondly, an accomplice by accepting a pardon under Section 306 CrPC becomes a competent witness and may as any other witness be examined on oath, the prosecution must be withdrawn and the accused formally discharged under Section 321 of the Criminal Code before he would be a competent witness18 but even if there is omission to record discharge, an accused is vested with competency as soon as the prosecution is withdrawn. 19 Thirdly, Article 20(3) of the Indian Constitution says that no accused shall be compelled to be a witness against himself. But as a co-accused accepts a pardon of his free will on condition of a true disclosure, in his own interest, and is not compelled to give self-incriminating evidence, the law in Section 306 and 308 of CrPC is not affected and a pardoned accused is bound to make a full disclosure and on his failure to do so he may be tried of the offence originally charged and his statement may be used against him under Section 308. 20 This suggests that a participes criminis continues to be the same and if so then despite the fact that his involvement has been pardoned by a judicial act can be sed for self-incrimination and to expect a â€Å"true and full disclosure† is unreal. SECTION 114 VIS-A-VIS SECTION 133: At the outset, it has been proposed that incorporation of Section 133 when read in the light of Section 118 speaking about the competency of witness does not justify the inclusion of the former in the Act. Further Section 134 which deals with the number of witnesses in a case negates the second part of Section 133 which narrates that the uncorroborated testimony of an accomplice is not illegal. But the inclusion of the section attains a highly elevated status, for without inclusion of this specific section, there existed a dominant chance of the law being misunderstood or misapplied. Section 114, illustration (b) creates a cloud of doubt as to the competency of the accomplice witness and it seems significant when seen from this perspective that inclusion of Section 133 was required to settle a sound basis and caution that merely because the testimony of the accomplice is uncorroborated does not make it illegal. The difficulty in understanding the combined effect of the two sections proceeds largely on the account that their positioned under different Chapters in the Act. It clearly emerges that both- rule laid down in illustration (b) to Section 114 which deals with presumptions of various kinds and the caution laid down in Section 133 are part of the same rule and neither can be ignored in the exercise of judicial discretion, except in cases of a very exceptional nature. The application of the rules together emerges as a rule of practice that has assumed the force of rule of law21 that evidence of the accomplice would be accepted with corroboration. 22 Why this â€Å"practical rule† emerged? This rule is an outcome of experience that an accomplice is unworthy of credit23 for the following: 1. A bare and segregated perusal of Section 133 may instigate the young magistrates and judges at the lower courts to base their convictions on the uncorroborated testimony of accomplice witness on the presumption that the legislature intended to encourage such convictions and such testimonies. . This rule emerged in order to ration the threats that flow from necessity for administration of justice for an accomplice witnesses are a practical mandate as matter of necessity nevertheless they are infamous and the most dangerous forms of witnesses to base a conviction. 3. An accomplice is a ‘partner in guilt’ and is definitely an infamous witness and inevitably distrust flows into what he testifies calling for fullest corroboration in material particulars for a conviction. He may without this burden simply testify to save himself by procuring conviction for others. 4 Section 133 is the absolute rule of law as regards to the evidence of accomplices but this essentially has to be read with the rule of prudence laid down in illustration (b) of Section 114. Section 114 enacts a rule of presumption but this is not a hard and fast presumption that cannot be rebutted, a presumption puris et de jure and the right to raise this presumption as to an accomplice witness is sanctioned by the Act, and it would be an error of law to disregard it, what effect is to be given to it must be determined by the circumstances of each case. 5 It is thus well settled that except in circumstances entailing an exceptional nature, it is the duty of the court to r aise the presumption in section 114 illustration (b), and the legislature requires that the court should make the natural presumption in that section. 26 The result of the combined reading that is to be done to both the sections may be stated as follows: 1) the uncorroborated evidence of an accomplice is admissible. There can be a conviction upon the uncorroborated testimony of the accomplice if believed to be true and this is so especially where there is in question the evidence of a person who is not so much an accomplice as a victim27, 2) Although it is so, experience teaches that an accomplice being an infamous person , it is extremely unsafe to rely upon its testimony unless and until materially corroborated 3) It is the duty of the judge to be warned that it is dangerous to convict on the uncorroborated testimony of an accomplice and an omission to warn with prudence would be misdirection 4) and if a departure is made form thus virtual rule of law , then it has to be showed that the circumstances justify the exceptional treatment for the presumption of unworthiness is raised and corroboration is demanded for administration of justice. However, on a perusal of various judicial decisions it seems that the word of caution under Section 114, illustration (b) has a super imposing sweep over the clear wordings of Section 133 What is corroboration? Corroboration means independent testimony. Lord Abinger said- â€Å" In my opinion that corroboration ought to consist in some circumstance that affect the identity of the party accused. A man who has been guilty of a crime himself will always be able to relate the facts of the case, and if the confirmation be only truth of that history, without identifying the persons, that is really no corroboration at all. If a man were to break upon a house and put a knife to your throat, and steal your property, it would be no corroboration that he had stated the facts correctly, that he had described how the person did put the knife to the throat and steal the property. It would not at all tend to show that the party accused participated in it †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ The danger is that when a man is fixed, and knows that his guilt is detected, he will purchase immunity by falsely accusing others. 28 Independent corroboration does not mean that every detail must be corroborated by independent witnesses and all that is required is that there must be some additional evidence rendering it probable that the story of the accomplice is true. 29 That is to suggest that supposed in a case of conspiracy, if there is corroboration with regards to the general facts of the existence of a conspiracy and also of participation in it of any particular accused, corroboration of the specific acts is unnecessary unless the evidence of the accused is intrinsically subject to suspicion. 30Amount of corroboration cannot be laid down in specific as it depends upon the circumstances; particularly on the crime charged and the degree of the accomplice’s complicity. 31 THE GREY ZONES: THE PERSISTING PREDICAMENT: 1. The need for asking for corroboration is to bridge the gap between the crime and the criminal. The manner and extent of corroboration are however not clearly defined except the relief that it has to be substantial. 32 Some judges have deemed it sufficient, if the witness be confirmed in any material part of the case; others have been satisfied with confirmatory evidence as to corpus deliciti only; but others, with more reasons have thought it essential that corroborative proof should be given of the prisoner having actually participated in the offence: and, when several prisoners are tried, the confirmation should be required as to all of them before all can be safely convicted. 3 Regarding the kind of corroboration requires, the SC held that it would be impossible, indeed it would be dangerous, and to formulate the kind of evidence which should, or would, be regarded as corroboration and its nature and extent must necessarily vary with the circumstances of each case and also in accordance with the offences in question. 34 Often it has been seen that there arises problems when the offence in question is heinous like rape which is committed with accomplices in secret and there may not be any direct evidence for corroboration and resort is done to circumstantial evidence. 35 So the situation stands that there is no fixed standard of corroboration required. 2. The view that before reliance has to be placed on the evidence of an approver the approver must appear repentant is not legally correct. Whether his evidence is reliable or not would and should depend upon the usual tests such as probability of truth of what he said, whether he made a full and complete disclosure , whether his evidence is mere self exculpatory and whether his evidence has been corroborated in material particulars. 36 It is also suggested that apart from satisfying the test of corroboration the accomplice witness has to also fulfill the test of reliability. This does not imply that the evidence of the approver with the corroborating pieces should be treated in two separate compartments. 37 This suggests that the two tests are Siamese twins. But the SC in Swaran Singh v. State of Punjab38 held that since the two sets of statements made by the approver were wholly inconsistent and irreconcilable it lead to a conclusion that there was serious infirmity in the character of the approver and hence was not reliable. 39 In Narayan Chetanram Choudhury v. State of Maharashtra40, it was held that- â€Å"Only such omissions which amount to contradiction in material particulars can be used to discredit the testimony of the witness. The omission on in the police statement by itself would not necessarily render the testimony of the witness unreliable. When the version given by the witness in the Court is different in material particulars from that disclosed in his earlier statements, the case of the prosecution becomes doubtful and not otherwise. Minor contradictions are bound to appear in the statement of truthful witnesses as memory sometimes plays false and the sense of observation differs from person to person. The evidentiary value of the accomplice witness depends considerably upon the circumstances under which the evidence is tendered. 41 But the doubt persists that if the testimony of accomplice is reliable then what is the need for corroboration. What the court considers as reliable and whether the two tests are one and the same thing still needs judicial attention and scrutiny to simplify the law. 3. Courts have been critical about the character of an accomplice. In Indar v. R42, the court opined that the testimony of a man of the very low character who has thrown to the wolves his erstwhile associates and friends in order to save his own skin and who is a criminal and has purchased his liberty by betrayal must be received with great caution. Apart from corroboration, the evidence of the accomplice if at variance with the evidence of another witness on a material point, then it cannot be accepted. 43 Sometimes it is quite possible that the accomplice would have acted under pressure and such person though technically be turned as accomplice would not really evince suspicion in the mind of the judge as to his role. 44 It is the duty of the prosecution to bring forth the character of the accomplice evidence to the notice of the court and then to invite belief by reference to corroborative evidence and it cannot be urged in appeal that it was never suggested in the trial court that a witness was an accomplice, the accused can keep quite and take advantage of the flaw in evidence. But the rule of prudence is often read in isolation in the lower courts whereby the character proof of the accomplice is not regarded and with the prevalent corruption of the criminal justice system, the culprit goes scot free due to the loop holes in the testimony of accomplices on the presumption that the accomplice has low morals. 4. There is nothing in law to justify the proposition that evidence of a witness who happens to be cognizant of a crime or who made no attempt to prevent it, or who did not disclose its commission should only be relied on to the same extent as that of an accomplice. Where an informer was upon his own statement cognizant of the commission of an offence , and omitted to disclose it for six days, the court was not prepared to say that he was an accomplice, but held that his testimony was not such as to justify a conviction except where it was corroborated. 5 The factum that a person of low intelligence being struck with terror made no report of a crime does not make her or him an accomplice. 46 The Supreme Court in the case of Vemireddy v. S47 held – â€Å"If A happens to be present at a murder and takes no part in it, nor endeavours to prevent it, or to apprehend the murderer, this course of conduct will not of itself render him either principal or accessory. † The caution remains that the evidence of such a person should be scanned with the scrutiny of care and corroboration. It may not be possible to rely on their evidence, but they are not accomplices and it leads to confusion of thought to treat them s practically accomplices and then apply the rule of corroboration as to their credibility, instead of judging their credibility by a careful consideration of all the particular facts of the case affecting the evidence48 suggesting the over emphasis that is laid down upon independent corroboration even of witnesses who do not fall under the category of accomplices. 5. Absolute standard of proof does not exist and for a proof to be beyond reasonable doubt, the standard of reasonable man must be adopted. 49 Appreciation of evidence remains a delicate task and often the lower courts have the sole task upon them. A testimony without a fringe of untruth is rare and the court can reject it only when it is tainted to the core, that is, where falsehood and truth are inextricably interwined. 0 The question of weight to be attached to a particular piece of evidence is a matter on which decided cases cannot be of much help. 51 It is a well settled principle of the law of evidence that evidence may be accepted partially or in the whole. Where a part of the evidence is not separable from the rest of the unbelievable part, entire statement is liable to be rejected. 52 Merely because a part of the evidence is not acceptable, the entire evidence can not be rejected. 53 Witnesses cannot be branded liars in toto and their testimony rejected outright even if parts of their statements are demonstrably incorrect or doubtful and it is sound common sense to refuse to apply mechanically the maxim â€Å"f alsus in uno falsus in omnibus†. In criminal cases, the court cannot proceed to consider the evidence of the prosecution witness in a mechanical way. Credibility of a witness should not be accepted merely because it is corroborated by the evidence of other witnesses but credibility should be tested in the touch stone of the probabilities of the case and if the doubt arises with regard to any material fact then the accused should be given the benefit of doubt. 54 But often in cases of accomplice witnesses the rule is applied mechanically forgetting these basic principles of appreciation of evidence. 6. Confession of the co-accused can be treated as substantive evidence55 but not an accomplice witness. Section 3056 says that if in a joint trial for an offence and a confession is made by any one of them, then it should be considered as against such person and also against others and offence in the section includes the abetment of or attempt to commit the offence also. The object of this section is that where an accused person unreservedly confesses his won guilt, and at the same time implicates another person who is jointly tried with him for the same offence, his confession may be taken into consideration against such other person as well as against himself, because the admission of his own guilt operates as a sort of sanction, which, to some extent, takes the place of the sanction of an oath and so affords some guarantee that the whole statement is a true one. 7 Yet in cases it has been held that confession of the co-accused is an evidence of the weak type for it is not required to be given on oath, nor in the presence of the accused and it cannot be tested on cross-examination an d thus it is a much weaker type of evidence than that of the approver which is not subject to any such infirmities. 58 The admitted fact is that there is a tendency to include the innocent with the accused which is peculiarly prevalent in India, as it has been observed on numerous occasions by the Courts that it becomes difficult to guard against all the danger and there by insistence is placed on independent evidence which in some measure implicates such accused. There is an inherent contradiction whereby the Courts have at one point held that confession of co-accused cannot be considered as an accomplice witness and thus it may not require corroboration whilst in other situations the Court considers it as a weak evidence and call for independent testimony is done defeating the earlier reasoning that the co-accused facing a joint-trial with his associates would divulge the truth. Thus it has made the position more complicated and the distinction between an accomplice who has been granted pardon and who still faces trial should be eroded from the legislation and the law should remain that wherever needed the rule of prudence should be adhered. 7. A general rule, courts may act on the testimony of a single witness even where there is no other evidence which supports it. In England, the rules governing warnings to juries in criminal cases about the dangers of unsupported evidence have changed markedly during the last two decades being driven by several concerns, in particular; some old rules were based on the assumptions about the characteristics of certain categories of witnesses which derived from out-dated views and even prejudice, whilst the jury directions which the common law often required were complex, confusing and gave rise to many appeals. The modern law has thus moved towards a position where trial judges have discretion to choose whether to give a simpler form of warning or none at all. 59 This transaction has made redundant a large amount of the previous law concerning the categorization of witnesses and the identification of evidence capable of amounting to corroboration. 60 Two further consequences of these changes seem likely. First, the common law in areas not directly covered by the reforms is nonetheless likely to be developed in future in accordance with the values underpinning the reforms. 61 Thus for instance some simplification of the warnings given in cases involving identification evidence might be predicted. Secondly, the replacement of complex set piece warnings with simpler and more flexible warnings may encourage trial judges to give warnings in suitable cases beyond the strict limits of the previous categories. 62 In R v. Makanjoula63 counsel for the appellants argued that the rationale for such warnings had not evaporated overnight with the bringing into force of sections 32 and 33, and that consequently in the cases under appeal the trial judges ought to have chosen to give warnings in the same terms previous law. The court of Appeal disagreed and held that it would be contrary to policy and purpose of the 1994 Act for judges to continue give warnings in the same terms previously used and in all cases involving accomplices and sexual complainants. The court of appeal acknowledged, however, that judges do still have discretion to give warnings about the dangers of relying on unsupported evidence. The discretion identified by the Court of Appeals in the above mentioned case is a broad one and covers both whether a warning should be given and if so, in what terms should be. In exercising the discretion judges should consider the content and manner of the particular witness’s evidence, the circumstances of the case and the nature of the issues raised in it. 4 To avoid the risk of warnings being based on out-dated stereotypes or prejudice the Court of appeal advised that a warning should be only given about a particular witness’s testimony where there was an evidential basis for suspecting that the testimony could be unreliable. A mere suggestion to the witness in cross-examination that his or her testimony was unreliable will not amount to an evidential basis for this purpose. If there is an evidential basis the judge should vary the terms of any warning65 to be given according to where the witness stands in the scale of unreliability. Set piece warnings were castigated by the Court of Appeal as tortuous and more bewildering than illuminating. Henry L. J. has stated that the ‘old case incrusted orroboration directionglazed the eyes of injuries over generations’. 66 In Ranadhir Basu v. State of west Bengal67 the testimony of an approver was not accepted in respect of one of the co-accused for want of independent corro boration but the Court held that this did not have the effect of introducing any infirmity in her evidence or creating any doubt regarding her reliability as a witness. Yet in another case where the evidence of an approver implicated several accused persons, there should have been corroboration not only generally but also qua each accused, nevertheless corroboration from independent source of each and every circumstance was not made necessary. 8 This clearly indicates that the rule of prudence has underwent change where reliability precedes the need for corroboration yet the changes in Indian criminal justice system have yet to be incorporated when our predecessors have moved way ahead catering to the need of speedy justice. CONCLUSION The rules of evidence cannot be departed from, because there may be a strong moral conviction of guilt; for a judge cannot set himself above the law which he has to administer or make it or mould it to suit the exigencies of a particular occasion. 69 Suspicion cannot give probative force to testimony which in itself is insufficient to establish or to justify an inference of a particular fact. 0 Suspicion can be a ground for scrutiny cannot be made foundation of a decision for it is well known that the sea of suspicion has no shore and the court that embarks upon it is without rudder and compass. 71 In a criminal case no weight of preponderant evidence is sufficient, short of that which exclu des all reasonable doubt. Unbiased moral conviction is no sufficient foundation stone for a verdict against an accused. The degree of probability of guilt has got to be higher almost amounting to certainty than in a civil proceeding and if there is the slightest reasonable or probable chance of innocence of an accused, the benefit must be given to him. But that is quite different from suggesting that the burden of proof is different and the Act does not obviously contemplate that the satisfaction which is required to be caused in the mind of a prudent man before acting on or accepting the prosecution story is to be different kind or degree from the satisfaction which is required when the accused has to discharge the burden which is cast upon him by law. 72 Added to this it has to be bore in mind that unlike civil litigation, in criminal trials the judge has to decide the case on the basis of the evidence adduced before it and independently of decisions in litigation laid down for which a judgment or decision of a court is not available to be adduced as evidence in a case and is of only use to the extent to show the date and its legal consequence. 3 The onus of proof in criminal case never shifts to the accused, and they are under no obligation to prove their innocence or adduce evidence in their defense or make any statement. 74 Keeping this at the outset and the backdrop it can be sensed that the need for corroboration is on the basis that there is suspicion in the mind of the judge with regards to the character, the morality of the accomplice. This in turn has the disastrous effect as we see by making the trials lengthy, time consuming, and expensive. The number of appeals consequentially increases and the higher courts often become the courts of evidence than the court of law upsetting the entire system. The lack of corroboration often entails the rescue of the perpetrator and the only ground is lack of independent testimony of the accomplice witness. Realizing the facet that no set piece rule can be applied it seems a faulty approach that the lower courts in India have mechanically adhered to the rule of prudence making it an unbreakable and invincible dictate even when the intent behind the evolution has undergone changes and it is in this light that the judiciary should really step up in varying the terms of warning, in changing the order of the tests of reliability and corroboration, in inculcating the flexibility that initially was contemplated. ____________________________________________________________ ___________ 1-2 R v. Mullins 3 Cox Cr 526 (as per maule J. ) In two cases where the person is not participes criminis is also considered as an accomplice, namely a) receivers of stolen property b) where a person has been charged with a particular offence and evidence of other s imilar offences by him has been admitted as proving system and intent and negating accident persons who had been accomplices in the previous offences. (R. K. Dalmia v. Delhi Administration AIR 1962 SC 1821) 4 Ramaswami v. R 14 MLJ 226 (as per Subramania J. ), State v. Murli AIR 1957 All 53. (This definition has been based on the US definition of accomplice U. S. v. Neverson 14 Century Dig Col 1279. ) 5 Hussain Umar v. Dilip Singhji AIR 1970 SC 6 Jagannath v. Emperor AIR 1942 Oudh 221 7Ibid. 8 A principal of the first degree is one who actually commits the crime whilst a principal of the second degree is one who assists and prepares in the commission of the crime. Ismail Hasan Ali v. Emperor AIR 1947 Lah 220. 9 Ibid. 0 An accessory before the fact is one, who counsels, connives at, encourages or procures the commission of the crime and these are certainly accomplices and all accessories before the fact, if they participate in the preparation for the crime are accomplices but if their participation is limited to the knowledge that a crime is to be committed are not accomplices Ibid; Narain v. R 63 CLJ 191 11 Every person is an accessory to the fact that having knowledge of the fact committed by another person receives, relieves comforts or assists him in order to enable him to escape from punishment. All accessories after the fact do not have the same parameters of criminality and much depends upon the factual matrix at hand. Mahadeo v. The King AIR 1936 PC 242 12 Fost Cr Cas 341; 1 Russ Cr 21, 4 Bla Com 331, 1 Phil Ev 28 c. f. Sudipto Sarkar, V. R. Manohar, â€Å"Sarkar law of Evidence†, Vol 2, Wadhwa Nagpur Publications (16th ed, 2007) at page 2248. 13 Ibid (Sarkar on Evidence) 14 State of Bihar v. Sri

Columbia University SIPA Master in Public Administration Essays

Columbia University SIPA Master in Public Administration Essays Columbia University SIPA Master in Public Administration Essay Columbia University SIPA Master in Public Administration Essay Carbon emission trading was initially introduced by the Kyoto Protocol and was adopted in 1997, then later took effect in 2005 when Russia and Canada ratified the Kyoto Protocol to the UNFCCC. The cap and trade approach was adopted to help reduce carbon emission and mitigate future climate changes by internalizing the externality of economies, which is one of the major market failures. The trading was designed to provide economic incentives to countries to help in realizing the reduction in the volume of emotions of the pollutants. The market mechanism was expected to function to bring capital and interest from the private sector in the developing countries where the energy efficiency is relatively lower and as a result, reduce GHG gas in the most efficient way. Despite being an idealistic concept, the carbon-trading framework is facing challenges such as Push by multilateral donors, lack of institutional capacity, and poor governance. With its elaborate structure, the carbon-trading model can be used to eradicate poverty if we can say that the poverty is an outgrowth of global capitalism. I would like to explore the feasibility of applying the carbon market mechanism in the alleviation of the poverty.

Plain packaging of cigarettes is a good policy and should be retained Essay

Plain packaging of cigarettes is a good policy and should be retained in Australia - Essay Example Proponents of the laws enactment argue that it will restrict the use of colors, brand imagery, logos, and promotional texts. Inclusions in the product create the effect of its appeal to consumers. The government uses the legislation to make the product less appealing especially to the young (Australian Government, Common Law 2011). As a result, plain cigarette packaging is an initiative to reduce cigarette consumption. The government expresses concerns of citizens health and discourages commodities, such as tobacco. Product homogeneity is very instrumental in standardizing competition. Tobacco manufacturers use packaging to differentiate their products and make it attractive than others. The government intends discourage unfair competition that might affect the performance of small industries. Plain cigarette packaging comes along with product homogeneity that standardizes commodities. When packaging of cigarettes appeal in the same way to consumers, they will not reestablish brand loyalty (Davey, 2014). Therefore, the legislation eliminates unfair competition caused by well-established industries to small ones. Consumers tend to buy a product not because they are in need of it, but the packaging persuades them to acquire. Consequently, packaging causes impulse buying as consumers purchase products without an active decision-making process. The legislation on plain cigarette packaging achieves to encourage cigarette consumers to go through a proper decision-making process before deciding to buy the product (Walsh et al., 2008). Plain packaging standardizes the product and makes it consumers buy it only to satisfy their needs must not because of its appeal. The government imposition of plain cigarette packaging undermines trademark law. It also breaches intellectual property rights as well as international trade arguments. Trademark serves the purpose of distinguishing

Case studies and written questions Assignment Example | Topics and Well Written Essays - 1250 words

Case studies and written questions - Assignment Example : In the Democratic Leadership Style, managers encourage their staffs to participate in the decision making for the company development and growth. The role of managers in democratic style is as a leader, who gives guidance to their staff to solve the problems. : i. This management of style is time consuming. Since, to solve a problem a long discussion is required among team members. If the company wants to solve a urgent issue then this process will take long time to solve a problem. ii. In this style of management, much time a manager could not take decision easily. Since there are many outcome of discussion, which may led create confusion to the manager and to decide which outcome will be better for the company development. : This style of management is give opportunity to every staff to share points to solve the problems and give a unique result to solve the problem and help in the company development. This style of management always helps to motivate the staffs to do their work properly, and it will be good for the company’ development. Although this style has lots of draw backs like time consuming and sometimes the manger could not able to decide which outcome is better for the company. If the company willing to solve the long term problem, then this style of management will be better for the company and help to grow the company in faster way. This management of style is not useful of short terms issues. : The management style of Blake for the company point of view is good. Blake is encouraging his staff members to discuss the problem in a team meeting and even he is also showing concern to his staff privately but in private discussions, he is against of backstabbing and bitchiness among the staff. This style of management of Blake always helps to solve long term goal and motivate their staff too. : There is a huge communication gap between Peter and Jodie. They are not discussing

East Asian Essay Example | Topics and Well Written Essays - 1000 words

East Asian - Essay Example Qian had the prerogative to choose who, what, why and how things happened in his history. Qian chose to quote his sources as much as possible. An example is the account of the attempt made by Jing Ke on the life of the first Chinese emperor, which was an eyewitness account by the great-grandfather of his father's friend, who served as a low-ranked bureaucrat at court of Qin and happened to be attending the diplomatic ceremony for Jing Ke. Qian also created highly probable and consistent events even when there were none available. His work eventually consisted of 130 chapters about Dynastic houses, the biographies of the Han emperors, dates of events, descriptions of rites and rituals, music, and various other topics of interest. Also included were the histories of the states which existed during pre-Qin China and the biographies of other important personages in history. Before The Records of the Grand Historian, historical texts tended to downplay the role and events from other dynasties and played up their own. This tendency was also present in Sima Qian's historiography. Qian portrayed the Han dynasty as having the Mandate of Heaven and gave lesser importance to the dynasties that preceded it. Among the features that Qian emphasized in his work was the ascendant character of the Han Dynasty. Consequently, he depicted the preceding Qin dynasty, which was Legalist, as evil and as such deserved to be replaced by the Han which prescribed to Confucianism. This theme is recurrent in his biographies which often contained moral lessons and anecdotes. Qian also took every opportunity to point out that Legalist ideals which were abundant and commonplace in the Qin Dynasty did not benefit anyone unlike Confucian ideals which redounded to benefits for the people. Examples of these biographies which justified the ascendant moral plane of the Han were the Chen She, Han Xin and the Empress Lu. This bias of Qian's against the Qin dynasty is fairly evident throughout The Records of the Grand Historian. Qian's favorable disposition towards Confucianism is explained by his belief that it is a more preventive means by which to keep peace among the peasants. He believes that fair, just and moral rulers will beget fair, just and moral peasants for them to rule. This common nature when achieved among both rulers and peasants would result in peace, according to Qian's beliefs. In contrast, he believes that the Legalist approach is able to preserve peace through the rule of a tyrannical government. He contends that a tyrannical government places all its constituents, peasants, nobles and ministers alike, under threat of mistreatment and enslavement. Qian also pointed out that there are major differences in how the Qin and Han perform their rites and treat their ancestors. In Confucianism, rituals and ancestors were central in their beliefs. This was exemplified in the biographies of Han Xin and Chen She. Qian pointed out that the latter's grave was cared for by thirty families which saw it as an honor to perform such duty. Qian also related how Han Xin buried his mother "on a high broad expanse of earth with room enough around to set up 10,000 households," similar to the treatment received by an honored ruler. Both personages were practitioners of Confucianism in their lifetime and were correspondingly rewarded with power and influence. In contrast, Qian's biography of the

Prospect theory in decision making

Prospect theory in decision making Prospect theory is an important theory for decision-making between alternatives that involve risk. The theory departs from the traditional expected utility theory because it attempts to explain how people really make decisions between risky alternatives, which attempts to model optimal decisions. This vital difference leads to the prospect theory departing from the traditional framework in important ways. Unlike the traditional approach, it attempts to incorporate psychology into the consideration process to provide a behavioural approach to portfolio selection (Barberis, Nichola, Huang, Santos, 2001). During the course of this report, we will first look at how prospect theory differs from the traditional expected utility theory to gain a better understanding of the concept. Following this will be, a discussion of the key elements of prospect theory the value function including a small reference to endowment effect and the status quo bias, reflection and framing effect, isolation e ffect and probabilistic insurance. Towards the end, we will have a precise look at the applications of prospect theory equity premium puzzle and home bias. The traditional finance theory assumes that investors try to maximize expected utility of wealth when they are making decisions under uncertainty. However, many studies have shown that the underlying assumptions of the traditional theory do not accurately describe how people actually behave when choosing among risky alternatives. This inadequacy leads to the weak correlation between the utility theory model and real decisions. There are four key features [that] distinguish prospect theory from mean-variance theory, which is the traditional approach to modelling decision-making. First, according to the traditional theory people choose among alternatives based on how the outcomes will affect their overall wealth. However, according to prospect theory people evaluate outcomes in terms of gains and losses relative to a reference point. So decisions are based on how the outcome changes their income, in relation to their reference point. (Han Hsu, 2004). Second, the mean variance analysis makes the assumption that people are risk averse in all their choices. In contrast, prospect theory agents are risk-averse in the domain of gains but are risk seeking when all changes in income are framed as losses. The third feature of prospect theory is loss aversion. An individual is loss averse if she or he dislikes symmetric 50-50 bets and their degree of aversion increases with the absolute size of the stakes. In other words, prospect agents dont perceive gains and losses of equal amounts evenly. For example, the loss of a particular amount is more painful then the pleasure received from the gain of an equal amount. This is also known as the endowment affect. People place a higher value on a good that they own than goods that they do not, and are willing to accept a higher risk if it means that they can avoid the loss. Finally, in utility theory risk is treated objectively, by its probabilities. In contrast, the utility under prospect theory is not dependant on the original probability but rather on the transformed probability also known as decision weights. They do not just measure the perceived likelihood of an event. Instead, they measure how events will impact the desirability of prospects. (Han Hsu, 2004) This feature of the prospect theory helps explain a number of violations of expected utility theory, including the famous Allais paradox. People in prospect theory tend to overweight small probabilities. This overweighting explains why people buy lottery tickets offering a small chance of large gain, and insurance protecting against a small chance of a large loss (Kahneman Tversky, 1979). The four elements explained above and how risk is evaluated is usually explained by the value function. The concept of the value function is based on gains and losses from a reference point, as explained in the first element of prospect theory above. Value function stresses the importance of the reference point (starting point) although changes and movement are observed more compared to the resting point, due to the concept of gains and loss. The following is the prospect theory value function: à Ã¢â€š ¬= non-linear weighting function V(x-r) = the value function R= the reference point PT = à ¢Ã‹â€ Ã¢â‚¬Ëœ à Ã¢â€š ¬ (pi) v(xi r) This function creates an S-shaped curve (Figure 1.1) Figure 1.1 The curve clearly highlights the reference point, from where onwards gains and losses can be observed. It displays that as your gain increases the desire for it decreases demonstrating that people are risk averse when it comes to gains. On the contrary, as the loss increases the fear for more loss increases hence showing that people are risk seeking regarding losses. These two factors are highlighted in the graph by the steepness of the relevant sides. As gains increase the steepness decreases (indirectly proportional) and as losses increase the steepness increases (directly proportional) (Maher, 2010). An example for this irrational behaviour is how a random sample would prefer to spend their $400. Gain Option A, where you will have a 100% chance of gaining $200 Option B, where you will have 50% chance of gaining $400 and a 50% chance of gaining $0 Loss Option A, where you will have 100% chance of losing $500 Option B, where you will have 50% chance of losing $1000 and 50% of losing $0 In this scenario the vast majority of people would choose option A for gain and option B for loss confirming that people weight their losses more compared to their gains. As they would settle for a rational gain (even if it is small) but when it comes to losses they would prefer risk seeking to limit their loss. The determination of utility relating to the gain or loss mirrors the concept of psychophysical principle concerning the evaluation of outcomes. This reflects loss aversion which then implicates two specific aspects. Firstly, the endowment effect i.e. people would be willing to demand a higher value on product that they themselves own rather than a similar product that they do not. The second implication is status quo bias, in this case people like things to stay relatively in the same position they are in so they remain at the status quo they are in. In this scenario any sort of change either good or bad is taken to be a disadvantage. Another key element of prospect theory is the reflection effect, which states that while investors are risk averse over prospects involving gains, they are risk seeking over prospects involving losses. This effect explains the observed preference for definite small gains over uncertain large gains and in opposition preference for uncertain large losses over small certain losses. A remarkable interpretation of the reflection effect is that, a replacement of all positive payoffs by their negatives (reflection around zero) reverses the choice patterns. For example, a choice between a 90% choice of getting 2000 and a 45% chance of getting 4000 would be replaced by a choice between a 90% chance of losing 2000 and a 45% chance of losing 4000. This effect implies a risk-averse preference for high probability of the relatively safe 3000 gain, but a reversed preference for the risky option in the loss domain. Reflected choice patterns reported by Kahneman and Tversky (1979) were fairly high, i.e. 86% of subjects chose the safe lottery (90% chance of 3000) in the gain domain but only 8% chose the safe lottery when all payoffs were transformed into losses. (Laury Holt, 2000).An important implication of this is the S shape of the value function in prospect theory that is concave for gains and convex for losses. It was also identified, that if the same decision problem was worded differently, the preferences of decision makers differed as well. This was referred to as the framing effect. Prospect theory implies a unique relationship of risk seeking to positive and negative framing- negatively framed problem encourage risk seeking. For example: When a group of investors were faced with the following two propositions: A gamble that offers a 10% chance of winning $95 and a 90% chance of losing $5 and another gamble B offering a 10% chance of winning $100 and a 90% chance of winning nothing. It was found that although the outcomes on both the gambles were the same, 74% of investors chose option B as paying $5(negative as compared to a loss) for the gamble than simply losing made the gamble more acceptable. Von Restorff created the concept of the isolation effect, a way to make something that conforms within a similar a group stand out like a sore thumb. An isolated item, in a list of otherwise similar items, is better remembered than an item in the same relative position in a list where all items are similar. This is a way of distracting attention from one event when the alternative holds exactly the same probability and can be of some help in explaining the prospect theory in decision making in relation to investments. Kahneman and Tversky (1979) used the example of a two-stage test to better explain the use of the isolation effect practically in a behavioral finance situation. Isolation effect is important to show the irrationality of investors in situations that would normally produce a rational effect. This typifies the psychology of an investor having their attention diverted away from using a mean variance analysis of a situation. The first step of the test is a .25 chance of progression to the second stage and a .75 chance of gaining nothing. The participant is asked to decide before the first stage whether, if successful, they would take 3000 or a 0.8 chance of taking 4000. It must be noted that in this game, the participant is choosing between 0.2 chance of 4000 or a 0.25 chance of 3000, the expected value of the former being greater (800 rather than 750). Of the 141 participants that Kahneman and Tversky (1979) tested, 78% chose the first option of the guaranteed 3000. The reasoning behind this is the greater appeal of the sequential certainty of the choice; most participants ignored the first stage of the experiment and just looked at the second test as a basis for their decision rather than weighing up the potential outcomes. The concept is a strong indicator to suggest against all investors being mean variance optimising, there is clear evidence that given the right circumstances people will ignore the obvious rational choice and accept a decision based on the higher valuation of certain prospects. This evidence of irrational preference conforms to the reflection theory where the certainty of a small gain is valued higher than a chance of a large gain. Using this psychological weakness in peoples logic the Von Restorff effect distracted attention from the overall probability and coerced the decision maker into accept a decision based on something that stood out. The rising popularity of insurance policies has been used by supporters of the utility function as strong evidence of the concavity of the utility curve for money. However Kahneman and Tversky (1979) demonstrated that not all insurance policies support this idea, basing their argument around the example of probabilistic insurance. Probabilistic insurance has also been used to highlight that decision weights tend to overweight small probabilities and large probabilities, but underweight moderate probabilities (Wakker, Thaler and Tversky, 1997). Standard insurance provides the purchasers with a zero percent chance of any loss after a given incident, however a probabilistic insurance policy leaves the purchasers open to a small possibility that they will not be fully reimbursed. Following is an example of standard versus probabilistic insurance. Suppose you want to insure iphone4 for the coming year, you can either insure your phone with Natwest bank for  £10 a month or with ABC insurance who offer to insure the phone ever other day throughout the year for  £4.50 per month. Most people would view the offer by ABC as unattractive and prefer to go with the deal offered by the bank of  £10 per month. In this situation the purchaser is underweighting the fifty percent chance of damage to the phone occurring on a day that he or she is covered by the ABC insurance policy. This example demonstrates that reducing the probability of a loss from p to p over 2, is less valuable than reducing the probability of a loss from p over 2 to zero (Tomas and Viilar, 2002). In contrast to the iphone4 insurance example given above, expected utility theory implies that probabilistic insurance is superior to regular insurance. This aversion towards probabilistic insurance is noteworthy because the most avid purchaser of insurance is still subjected to some level of risk. For example, most household contents insurance policies are void if the purchaser forgets to lock their front door. This type of insurance represents many types of protective action, where the user pays a certain cost to reduce the probability of an undesirable event. For example, the purchase of a steering wheels lock or a carbon monoxide detector (Kahneman Tversky, 1979). Applications of Prospect theory The underlying principles behind Prospect theory have been used on a number of occasions to explain a range of financial anomalies. The real world aspect of the model means it offers genuine explanations for some of the most prominent puzzles such as the Equity Premium Puzzle and Home Bias. Equity Premium Puzzle The equity premium puzzle refers to the empirical fact that stocks have outperformed bonds over the last century by a surprisingly large margin. Since 1926, the annual return on stocks has been around 7% while the return on bonds has been around 1% so, $1 invested in the SP 500 on January 1, 1926 was worth $1100 by the end of 1995, while $1 invested in T-bills was worth $12.87. In 1985, Mehra and Prescott noted that under the assumptions of Expected Utility Theory, these abnormally high and low returns are difficult to explain. In 1995, Banartzi and Thaler offered an explanation to the puzzle based on key features of Prospect Theory. They claimed that the puzzle is caused mainly by two factors derived from the Prospect theory; loss aversion (investors being more sensitive to losses than gain) and a short evaluation period (investors checking their portfolio too often). This combination they termed Myopic Loss Aversion. They argue that the attractiveness, and therefore value of a stoc k depends on the time horizon of the investor and frequency of evaluation. The more frequently somebody evaluates their portfolio, the more likely they see their losses and suffer from loss aversion. Putting this application into more contexts, a risky asset paying 7% per year with a standard deviation on 20%, like the average stock, has a probability of loss or gain of around 50%. For a loss averse investor who evaluates frequently, the stock market appears very risky. Considering this, an investor who is prepared to wait a long time between evaluating will find stocks much more appealing as there is an increased chance of them closing their position with a positive return. In turn, long-term investors will be willing to pay more for an identical stock than a short term, frequently evaluating investor. Prospect theory has other various applications associated with it apart from the above mentioned equity premium puzzle. The Home bias phenomenon is another such example. This phenomenon contradicts the mean variance framework, which elucidates the benefits of international diversification helping in the minimization of risk of a given securitys expected return. Home bias states that investors hold more domestic stocks and few foreign stocks than the optimal amounts actually predicted by the mean variance optimization (French and Poterba, 1991). Prospect theory explains this tendency of investors to choose domestic stocks. It says that one of the reasons for this could be a greater familiarity of investors with domestic assets and lower downside risk. This compels investors who may think globally to act locally (Campbell and Kraussl, 2006). Consider a foreign stock and a domestic stock with identical distribution payoffs. Since the foreign stock seem less familiar than the domestic on e, investors may perceive it as having higher variance of payoff leading to low allocation to the foreign stock. However a direct implication of this is derived from the portfolio choice theory that home bias would decline as investors became more familiar with foreign stocks ( (Han Hsu, 2004). Thus, while the prospect theory can explain this behaviour of investors to concentrate risks on single assets rather than to hold a well diversified portfolio, it fails to explain why the single asset chosen by investors are domestic ones. In addition, the argument posed by Stracca (2002) says that if prospect theory is an accurate description of human attitude towards risk, the benefits of international diversification would be reduced to a significant extent. Conclusion We have looked over the principal elements behind the prospect theory proposed by Kahneman and Tversky in 1979. Prospect Theory is an alternative descriptive model of decision making under uncertainty, which incorporates real life choices and psychological analysis. Firstly, within prospect theory investors evaluate their outcomes in accordance with a reference point and make decisions based on how the outcome changes their wealth in relation to this unique reference. Within the expected utility theory, this relative level of wealth is not accounted for. Another key assumption behind prospect theory is the risk averse and seeking behaviour of investors under different circumstances. Investors are risk seeking in terms of losses and risk averse when it comes to profits. The assumptions of an endowment effect and decision weights are also included within the theory, where people place a higher value on a good that they already own and, in contrast to expected utility theory, risk is in corporated not by the original probability but by transformed decision weights. The S-shaped value function curve for prospect theory show this risk seeking and averse behaviour in investors, a reflection effect. The idea of framing is also a key element of prospect theory, where if the same decision problem is described in different words, it can lead to different preferences. Within the theory also is an isolation effect, where devices are used to draw additional attention to something that would otherwise conform, and probabilistic insurance, where decision weights tend to overweight small and large probabilities, but underweight moderate probabilities. The real world assumptions behind prospect theory have been used to explain a number of financial anomalies. We finally looked into prospect theorys applications to the equity premium puzzle and home bias which offer explanations to these anomalies.

The village by the sea :: essays research papers

ESSAY NO.2 In Annita Desai’s novel, the treatments between male and female characters are totally different. It is described in the novel that the male characters are always lazy, selfish drunkards while the female characters are diligent and always keeping the family together. Annita tried to illustrate the readers how Indian people live in the village of Thul and how urban Indians live in the capital city of India, Bombay. In the creative novel of The Village by the sea, the two characters that play the most important roll in the play are Hari and Lila. Hari is the one who find some food and some earnings for the family, and also the one who decides to go to Bombay because he thinks that he certainly cannot get a job in an industry. On the other hand, Lila is the one who takes care of her two sisters, Bela and Kamal, and also her sick mother. In every morning, she needs to make tea for her two sisters before they go to school and also her mother who is sick of an unknown disease. Both Hari and Lila cannot go to school because the family does not have enough money to support all the children’s school fee. Despite the facts that Annita Desai describes the village of Thul as a mini paradise which lived there happy people, but apart from that she tries to focus at Hari and Lila’s hut. All the people and houses around their hut seem so colourful and joyful. However, Annita describes Hari and L ila’s hut as a small, old patched hut which has a feeling of unhappiness and sickness. The earthen walls are crumbling and the windows gapped without any shutters. She illustrates the readers that this hut is such a colourless hut apart from all the other huts around it. The mother, who is sick, of this family is the one who plays the most important part in keeping the family alive, well and together. Although Annita just writes in the novel that the mother is very sick and cannot move anywhere, but she was the one who keeps this family joined together. Because the father, who is the leader of this family, is a drunkard who is irresponsible about taking care of the family Hari and Lila needs to find some way to survive and to earn some money to take their mother to the hospital.

Ralph Waldo Emerson Essay

Those who think Transcendentalism is just a literary movement that took place in the early 1800s are only half correct. Transcendentalism is indeed a literary movement; however, it is much more than that. It is meant to challenge people to think for themselves and cause change. Authors such as Ralph Waldo Emerson, Henry David Thoreau, Jerome Lawrence and Robert Edwin Lee taught the importance of non-conformity and civil disobedience through short stories such as â€Å"Self Reliance† and â€Å"On the Duty of Civil Disobedience†, and the play, The Night Thoreau Spent in Jail. Transcendentalism is based on the belief that knowledge is derived from experience and personal reflection as opposed to reason. Transcendentalism promotes self-revelation because it encourages people to form their own opinions and then voice them in a way that will promote change in society. Transcendentalists ground their philosophy with the idea that every person’s inner self is where knowledge is gained. In Ralph Waldo Emerson’s â€Å"Self Reliance†, he says, ‘†What I must do is all that concerns me, not what the people think†¦It is easy in the world to live after the world’s opinion; it is easy in solitude to live after our own; but the great man is he who in the midst of the crowd keeps with perfect sweetness the independence of solitude. ‘† Emerson realizes that it is easy to conform to society, but there is value in forming one’s own opinion. What makes a person great is if he or she can stand out in a crowd of people. While in a crowd, one can see the overall ideas of the group but never the individual thoughts that made up these ideas. Emerson is saying that to be great, one must be able to be with the crowd physically, but mentally remain one’s own person with their own ideas. Because Transcendentalism values individual opinions, it is also important to people such as Henry David Thoreau that everyone, especially the government, is open to other peoples’ opinions. In â€Å"On the Duty of Civil Disobedience† Thoreau says, â€Å"There will never be a really free and enlightened State until the State comes to recognize the individual as a higher and independent power†¦ and treats him accordingly. † Thoreau understands that citizens should be able to influence the government and cause change. To do this, the government needs to treat its citizens with respect. Politicians and other government workers need to do away with their pride and listen to what is really important- the citizens. When people can form their own opinions, respect others’ opinions, and voice their opinions, there will be harmony. In Transcendentalism, people are encouraged not only to form their own opinions, but to voice them as well. Thoreau tells everyone to â€Å"make known what kind of government would command his respect, and that will be one step toward obtaining it† (Thoreau). He supports transcendentalism by encouraging people to stand up and talk about their opinions. Thoreau understands that change, especially in government can only occur when individuals make their opinions heard. During his life, Thoreau challenged the idea of slavery, government corruption, payment of taxes, and the Mexican-American War. In The Night Thoreau Spent in Jail, Thoreau is talking to his old professor about how he should voice his discontent with the Mexican-American War. When Thoreau’s professor asks when he should voice his opinion Thoreau yells, â€Å"‘NOW! A year ago was too late! I’ll get you an audience. This afternoon. At Concord Square! †Ã¢â‚¬â„¢ (Lawrence and Lee 89). In the play, Thoreau expresses that opinions are no good if they are not proclaimed to the world. If opinions are not voiced they cannot be heard. Transcendentalism values individual opinions and acknowledges that voicing them is crucial if they are going to spearhead change in their society. Transcendentalists agree that self-revelation is wasted if it is not voiced and then heard and thereby causing change. During The Night Thoreau Spent in Jail, Thoreau spends a small amount of time as a schoolteacher. While Thoreau is a schoolteacher, he gets into trouble with the schoolmaster because he lets his kids â€Å"Huckleberry† in order to come to a conclusion in a class discussion. After he gets in trouble Thoreau sarcastically tells his students, ‘â€Å"You must not listen to a cricket or smell a flower that has not been approved by the School Committee. You’d better close both ears and hold your nose- though you may have to grow an extra hand to do it†Ã¢â‚¬â„¢ (Lawrence and Lee 20). In this instance, Thoreau is trying to speak out against the strict policy of the school committee. He sees that the policy is unfair and that students should be able to learn in a way that is effective for them. By speaking out against the school committee, Thoreau is opening up the possibility for a reform in the education system. Thoreau sees that there is an opportunity to promote change so he takes it and speaks his opinion. According to Thoreau and other transcendentalists, the government needs to be ameliorated. Thoreau says, â€Å"The government itself, which is only the mode which the people have chosen to execute their will, is equally liable to be abused and perverted before the people can act through it† (Thoreau). Transcendentalists agree that the government usually does not work for the people it is protecting. However, they do realize that it is necessary for the survival of the United States. Thoreau is encouraging people to take a stand against the current government, which he hopes will lead to a reform that will empower people to demand more influence in politics. Transcendentalism emphasizes that individuals need to voice their opinions if change is going to occur. According to Transcendentalists, promoting change in society occurs through self-revelation. There must be free thinking people in the world who are willing to make their voice heard if change is ever going to occur. Today many people think that the American school system is something that needs to be reformed. There is a problem if most students are no longer engaged and excited to go to school. Transcendentalists would say that students should be learning things that are interesting to them and cause them to think beyond what is being taught. Students should be encouraged to investigate and debate ideas in order to come up with their own. If America were still in the Transcendentalism time period, people would be insisting on these types of changes. They know that if they do not speak out, nothing will happen.

How To Build Your Spanish Vocabulary

How To Build Your Spanish Vocabulary A big part of learning any foreign language is learning the vocabulary - the collection of words used by those who speak the language. Fortunately for English speakers learning Spanish, there is a large overlap in the vocabulary. Thats because Spanish is a direct descendant of Latin while English received an infusion of Latin-derived vocabulary in the aftermath of the Norman Conquest of 1066. Word Similarities The overlap gives English speakers a head start in learning Spanish vocabulary. A linguist would say the two language have an abundance of cognates, words that are similar and have a common origin. But that head start comes with a price: Meanings of words change over time, and English and Spanish havent always changed in the same way. So some words, known as false friends, look like they might mean the same thing in the corresponding word of the other language. For example, something that is actual in Spanish is something thats current or happening now rather than something that isnt imaginary. And some words, ones I (but hardly anybody else) call fickle friends, correspond frequently but not so often enough that their meanings need to be learned. Arena in Spanish can refer to a sports arena, for example, but it more often refers to sand. Expanding on What You Know How many words do you need to be proficient in Spanish? Thats an open question because the answer depends on what you want to do with the language. That task of learning thousands of words may sound daunting. But there are ways you can make the task easier. One way is to take advantage of the many prefixes and suffixes, word beginnings and endings you can use. Many of the prefixes will seem familiar, because most come from Latin. Thats not as common with the suffixes. Two of the main kinds are augmentative suffixes, which can add a negative connotation to a word or refer to something thats particularly large, and diminutive suffixes, which can refer to things that are small or that are especially desirable. Memorization Memorization is seldom the most fun way to learn words, but many students benefit from it. Here are some of the word lists we provide as an aid: Top 100 Spanish words you need to knowSpanish for air travelersArabic words in SpanishSpanish arithmetic termsSpanish at the beachWords for everyday things around the homeComputer and Internet termsBody parts in SpanishCompound words in SpanishConfusing Spanish verb pairs: ser and estar, saber and conocer, othersEnglish words borrowed from SpanishGeography in Spanish: City names, definite articles with country names, nationalitiesSpanish lodging vocabularySpanish love wordsCommon and not-so-common vegetablesAlternatives for muySpanish names for occupationsSpanish names of petsSpanish astronomical termsSpanish names for relativesSpanish for ThanksgivingShopping in Spanish and Spanish names for storesSpanish units of timeSeasons in SpanishSpanish weather termsSpanish war and military termsSpanish words for whatSpanish words for snowWinter sports in SpanishU.S.-style football termsBasketball glossarySpanish at the zooWords for celebrating Halloween We also have lessons on use of particular words. Many of these lessons include comments on the words etymology, or word history. AlfabetoClaroDerecho and derechaGraciaGringoHuracnMejor and peorNoSanto For Fun It may not always be practical, but sometimes its fun to learn words just for the sake of learning them: Crossword puzzles in SpanishWhat is the longest word in Spanish? Ways to Make These Words Yours Over the years, numerous  readers of this site have offered their advice for incorporating the words into the Spanish that you can use everyday. The simple fact, though, is that what works well for one person doesnt work for everyone, as we all have our own learning styles. You might consider some of these methods, however, to see of one of them clicks for you: Make sticky notes with names of objects and place them on the things you want to be able to talk about. You cant do this everywhere, of course, but if you do this your home you can track your progress by removing the notes for words you have already learned.Create three-by-five-inch cards with vocabulary words on one side and definitions on the other. And random times during the day, compose sentences using the words.Use social media to find Spanish speakers learning English and you can help each other.

Jet Blue

Jet Blue JetBlue Customer ServiceJetBlue Airways is one of the top commercial airlines in the industry. JetBlue was founded in 1999 by David Neeleman. Their sales pitch was to give consumers "leather seats, satellite TV from DIRECTV, satellite radio from XM, and movies" (JetBlue) all for a reasonably low price. JetBlue's main goal was to "bring humanity back to air travel". The airline industry is suffering more than ever when it comes to customer service.JetBlue airways have always been my families choose of airline. Not because they were the best in the industry but because they provided a quality service for an affordable cost. We traveled often and my parents trusted the airline enough to send me and my sister on their flights alone. Our experience with customer service has been nothing to brag about. To name a few situations: they changed our flight information last minute without sending us the updated information, they lost our baggage twice, and the finally situation was when the atte ndant that was supposed to accompany me and my sister through security and to board our flight was late to work that day so we missed our flight and we had to board another flight 3 hours later.One of the main issues for JetBlue customers are the over-exaggerated bag fees that add to vacation costs. According to the American Customer Satisfaction Index (ACSI) "passengers that pay to checked bags are 10 points less satisfied than those who don't." (Aluise). Although this is one of the most successful ways airlines generate revenue it is destroying customer relations and giving them a bad reputation. JetBlue wanted to distinguish them from the rest penny grubbing airline carriers without disappointing investors so they came up with the "First bag checked free program". Other than Southwest airlines who allow...

Inflation Essay Example | Topics and Well Written Essays - 500 words

Inflation - Essay Example There have been cases around the globe known as hyperinflation. Though there is no official definition for it, it is generally accepted as a 50% annual inflation rate. Ecuador suffered through a 96% inflation rate in 2000 ("Background Note: Ecuador"). This was caused by a weak economy, massive debt from El Nino in 1998, and a floating currency. The president was ousted in Jan. 2000 and caused a 75% spike in a one-month period. The new government restructured the debt, privatized state owned industries, and tied the currency to the US dollar. The following years saw lower rates and it had dropped to 1.9% in 2004 ("Background Note: Ecuador"). The war and economic hardships in the former Yugoslavia resulted in inflation rates in the period 1971-91 of 69 percent, with hyperinflation of more than 50 percent per month in 1989 (Hanke). According to experts, Slobodan Milosevic triggered the hyperinflation by granting $1.8 billion in unauthorized credits to Serbian-owned enterprises (Hanke). It was only brought under control when the war ended and a new government was installed. Though the UAE and Dubai have not seen these rates of inflation, it has been on the rise in recent years. It was 2.8% in 2002 and is estimated to hit 20% in 2006. That was up from 10.5% in 2005 ("United Arab Emirates"). The rate was 3.2% and 4.6% in 2003-2004.

Case Study Example | Topics and Well Written Essays - 750 words - 45

Case Study Example In the bid for technology refresh, the organization requires to refresh 35 desktop personal computers. The refresh will involve the making the PCs able to deal with handle complex calculations when presented with statistical models that utilize enormous amount of data; this requires actual computer power right in the desktop machine. The senior manager considers that this would maintain the loyalty of its customers, especially banks, credit card companies and a fraction of law enforcement entities.. This report is written with the main objective of presenting a guides in assessment and identification of the hardware that would be essential to aid the users, financial analyst and economist, to maneuver through with their work; the work of operating with statistical model that use large amounts of data. This will involve concentrating on the components of internal hardware such as the CPU, motherboard, bus and hard drive. From these, the characteristics of the components will be evaluated on how it meets the requirement of the project. The first step was to identify the list of various components of hardware. This was done by considering the most probable ones that could satisfy the needs of the project. The attributes for each component was then defined to help in determining the usability. The attributes studied for this case were the size, number, capacity and speed, with reference to how they can handle large data sets. In which case, each component was defined by the attributes that are usually used to identify them. This step was significant to help in identifying the recommended attributes that could be used to evaluate whether the component in question meets the requirements (Vogt & Johnson, 2011). The next step was the evaluation of the usability of the component by justifying why a component might be recommended. This involved accessing the already mentioned