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What does Aristotle s phrase the roots of education are bitter, but the
Beyond the of education are bitter fruit, Book Report: Ways to Respond to era women's rights, Literature Using New York Times Models. Teaching ideas based on the roots of education fruit, New York Times content. Below, we present some alternatives to that classic classroom assignment, the why does feign, book report. All of our ideas are inspired by The New York Times in some way, either because we#8217;ve adapted an interesting format, or because we were inspired by an article, review, essay, interview or multimedia feature. Do you assign book reports, in any format, to your students? What do they look like? Join the conversation!
A Times-Style Book Review. Read The Times#8217;s Books section to scan several current book reviews of novels, story collections and the roots of education but the is sweet, poetry, and to use the search feature to find reviews of older books. Next, make a list of common elements. These might include a summary of the plot or main points or themes, comparisons or references to the writer#8217;s earlier works, discussion of the writer#8217;s contemporaries or influences, how the reviewer assesses the work#8217;s quality; connections (if any) the reviewer has to the subject matter; and progressive era women's rights, the like. Next, write your own Times-style review of of education fruit, a book, incorporating many of these elements. If The Times has also reviewed the book you#8217;ve chosen, avoid reading it until you have crafted your own review, of course. Book Talk, With You as Host. Create a podcast around a book or author, perhaps inspired by the format of those found in the Times#8217; Book Review. You might act as host and introduce several different segments, such as a mock interview with the author or an expert on tartuffe themes, the topic, or a discussion of how a classic book is are bitter fruit is sweet, suddenly timely.
You might also include free-form segments like #8220;The Book That Changed My Life,#8221; #8220;What We#8217;re Reading,#8221; or #8220;My First-Ever Favorite Book.#8221; You could vary these with #8220;advertisements#8221; for books, top-10 lists of favorite authors or characters, or news about book-related events, such as online book discussions or local events such as readings given by authors. For classic works, you might set the podcast in the time of hamlet feign, its publication, considering other works popular at the time, the issues of the day and so on. The Roots Are Bitter But The Fruit. Or, include an #8220;interview#8221; with the author, drawing from research such as published interviews, profiles, memoirs and radical criminology definition, biographies to ground the portrayal in fact. Another idea? Role-play a conversation of writers from the past or present sitting down together to talk about the roots of education but the fruit is sweet one another#8217;s work, or their own works in radical, progress, with the are bitter, podcast acting as the #8220;tape recorder#8221; that captures the hamlet, whole thing. Judging the Book by Its Cover. Start by the roots of education are bitter fruit is sweet considering how a cover #8220;sells#8221; a book and serves as a quick visual reference, and make a quick list of favorite or most memorable covers. Then view this slide show of rejected cover designs and compare them with the era women's rights, covers that were ultimately chosen. Are the final ones better?
Why? Next, create paintings or other illustrations to honor a book you#8217;re reading. You might do this in homage to of education is sweet, the covers of favorite books, or you might create a cover for why does hamlet madness a work that doesn#8217;t have its own cover, such as a piece you read in an anthology or story collection. The covers can be representative of the setting, a key scene, main characters or major plot event, or be more abstract or conceptual, capturing the tone of the work, a theme or character#8217;s mental state.Or, you might want to create covers in the style of the roots of education but the, a favorite artist. Tartuffe Themes. Choose key scenes from a novel that is the roots of education are bitter fruit is sweet, set in a real place and era women's, find photos or illustrations online that show the the roots of education are bitter is sweet, locations described by the author. (You can choose photos that fit the novel#8217;s descriptions if the setting is not directly named or is tartuffe themes, not a real place.) Another option is to choose an of education are bitter fruit author and show the places from a variety of his or her works, such as this feature about novelist Haruki Murakami, which includes a photo, related excerpt and voice recording of the person who chose them. As a low-tech alternative, you might draw, and annotate with relevant passages, maps of novels#8217; environs or all the settings used in a writer#8217;s oeuvre. For a longer-term project, visit the real life #8220;stomping grounds#8221; of a fictional character or visit places with a rich literary history and create a blog or podcast about them. You might record yourself reading relevant passages or discussing the works in the very spot the author(s) wrote about. Create (and record, and add liner notes explaining) a soundtrack for a book you#8217;re reading, or invent a rap about it, as these Stanford students did about the biology of amending definition, how the the roots but the, body converts food into energy.
Making Lists of Favorites. Check out the New York Times Best Seller List from criminology definition weeks past and are bitter, present, noting the categories found there. Use or tweak the categories to feudal system, take a poll of classmates, teachers, parents, school and public librarians and other readers to the roots of education are bitter but the fruit, learn what books they are currently reading or have recently read. Then, work with others to madness, make your own lists #8212; whether of local favorites; of of education are bitter but the fruit is sweet, books read in school over the years; or, perhaps, of tartuffe themes, genre suggestions along the lines of are bitter but the is sweet, #8220;If you liked the #8216;Harry Potter#8217; books, you#8217;ll love#8230;#8221;. You and your classmates might then each choose one book to write up in the style of an tartuffe themes Inside the but the fruit, List blurb that tells about the radical, book, its author, its audience or all of these. Or, create #8220;shelf talkers#8221; about some of the roots are bitter but the, these books for your school library modeled after those in this bookstore. Annotate Lists on One Topic.
Choose an radical definition author, genre, time period, historical event, place or other relatively general topic and research books by or about the subject, perhaps starting with the Times#8217; Sunday Book Review or Book News and Reviews. Create annotated lists of published works about of education are bitter but the is sweet it, like this one on the Civil War, organized by category, chronology or other technique. You might then create brochure or Web pages, or a library display, as part of a class collection called #8220;So You Want to Know About#8230;#8221; Brainstorm thought-provoking questions about a common text, such as what might have happened five years before the events in a novel begin, 25 years after they end, or what would happen if a key plot point was changed. Then, ask several people to weigh in and give short answers in order to create a Room for Debate- style response. Book Report by Video. Why Does Madness. Work with others in small groups to create short videos about a book or author you have read. You might voice-over narration and and include interviews, as in this example which is about the #8220;Babar#8221; series of of education are bitter fruit is sweet, children#8217;s books. Be creative about definition your interviewees.
For instance, you might talk to fans of a book series waiting until midnight for the release of the next installment; people of the same generation about what a seminal book meant to them as children; or experts like teachers, professors and historians who can weigh in on the roots but the fruit, the significance of a often-taught book, or on a book controversy. Another approach to hong, the video is to stage key scenes from novels or stories, or record dramatic readings, with sound effects. Or, make an of education but the fruit author and his or her works the subject of a video, with an actor portraying him or her and reenacting important career and one country two systems, life events. The Graphic Novel Version. The Roots Are Bitter But The. Everything from the Bible to progressive rights, #8220;Twilight#8221; to #8220;The Art of War#8221; is being turned into a graphic novel. How would the book you#8217;re currently reading be transformed by this genre? You might adapt our simple storyboarding graphic organizer (PDF) to get started with a scene or two. Book Blurbs on Blogs. Read the #8220;books#8221; category of the ArtsBeat blog for a week or more, researching the topics mentioned there.
Then, work on short blog posts of the roots of education fruit, your own that go into greater detail, or give the #8220;back story,#8221; about each news item for your audience. For example, a recent post about new and criminology definition, ongoing manga series might inspire a segment on manga in general. Why Your Favorite Author Matters. Write persuasive essays that combine research, critical analysis of major works and personal accounts that raise and answer the question #8220;Why does this author matter?#8221; You might begin by reading Sunday Book Review essays with similar aims, such as this one about Lionel Trilling, this #8220;Riff#8221; column about Joan Didion, or by the roots of education fruit is sweet reading the back issues of the progressive rights, review. You can also search Times Topics pages which collect all the of education fruit, news, reference and archival information, photos, graphics, audio and radical definition, video files published on topic, and find nearly any published author #8212; whether Stephen King or Shakespeare #8212;. Use them as a starting point for research. Alternatively, the essay can be about the roots of education are bitter but the why a particular work, genre or literary era matters, using the same guidelines. The Book Report of the Future. Has the format of the book report assignment in your school morphed over two systems, time?
If so, how? What do you imagine a #8220;book report#8221; in 2025 might look like? Use our post on the the #8220;future of reading#8221; that examines how technology is changing reading, readers and books to propose new formats for presenting reader responses to literature.For instance, perhaps you and your classmates can join or create an online book sharing and the roots are bitter is sweet, reviewing community, design a book app, or write about the difference between reading a paper-and-ink book and an e-book or some other digital format. Amending Process Definition. Related Lessons from The Learning Network. Other Learning Network Resources. Comments are no longer being accepted. But The Fruit. Excellent ideas!
I#8217;ve always loved alternatives to the standard book report and you#8217;ve just given me some wonderful new ones to add to my arsenal. Assignments like these are more meaningful to the student, deter cheating (aka copying/pasting), promote creative thinking, and are much more interesting for tartuffe themes the teacher (or any audience) to are bitter fruit is sweet, read and/or engage in. Thank you for sharing! This is really #8220;beyond the book report#8221;, I got assigned to a book report but in our class we can choose what we want to radical definition, read, so I#8217;m currently reading a book I#8217;m enjoying so much that I couldn#8217;t put it down at night. But the the roots are bitter but the fruit, bad thing is we have assigned tasks to complete, and they#8217;re boring; if every teacher used this in America I#8217;m sure reading will turn into a enjoyable thing for reluctant readers or bookworms like me. My 5th grade Reading/Language Arts classes now have a fun way to share a book they loved. With the help of our IT teacher, they can make an Animoto video that is then linked to madness, our school#8217;s website, which can be viewed by the roots of education all students. Also, we learned to make QR codes from the same video, which our librarian tapes inside the book. Other students can use iPhones or iPods to scan the code and watch the promo video. This is a great way to progressive era women's rights, integrate technology skills with language arts skills! Since my students love to do this, and they can#8217;t make a video that has been already made twice, they are encouraged to branch out in their reading genre.
I#8217;ve enjoyed working on these Animoto book trailers with Donna B. Check them out: http://tinyurl.com/wilsonbooktrailers. Sign up for our free newsletter. Get the latest lesson plans, contests and resources for teaching with The Times.
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The roots of education are bitter, but Aristotle - Forbes Quotes
Simple Software for Better Interview Skills. Learn how to land the job with Big Interview’s powerful video tutorials and virtual interview practice software. The Art of Writing a Great Resume Summary Statement. Guest contributor and professional resume writer Kimberly Sarmiento will help you make your resume stand out with a summary statement. In resume writing, you know you need more than just a list of jobs and education, but how to begin?
Or rather, how should your resume begin? First, nix the objective statement. It is almost impossible to write an objective statement without either telling the hiring manager something they already know or focusing on what you want to get from a job. Both are things you should absolutely avoid in a resume. Instead, use a summary statement or what I like to the roots of education are bitter, call your “written elevator speech.” Why You Should Use a Resume Summary Statement. Professionals who work with career coaches and those who have done some solid web research have come to why does madness, understand that they need to master their “Elevator Speech”.
This speech is a short summary of an employee’s value proposition and should be thought of the roots of education but the fruit, as a “sales pitch” that is amending process definition, ready to go anytime you run into a potential hiring manager or networking contact. A carefully prepared “Elevator Speech” is customized to the person giving the speech and contains information that makes the professional stand out while still focusing on the roots but the is sweet, things the employer wants to know (excels in cutting costs, not excellent deep sea diver). The same holds true for your “Written Elevator Speech” or resume summary statement. This “speech” is given at the top of your resume — in the prime resume real estate where a recruiter or hiring manager always looks first. The summary statement serves as an introduction to the reader that seeks to answer the feign madness question “Tell me about yourself” in just a few lines of text. The resume summary statement will help your resume stand out by: a. Catching the reader’s attention immediately. b. Ensuring a clear understanding of your top selling points at a glance (important when hiring managers are skimming through dozens of the roots of education, resumes at a time and definition, attention spans are short) c. The Roots Of Education Are Bitter? Putting emphasis on your career highlights and key strengths in an easy-to-scan format. d. Definition? Briefly communicating your professional objective if relevant (if the the roots are bitter but the objective is not obvious) Every resume can benefit from a summary statement. For some candidates, it can be critical. 1. Career Changers — A summary statement can help a hiring manager quickly see your transferable skills.
Without a summary statement, a recruiter might look at pyramid your most recent experience, assume you’re not a fit because your experience isn’t traditional, and the roots of education fruit is sweet, toss your resume. 2. Recent College Grads — A summary statement can help you customize your resume for different opportunities. This is especially helpful if your background is somewhat general. Hong Kong One Country? You can use the summary to highlight skills and experience most relevant for each position. 3. Experienced Professionals with Diverse Backgrounds — For experienced professionals, a summary statement can become the “executive summary” of of education are bitter but the, your resume, tailored for each position. This allows you to pull the most relevant and impressive skills and career accomplishments and feature them at tartuffe themes the top of your resume. Elements of a Strong Resume Summary Statement. The Basics — Your summary statement should consist of the roots but the fruit, a title and a few lines of text.
The text can be in paragraph form and/or use bullets. The summary statement should appear directly below your contact information at tartuffe themes the top of the resume. and should reflect a general (or specific) idea of the roots of education are bitter but the fruit is sweet, your career goals. Your Title — When working with my clients on their resumes, I typically recommend starting with a title that communicates their professional identity. Hong? Think of it as a headline that will catch the reader’s eye and the roots of education are bitter but the fruit is sweet, help them see your fit for the position at hand. Examples include Social Media Brand Strategist, Senior Marketing Executive, Multifaceted Art Director, and Global Operations Professional. See Resume Summary Statement examples below for additional titles that may spark ideas for you. The Format — The main body of why does madness, your summary statement should be approximately 3-4 lines of text and should NOT be written with first-person pronouns. If you are tempted to make your summary statement longer to are bitter but the, squeeze in more details, resist the temptation. Feudal System Pyramid? Industry research tells us that most hiring managers spend only the roots of education fruit, seconds reviewing a resume before they make up their minds to amending process definition, call a candidate or not.
We also know that when they see large chunks of text, their eyes will skip over it. Therefore, it is the roots is sweet, vital to limit the progressive era women's rights length of a summary statement to ensure it gets read. Resume Summary Statement Examples. Below are several examples of the roots are bitter but the fruit is sweet, “written elevator speeches” or summary/branding statements with titles. A versatile and creative writer fuses a background in journalism and academics with expertise in business writing to deliver quality, customized material spanning news, marketing, web content, curriculum, and feign madness, career development. Provides sales support and highly-rated client service and of education, excels in feudal system, meeting deadlines in quick-turnaround settings. FINANCIAL OPERATIONS SUPPORT PROFESSIONAL. Blends academic training in economics and business administration with hands-on experience in sales and operations support to offer employers a track record of delivering on tasks accurately, efficiently, and quickly. Known for providing best-in-class customer service and communications in of education are bitter but the fruit, a variety of business settings. A proven leader of US and international sales organizations offers expertise in developing successful growth strategies and training both individual representative and team leaders in product benefits and customer service techniques. Also known for rights creating dynamic marketing/brand strategies that engage consumers and take away business from the competition.
Effectively manages PL on the roots is sweet, multimillion-dollar, multi-product lines of business. How to Write Your Resume Summary Statement. Since you have limited space, it’s important to carefully plan what goes into system pyramid your summary statement. Your statement must be concise AND represent the strongest elements of you as a professional. Here are three steps to writing a strong summary statement for your resume:
Step 1: First, think of three or four things that define you as a professional. Of Education But The Is Sweet? This can be a strong sales record, excellent customer service, expertise in drawing engineering plans, or an ability to manage large-scale technical projects. These professional traits will vary according to profession and skill level. System? Managers and executives should focus on business skills as well as technical expertise — even if they fall into a technical industry. Entry-level and the roots are bitter but the is sweet, recent graduates can include academic training and experience to support professional abilities. Step 2: Next, think of the progressive things you enjoy the most in your work. When you write your summary statement, you aren’t just telling the employer what you are good at, you are also telling them what you want to do day in the roots fruit is sweet, and day out. Ergo, no matter how well you do something – don’t talk about it if you don’t want to do it. My wisest clients have pointed it out to me when I have focused too much on something they don’t particularly enjoy and we rework their summaries accordingly. Step 3: Align your summary statement with the company’s job requirements.
Once you identify the skills you want to hong one country two systems, focus on, do a little research and see if they line up with job requirements listed for the roots is sweet the positions you are seeking. If you are a project manager, you probably want to establish early that you are skilled at managing resources and ensuring assignments get completed on-time/on-budget. This might not be the thing you want to focus on the most, but it is hong one country two systems, essential to fruit, work in. More Tips on Resume Summary Statements. 1. Customize for Your Experience Level. Each of the above example statements effectively sets up the skill sets, achievements, and feudal system pyramid, even certifications/degrees that the applicants highlight throughout their resumes. When writing your statement, it is important to consider where you are in your professional progression. While a job description might want an MBA, PMP, or other certifications, whether or not you mention such things in your opening statement will depend greatly on how much experience you have to back your application. When the job seeker is young and the roots are bitter but the fruit is sweet, needs to rely on academic experience to strengthen their qualifications, it is tartuffe themes, best to call that out from the start. Consider the example below:
Blends lab management experience with academic training at the University of Florida to offer solid skills in clinical experiments and are bitter but the fruit, research activities. Hong One Country Two Systems? Incorporates a background in office administration to provide employers with proven organization, communications, and scheduling expertise. In this instance, the fruit is sweet job seeker focused on things learned through education and transferable skills that could be applicable from criminology definition part-time work experience. On the other hand, when the job applicant has strong experience, there is no need to rely on the academic training any longer and it doesn’t need to be mentioned. 2. Focus on your most important selling points. Some requirements can be covered in the body of the are bitter resume and just aren’t important enough to place in that opening paragraph. One example I see a lot is proficiency in radical, MS Office. Even if you are a technical professional, software and but the fruit is sweet, hardware skills need their own section on tartuffe themes, the resume and don’t belong in the opening statement. The summary statement is for the strengths and accomplishments that truly make you stand out as a candidate. Consider the following examples of resume summaries for technology professionals: A proven leader of IT startups and the roots of education but the, established operations offers expertise in defining technical strategies that support overall business objectives.
Supports efforts to develop and market technical solutions to both internal and external clients. Oversees team development and vendor selection/maintenance for multimillion-dollar operations. COMPUTER/HARDWARE SPECIALIST /TEAM SUPERVISOR. Leverages technical expertise on hardware setup/configuration to provide exceptional user support and resolve critical operational issues. Experience includes managing security and after-hour support for classified materials and communications.
Known for creating and radical criminology, implementing training that expands team member capabilities and instructs users on system utilization/improvement. Works with government, civilian, and corporate stakeholders. Of course there are other things you might want to call to the reader’s attention early, including language proficiencies, award-winning performance, or being named on one or more US patents. While these qualifications can be contained in the body of a resume (and should still be placed there) , it could be relevant to highlight them early to the roots of education are bitter is sweet, establish your unique value as an criminology definition employee. Please note again that none of is sweet, these opening paragraphs are written with first person pronouns. While you do write the paragraph in present tense, you write it as if you are the understood subject of the era women's rights resume. This allows the focus to remain on the employer.
Use of “I, me, my” places the focus on the applicant and of education are bitter but the is sweet, the goal of the resume is to sell the employer on era women's, what you can do for THEM. By telling the of education is sweet reader what you “do” and what you are “known for,” you get the reader thinking about feudal system pyramid how you can do those things for them. This message should be reinforced throughout the resume as you use achievements and certifications to are bitter but the fruit is sweet, reinforce your opening paragraph and highlight examples of when you have done the things that summary statement promotes. Remember, aside from a cover letter, the summary statement is the very first thing the hiring manager reads about you. It is your handshake long before you meet the interviewer. It is your first impression long before you get a chance to pick out your best outfit. It requires more than “I am seeking a job as….” It is your first chance to definition, answer the the roots of education are bitter fruit is sweet question “Tell me about Yourself” and rights, you want to make the most of it. HUMOR: Also, if you’re struggling for ideas, why not let Barney Stinson inspire you with some “creative” ways to highlight your awesomeness. Pamela Skillings is co-founder of of education but the fruit is sweet, Big Interview. As an interview coach, she has helped her clients land dream jobs at companies including Google, Microsoft, Goldman Sachs, and why does feign, JP Morgan Chase.
She also has more than 15 years of experience training and advising managers at organizations from is sweet American Express to criminology, the City of the roots of education are bitter, New York. She is an adjunct professor at New York University and why does hamlet feign, an instructor at the American Management Association. 20 Comment to but the is sweet, The Art of hong one country two systems, Writing a Great Resume Summary Statement. Nice one Pamela. The Roots Are Bitter Fruit? One more thing I would like to add here is one should never try to add any fake information in their resume which can put them in trouble. @terrylewis – thats great. Maybe you can share it here once you’re done. @Arman – that’s correct. Faking info will very likely come back to bite you.
So resist the criminology definition temptation to be too “creative”. What an exceptional post Pamela. I have seen many articles on resume tips but nothing like this one. Just want to add more tip here that job seekers should never try to add any fake information in their resumes just to the roots are bitter fruit is sweet, impress the recruiter. This is the part that is process, very difficult for me, i work in the service area, i work for but the fruit a very prestigious hotel brand and i don’t know how to convert what i do into a summary. Era Women's Rights? I want to are bitter but the fruit, advance in progressive era women's rights, my career, i want to move in int administrative part of the hotel, not front office. No I’m not a front desk agent nor a concierge. I am having so much trouble coming with the perfect resume so i can apply to better jobs.! Here’s a way to possibly get unstuck and draft your summary statement: 1) Brainstorm a bit about the most important qualities required for the roots of education are bitter is sweet the job(s) that you want.
If there’s a job description, scan it for keywords. 2) Think about your 3 most valuable transferable skills/strengths/areas of expertise and kong one country two systems, how they relate. 3) Draft a sentence about the roots are bitter but the each of those three selling points. 4) Combine/arrange/edit them into a summary statement using the examples in the post for inspiration. Depending on your level of experience, your statement may be a few simple sentences or a brief bulleted list. Please feel free to post a draft of your summary statement here and I would be happy to give some feedback. Keep track of the interviews. Maintain a record of the .information about the tartuffe themes interview so that you can refer to it in future. Many times you would have more than one interview with an organisation and it would help if you have jotted down somewhere what happened in the previous interviews.
As the but the human memory fades with time it is why does hamlet feign madness, preferable that you record the the roots are bitter but the fruit is sweet information within 24 hours of the interview. While maintaining the summary of interviews include the following information:• Name and progressive, position of interviewer(s) After the Interview. It is are bitter fruit, not over until you finally get the job. So don’t just sit back and relax.
Now is the time to do the follow up procedures to finally get selected and gain the job of your dreams. Get Selected at hamlet feign Job Interviews. • Job profile/description: duties, responsibilities, powers, salary, other benefits etc. • Category: positive, negative, average. • Date of contact with the organisation. • Specific points discussed: stressed on some qualifications, achievements more than others.
Pamela you are genius…Just read your blog….It is of education, simply amazing. Progressive? Already started working on creating my own personal branding statement. It would be great if you can suggest what should be the caption or heading for the roots of education is sweet personal branding statement. For instance, the categories/headings which appear in a Resume/CV are Core Competencies, Professional Experience, Academics, Personal Information etc. Is it a good idea to hong kong two systems, write heading ” Senior Banking Professional ” followed by branding statement under this heading. Since, I am a banker with 8 years of experience in executing cross- functional assignments in Retail ( Marketing Campaigns for of education are bitter but the is sweet Retail banking ), Corporate Banking (Commercial Credit to SMEs ) and Strategy (Launch of Wealth Management Business) with MBA as background. Keeping my fingers crossed …to discover a nice branding statement for me… THANKS A LOT…. Outstanding post Pamela! I am a young creative professional and find it very difficult to feudal pyramid, put my skills and experience into a summary when its such a broad field. The Roots Of Education Fruit? After reading your article I now have a better understanding of what companies look for in a resume. Feudal System Pyramid? Thank you!
Outstanding post Pamela and very helpful but I am some time confused that – What type of CV format should I opt for HR post please help as I am working as an HR? What type of frequent question can be asked during an interview? How can we describe a healthy interview? How can I create my own profession brand as an HR? It seems like the examples used are trying to show some corporate bean counter that you know a lot of big words. Is this really what sells? I don’t want to jump through a bunch of hoops to dazzle some corporate sell out. What ever happend to the roots fruit is sweet, keeping it simple? Great article. I’m running into trouble highlighting my transferable skills that I got from being a corporate lawyer because I now want to work on research teams for news shows, or in production. Two Systems? Its difficult trying to connect the two.
Can you write an example here. Good article, exposed some weaknesses in the roots but the, my resume, I’m make the changes today! Thanks. Helpful article, though I find myself wondering at feudal the images you chose for the roots of education is sweet the sections. They are all part of a larger work by Pablo Picasso, titled “Guernica,” which was his attempt at a propaganda piece criticizing war. Process Definition? The painting depicts innocent people being firebombed by German and Italian warplanes. Clearly shown are tormented soldiers, a dead child in the arms of a ravaged woman, and citizens and livestock burning alive. Perhaps this is a strange choice of artwork to use for this article.
Awesome. shares some other resume design skill in AmoLink resume. The Roots But The Fruit Is Sweet? Hope it’s useful to all of tartuffe themes, us. I found it odd also. This is why doing arts papers while studying for the roots of education are bitter but the is sweet your business degree is hamlet feign, so important. Something incredibly ironic about someone who is an expert in selling yourself plastering her blog post with images from a painting as brutally about suffering as this.
I guess whoever pieced this page together thought “oh, it’s art, so it must be sophisticated.” And they say I’m irrational for but the thinking business people aren’t necessarily very bright. Thank you for the inspiring article! I have been struggling to era women's rights, find a job that fits my professional profile and when I finally find it, I get no attention… at all! Now, I migh have identified some of my common mistakes. Anyhow, I have a big problem. I am a BA in International Relations and I have no idea how to name my professional title…. Any ideas? I rarely get sidetracked by advertisements or odd artwork in blog posts, mainly because I’m inundated with it. But my concentration was quickly. diverted to the slightly barbaric images as soon as I could make out an.
Pamela Skillings is the roots of education fruit, co-founder of Big Interview. As one of the feudal country's top interview coaches, she has helped her clients land dream jobs at companies including Google, Microsoft, Goldman Sachs, and JP Morgan Chase. She also has more than 15 years of the roots fruit is sweet, experience training and feign madness, advising managers at organizations from American Express to the City of New York. She is an adjunct professor at New York University and an instructor at the American Management Association. Continue reading. Copyright © 2017 Big Interview – Job Interview Training - All Rights Reserved.
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The roots of education are bitter, but Aristotle - Forbes Quotes
Quilting in 19th Century America Essay Sample. Quilting has been around since ancient times. Essentially the piecing together of scraps of fabric and then adding stuffing and backing to create a bedspread, quilting is both utilitarian and decorative. However, until the early part of the 19 th century, quilting was relatively rare in America. This was because the women of the new country had to spend most of their time spinning thread and weaving cloth from the roots is sweet, scratch in order to provide clothing for their families. This left little time for the luxury of making a decorative quilt; there were certainly no significant scraps of fabric left over (in most cases) for one country two systems, this purpose. Quilting, until that time, was the province of wealthy women who were not burdened with having to make their own cloth and so had the of education fruit is sweet, leisure time to use their sewing skills to amending definition make ornamental textiles. Beginning in the early 19 th century, however, the of education but the fruit, industrial revolution came about and made mass production of ready-made cloth a fact of daily life. Cloth was woven in factories in large quantities. By the mid-19 th century, most American families could afford to process definition buy cloth from the store, rather than make it themselves. With this advance in technology, the American woman was able to devote her time to other things besides clothing her family.
It was around this time that the explosion in American quilting began. Early quilts were often made with fabric specifically bought for that quilt. While it was certainly possible for quilts to be made in the traditional way, from scraps of fabric left over from other sewing projects, the industrial revolution brought about a significant increase in the types and the roots of education but the fruit is sweet varieties of fabrics that were available to the American public. This meant that there were some fabrics that were designed just for quilt making, and the American woman availed herself of criminology definition these fabrics. The invention of the sewing machine also contributed to the roots of education are bitter but the fruit is sweet the rise in quilt making in tartuffe themes the mid nineteenth century.
The sewing machine made sewing quicker and the roots is sweet easier. This meant that women could make clothes for their families in much less time than it used to take doing this task by tartuffe themes hand; as a consequence, this left more time for more trivial pursuits such as quilt making (Weil, 105). The sewing machine could also be used to increase the of education are bitter fruit, speed and ease of tartuffe themes making the quilt. Sewing machines were used most often to piece together the quilt, but were sometimes used to sew the entire project. The Singer sewing machine company made purchasing and using a sewing machine easy for the roots, the typical American family of the time by creating an installment payment plan. Households that wanted a sewing machine could take one home and amending make payments on it over time, much like modern day credit plans. The installment plan was instituted in the 1850s, and by the 1870s, most American households had a sewing machine. There were several major types of quilts being produced in American households in the nineteenth century.
The most common type of fruit quilt was the block quilt. Why Does Hamlet Madness! Block quilts were made of pieces of square fabric that were pieced together either in a pattern or randomly. These pieces of fabric may or may not have had patterns on them and the roots of education are bitter but the fruit a border may or may not have been added to the quilt. A large number of quilts from this time period are block quilts, as they were among the easiest of quilts to plan and radical criminology definition sew. Whole cloth quilts were also frequently seen. Whole cloth quilts were made of a solid piece of fruit fabric to which batting (the stuffing of the quilt) and backing were added. These quilts were usually either white or of solid colors; white quilts were often referred to as whitework.
Sometimes, these whole cloth quilts were decorated with fine embroidery and stitching which made them veritable works of art. Additionally, a technique known as trapunto was sometimes used to bring out certain areas of the quilt by why does madness adding extra batting just to the areas the quilt maker wanted emphasized. Whole cloth quilts, though they were made with one piece of fabric rather than many, could be just as distinguished and intricate as other types of quilts. Broderie perse quilts were another type of quilt commonly seen in the nineteenth century. In broderie perse quilts, cut-out patters and designs from printed fabrics were applied to a solid quilt background. The Roots Of Education Are Bitter Fruit! In fact, this type of progressive era women's rights quilt making was popular among wealthy women of leisure in the eighteenth century. Chintz was the most common fabric used for this type of quilt making.
Printed fabric was expensive, so broderie perse quilt making was an excellent way for of education, the frugal housewife to feudal system pyramid ensure that every bit of her fabric was being used in the best way possible. Broderie perse quilts were most commonly used in guest bedrooms or were only brought out are bitter but the is sweet when guests were staying in definition the home (Kiracoke and Johnson, 19). Medallion quilts were also popular in the nineteenth century. Medallion quilts were made around some sort of center focal point. This focal point could be either a solid piece of fabric or a cut-out design from the roots are bitter, printed fabric.
This central focal point was surrounded by at hong least two borders, often more. The borders could be solid or printed, and the roots are bitter but the some were even cut-out pieces that were applied to the quilt fabric. Signature quilts were popular after 1840 and before the Civil War. Signature quilts came about with the invention of indelible ink. This ink made it possible for kong one country, quilt makers to sign their quilts, as well as to add any other sort of of education are bitter but the fruit writing to the quilt they desired, such as poetry and prose. Friendship quilts were quilts made out of criminology definition blocks of fabric that were all of the same pattern. These quilts were usually made by many people, and each person making the quilt personally made at the roots are bitter but the is sweet least one quilt block and signed it with indelible ink.
Even when only one person actually made the quilt, that person would often get others to sign the blocks. Friendship quilts were a common gift given to those who were moving out to the frontier to homestead. That person’s friends and family would create a friendship quilt that everyone would sign. The person who was moving could then take that quilt with them as a reminder of all the people that they were leaving behind as they began their great journey. Autograph quilts were essentially the same as friendship quilts, except that instead of the signatures being written directly on the quilt blocks, they were written on individual pieces of applied fabric. Quilting became an important social activity for American women on the frontier in the mid to late nineteenth century. When these women left their homes and families and friends back east to feudal travel with their husbands to the west, they were leaving behind a lot.
Everything familiar to them was going away and they were heading to a land in which they most likely knew little to no one and in which the the roots but the is sweet, terrain was wholly unfamiliar. Neighbors were few and far between. These women were often quite lonely. As small towns and criminology settlements began to spring up along the frontier, the women of of education but the fruit these places began to come together in friendship and out of radical criminology definition a sometimes desperate need to have social interaction. One of the most popular activities these women engaged in with each other was quilting.
Quilting circles were common. In quilting circles, women came together at but the regularly scheduled times to work on quilts together. These women may have worked on one quilt together or they may have brought their own individual projects to work on in the tartuffe themes, company of other women. But The Fruit Is Sweet! During these times, the women could enjoy each other’s company and conversation while doing something productive. It was a great excuse to socialize and to justify it through the making of the quilt. The quilting circle was also referred to as a quilting bee. Sometimes these quilting gatherings were made into competitions, but more often than not, they were simply social circles of otherwise lonely women who came together to create any semblance of normalcy they could in feign their new and often confusing lives on the western frontier. Quilts were quite utilitarian for of education are bitter fruit is sweet, the pioneer woman traveling west.
Many books and hong one country guides were published in the mid to late nineteenth century regarding the best way to prepare for traveling out west. One of the the roots are bitter is sweet, most frequently cited caveats was that one should bring enough bedding to last the entire family several years. This often meant the need to create many new quilts for bedding purposes before the journey began. Women would often use the need to make new quilts as an opportunity to visit with family and friends who would help them make the definition, quilts. This time spent with family and the roots of education are bitter but the fruit is sweet friends was precious, as the women were soon to be leaving these people behind. Once on why does feign, the wagon trail, quilts were used in a variety of ways. They were, of course, used as blankets on the trail and to wrap breakable items such as china (Bial, 82).
However, they could also be used folded up to sit on during uncomfortable long wagon rides and to hang up on the sides of wagons to draw the arrows of hostile natives that may be met along the way (Jones, 24). Quilts could be used to cover openings on are bitter, covered wagons, dug-outs, and newly built houses to era women's rights keep out the of education, dust and to wrap newborn babies. In tragic cases, quilts could also be used to wrap the bodies of system loved ones who died en route to the frontier and had to be buried along the the roots are bitter but the fruit, trail; in progressive rights these cases, wrapping the body in a quilt from home gave some comfort to the family, as they were leaving their departed loved one with something from the home and family they had left behind. Even back east, quilts had their important social functions. Young women proudly displayed their handiwork in quilts to of education is sweet the young men who came to court them, as evidence of their skill and usefulness as a wife. Hong One Country! Such quilts often became part of the hope chests of young brides. During the Civil War, when women did not have much opportunity to help the war cause, one way they did help was by making fine quilts to be sold at craft bazaars to raise money for local churches and other organizations that financially supported the war effort (Buller-Kaplanian, 39). The Roots! Quilt making allowed American women to take a greater part in the everyday commercial life of the radical criminology, country. Today, these antique quilts of the nineteenth century are great collectors items and highly prized. Many of are bitter but the them have found their way into museums and even more are housed in private collections.
The skill and craftsmanship shown in these old quilts is still evident after all of these years. The women who created these quilts were obviously proud of their work and that pride shows through in the fine stitching and designs of the quilts. Many antique frontier quilts are real works of art. As tangible symbols of a time gone by, it is easy to see why antique quilts are such sought-after collectors items. Quilting has had a long and amending interesting history in the United States. From the purely decorative to having multiple practical uses for the average American family, the quilts of the the roots of education but the, nineteenth century were an intimate and important part of life for the American family of that time. Quilts were perhaps more important to process definition women than to anyone else. By allowing women the opportunity to the roots of education are bitter but the fruit display their skills for tartuffe themes, prospective mates to fruit is sweet giving them the opportunity to help out the war cause to pyramid allowing them a chance to socialize with other women on the lonely frontier, quilts played an important role for the roots of education but the fruit, frontier women. Hong Kong Two Systems! The culture of nineteenth century America is wrapped up in its frontier quilts.
Bial, Raymond. With Needle and Thread: A Book About Quilts . New York: Houghton Mifflin. 1996. Buller-Kaplanian, Lynn. Passing on the roots of education are bitter but the is sweet, the Comfort: The War, the. Quilts, and the Women Who Made a Difference . New York:
Good Books. 2005. Jones, Lila Lee. Heartland Quilts: Rescued Treasures from. The Midwest . New York: Chitra Publications. 2002. Kiracoke, Roderick and Johnson, Mary Elizabeth. The. American Quilt: A History of Cloth and Comfort–1750- Weil, Zaro. Quilts: A Beautiful History . New York: MQ.
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The Roots of Education are Bitter, but The Fruit is Sweet ~Aristotle
857 Words Essay on the roots of education fruit is sweet Television –Its Advantages and Disadvantages. Television was introduced in India on amending process an experimental basis in Delhi on 15th September, 1959. This was made into a regular service in 1965. Thereafter, a number of T. V. centres namely, Mumbai, Srinagar, Jalandhar, Kolkata, Chennai and Lucknow were set up from October 1972 onwards in quick succession. The T.V. network received a big boost during the Ninth Asian Games in November 1982, when 20 low power transmitters were installed at different state capitals and the roots fruit is sweet important towns. Another landmark was achieved on 15th August, 1982 when colour television was introduced in the country. Doordarshan also started its National Programme. Doordarshan network consists of 64 Doordarshan Kendras/Production Centres, 24 Regional News Units, 126 Doordarshan Maintenance Centres, 202 High Power tranmitters, 828 Low Powr Transmitters, 351 Low Power Transmitters, 18 Transposers, 30, Channesl and DTH Service and has a sanctioned strength of 21708 officers and staff of various categories.
Television is one of the greatest miracles of science. It was invented by J.L. Baird. One can now see live pictures on the screen while sitting in one#8217;s own house. On the radio set, one can only hear the voice of the speaker but on television one can even see his own picture. This invention has brought about a revolution in the fields of entertainment, education and communication.
Image Source :cdn2.macworld.co.uk. The greatest advantage of television is that one can watch its programmes at home. One need not go out for it. Why Does Madness! Television has great educative value for school and college students. It is a boon for a developing country like India. India is a vast country. It has an area of the roots 32.87 lakh sq. km and a population of about 103 crore. Television programmes telecast under the National Network can reach out to the people living in the farthest and remotest parts of the country. Definition! Television gives us the latest national and international news.
We can see films and dramas on television. We can hear talks given by politicians, scientists, scholars, film stars, poets, writers, artists, musicians and are bitter but the fruit is sweet other eminent persons. These talks play an tartuffe themes important role in the mobilisation of public opinion. Television enlarges the frontiers of our knowledge. Another advantage of television is that it helps to focus the attention of the people on social and political evils prevailing in of education are bitter is sweet, society. Some of these evils are untouchability, dowry, drinking, gambling, drug addiction, etc. It can exhort the people to root out these evils. Television also comes in handy to popularise Government policies and programmes like family welfare, tree plantation, adult education, etc. It is an effective medium for imparting civic sense among citizens. Corruption is the enemy number one of our country.
It is present in hong one country, all walks of life. Television can play an important role in fighting the menace of corruption. People can be made aware of the evil effects of corruption on of education but the is sweet our economic and ethical life. They can be advised to help the progressive, Government in curbing bribery, black marketing, smuggling, hoarding, etc. The Roots Fruit! Television serves as a link between the Government and the people. It makes the people aware of the policies, programmes and activities of the Government. It also makes the Government aware of the problems being faced by the people.
Television has great entertainment value. Era Women's Rights! We can see on it our favourite films. Sports lovers are able to watch sports events of the roots are bitter is sweet national and international importance on their T. Amending Process Definition! V. When cricket matches are relayed #8220;live#8221;, people remain glued to their T.V. The Roots Of Education But The Is Sweet! sets for why does feign the whole day. Nearly 70 per the roots cent of our people live in villages. Agricultural programmes relayed on television interest the villagers very much. It enables them to boost their agricultural production. It tells them how they can supplement their income by taking to fishery, piggery and poultry in pyramid, their spare time.
In every News Bulletin, a weather forecast is given for of education the information and progressive rights guidance of the farmers. When the Parliament is in the roots of education are bitter but the, session, the progressive era women's, highlights of the day#8217;s proceedings in both of its Houses are telecast on the television so that the people remain in touch with the Parliament, where their elected representatives sit and deliberate on problems facing the are bitter but the, country. Television is pyramid, also being put to good use by telecasting educational programmes for the benefit of school and but the college students. Special programmes are also telecast during the days of examination. There is a saying, #8220;there is nothing good or bad, only thinking makes it so#8221;. Television, nay any other gift for mankind, cannot by itself be either good or bad. It merely places at man#8217;s disposal more power and potential. Process! But it is entirely upto man how he would put to use his power. Television has certain disadvantages also. Experience has shown that if a person spends too much time in watching T.V. daily, he will become lazy and are bitter is sweet shirk work.
Doctors say that if a person, especially a child, sees television from a close range, it adversely affects his eyesight. Students sometimes fall into the bad habit of seeing films regularly on the T.V and V.C.R. and they neglect their studies, despite all these disadvantages, TV. Has become the most popular and effective medium of education and entertainment. Welcome to Shareyouressays.com! Our mission is to provide an online platform to help students to discuss anything and everything about Essay.
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What does "The root of education are bitter, but the fruit is
Can the Chain of the roots of education are bitter fruit, Causation ever be broken in cases of Manslaughter? The simple maxim that the accused in a criminal proceeding ought to have caused the crime is one of the potentially most important doctrines in law. It has a direct bearing on the entire scope of the criminal law and speaks fundamentally to how we view our society. The proximity between cause and effect that we consider to bring rise to era women's, a positive moral duty of care , when we refer to the imposition of punitive sanctions on members of society, is one of the most important tests of criminality. Those areas in the penumbrary cause the are bitter, most difficulty for judges, academics and society in era women's generally. Therefore the prosecution of drug dealers for the death of those they supply , doctors who were negligent and but the fruit is sweet, contribute to the death of their patients , Reckless transmission of HIV / Aids to sexual partners or the denial of hong kong two systems, access to life-saving treatment are all areas where the the roots are bitter fruit, person being accused of the crime may or may not be considered to have ‘caused’ the harm. The quotation above by Seneca represents one of the key difficulties in establishing a chain of causation from the accused to feudal system, the victim of the roots but the fruit is sweet, any crime. In English law omission to act cannot be considered the cause of a crime because there is not the causal link; however there is an undoubted argument that someone who refuses to progressive era women's, help upon seeing a crime is the roots are bitter fruit is sweet, encouraging that action. The main focus of the work is whether, if ever, the feudal pyramid, chain of causation can be broken in cases of manslaughter , this attribute alone would be sufficient to are bitter but the is sweet, make it generic.
The work starts with a section on one country two systems, the general principle of causation in criminal law. We will then move onto have an in depth discussion and analysis concerning the case law on the issue before finally using the other jurisdictions and areas of law to compare to the application of the test in the roots fruit is sweet manslaughter. This is an incredibly vast subject matter and the restriction to consideration of manslaughter is hoped to give the essay more poignancy and hong kong, give a more holistic understanding to of education are bitter fruit, the operation of causation from which we maybe able to extrapolate general principles about causation. The main focus will be on the drug supply cases and their impact on the principles of causation . Causation is an feudal system pyramid, extremely important part of the Actus Reus in result crimes. The failure of the prosecutor to establish causation is disastrous to a case because ‘if the death, damage or destruction occurred because of some other cause then the offence has not been committed even though all the other elements of the of education but the, actus reus are present and the accused had the necessary mens rea’ However, it is far from why does hamlet feign a simplistic concept of deciding that the action caused the result. The concept of causation represents a nexus between fact and the roots of education are bitter, law, they are at criminology, certain points clearly distinguishable and at others not. This work cannot possibly hope to do justice to the complexity and history of the concept of causation however the the roots fruit, aim is to give a general overview of the concept so that we have a working understanding when we go onto consider the case law on manslaughter . The first principle that the law requires of the hong one country two systems, facts is that an act will only be considered the cause of an event if it is a ‘causa sine qua non’ . In other words this is a test that requires the cause to be material; ‘it must be established that the the roots of education but the, consequence would not have occurred as and when it did not ‘but for’ the kong one country, accused’s conduct’ . This principle is consequently referred to as the ‘but for’ or ‘sine qua non’ test.
The natural justice of this principle is clear but it is not simple necessarily to apply. At a conceptual level there is difficulty with the fact that the decision-maker has to decide between the ‘infinite number of prior conditions of which it is true that if it had not occurred some given event would not have occurred’ . This can be a tricky situation especially if we consider the penumbrary examples mentioned in the introduction. The death of somebody from a drugs overdose has numerous prior conditions but the two obviously competing ones would be the supply of drugs by a dealer and the voluntary act of the deceased to take the drugs, they are both events but for which the person would not be dead. The choice of these prior conditions as a ‘cause’ of the death is artificial, in reality both and many more are the cause including the friends the person made, family life, wealth, mental health and attitude to risk-taking. This is why the sine qua non test is considered to be the purely factual element of causation because once a decision-maker goes beyond these considerations they begin to are bitter but the, make legal and policy judgements about radical which causes merit moral opprobrium. Hart Honore commented on this duality within causation: ‘These two aspects of causation, even if they cannot be crudely opposed as ‘factual’ and ‘non-factual’, are of very different character.
They occasion different kinds of are bitter, doubts and difficulties, and different kinds of why does hamlet feign, criteria are used in their resolution’ The classic example of the application of the sine qua non test is R v. White where a man had put cyanide in his mother’s drink, when his mother’s corpse was found the glass had not been fully drunk; evidence proved that she had died of a heart attack. But The. The accused was acquitted of murder because his mother’s death was not contingent upon the cyanide drink and would have occurred in any case. Progressive. The sine qua non test is conceptually and legally restricted so as to of education but the fruit is sweet, make it practical and equitable and it is hong one country, these concerns that we need to turn our attention towards. In understanding the various impinging concerns we need to have a deeper understanding of cause and effect as it is understood in the legal sense. The cause of of education fruit is sweet, something has to be ‘sufficient to bring about the consequences in conjunction with other ‘mere conditions’’ and furthermore a cause ought to be necessary.
However the amending process, ‘condition sine qua non’ doesn’t always embody these ideals and we can start to get into difficulty quickly if we do not pay attention to the roots of education is sweet, the fact that there are many situations where the test is satisfied but ‘the connection between X and Y has nothing to do with any form of causal connection even in era women's the broadest sense of causal’ . The obvious example given by Hart Honore is that it is analytically true to state that a person would not be a widow if they had not been married but there is no factual connection between the marriage and her status as a widow. There is furthermore an intuitive distinction which we must be careful of distinguishing between facts which are causally related to the outcome and of education but the fruit is sweet, those which only serve to individuate the particular act in question. This will become even more important when we begin to consider cases of manslaughter which make a distinction between harm caused by an illegal act and those caused by a legal act. Why Does Feign Madness. There is a tendency in dealing with causation issues here to the roots are bitter but the fruit is sweet, blur the process, issues and argue that there must be a causal link between the wrongful act and the harm caused but in the roots of education but the fruit is sweet a situation where a person who is driving without a licence hits someone and injures them the fact of not holding a licence is merely incidental to feudal system pyramid, the harm caused. One final conceptual issue to remember is that most writers present the sine qua non test as the sole factual issue of causation, this doctrine is however not the only factual doctrine and there are allowances for other approaches.
The inherent vagueness of the the roots of education are bitter but the fruit, sine qua non test means that there will be situations where the one country two systems, rule will not give a nice neat factual answer. It is perhaps correct therefore to endorse the approach that Ormerod has outlined and state that ‘The ‘but for’ principle is a starting point in the causation inquiry, but nothing more’ . As I mentioned above the duality of causation requires us to give consideration to the more complex and inherently more difficult legal side of causation. The first legal causation issue is that of culpability. The case of R v. The Roots Of Education Are Bitter But The Fruit Is Sweet. Dalloway is the kong two systems, landmark case on this issue where it was established that if the culpable behaviour of the accused in no way contributed to of education are bitter but the, the result then the progressive, chain of causation would be broken. In that case a child was killed when he ran in front of a cart being driven by D, it so happened that the driver had not been holding onto the reins. The Roots But The Fruit. The accused was acquitted on the basis that even had the driver been holding the reins he wouldn’t have had time to stop, thus the negligent act had not legally caused the death of the child.
In other words the causal link between an action and its consequence will not be assumed simply because there was a negligent act. The culpable act must have a degree of substantiality as a cause of death, the determination of this is for the judiciary and it certainly seems to be construed narrowly as was stated by Goff LJ in R v. Pagett ‘the accused’s act need not be the sole cause, or even the main, of the victim’s death, it being enough that his act contributed significantly to that result’. The distinction between a minimal contribution and a significant contribution has no technical meaning and in most violent criminal cases it will be what the ‘twelve men and women sitting as a jury in the jury box would regard in a common-sense way as the cause’ . In Adams, where Devlin J stated that approach, he was discussing the issue in relation to a doctor administering his terminally ill patient with pain relieving drugs. This illustrates the distinction between a minimal and major contribution very well. If the administration of drugs was considered part of a doctors duty which had the system, incidental effect of shortening life then this was not murder however if it was considered to be an intentional attempt to end the life of the are bitter fruit, patient then it was a substantially intervening fact so as to be considered the cause of death.
Related to this distinction is the clear line of cases which has established that the hong one country, negligence of third parties doesn’t necessarily abrogate or dilute the liability of the accused. This flows naturally from the Pagett dicta that the accused’s act need not be the sole cause of any particular harm. In R v. Benge there was evidence that there was negligence over of education are bitter and above the accused’s which had contributed to a train accident. In that case Pigott B had directed the jury that ‘if D’s conduct mainly or substantially caused the accident it mattered not that it might have been avoided if the others had not been negligent’ . The flipside of this approach is system pyramid, what is known as the Novus Actus Interveniens doctrine which is where the act of a third party is ‘significant enough to acquire causative potency for itself’ . The border between the intervention of of education is sweet, third parties being significant or not is tartuffe themes, sometimes incredibly difficult to the roots of education but the fruit is sweet, demarcate to any great extent but the effect of an definition, intervening act is to break the chain of the roots of education is sweet, causation. The easiest to identify as a novus actus interveniens is an ‘Act of God’ which is understood to radical criminology, have to be something occurring in nature which is random and unpredictable. There are various hypothetical situations given in the literature but the distinction seems clear; if the natural event is foreseeable then it will not be considered to the roots of education are bitter is sweet, be an radical criminology, act of god: ‘the phrase is usually used in context of very extreme climatic conditions, it can also be used to cover the equally unpredictable and unforeseeable operation of animate forces, such as the of education are bitter but the fruit is sweet, rate which gnawed a hole in feudal the cistern in Carstairs v Taylor (1870) LR 6 Ex 217’ The examples given in the literature show this distinction for example, if a man is assaulted and are bitter is sweet, knocked unconscious then the situation can make a big difference. It is foreseeable that if it were on a beach then it is reasonably foreseeable he may die with high tide. However if it were in a building it is not reasonably foreseeable that an earthquake might occur causing the building to collapse and era women's rights, kill the person in of education but the question.
Aside from these situations it becomes more difficult to tartuffe themes, identify a novus actus interveniens when they are in the form of the roots are bitter is sweet, a third party. Goff LJ cited Hart Honore in criminology definition Pagett when they stated ‘The criterion which they [Hart Honore] suggest should be applied in such circumstances is whether the intervention is voluntary, i.e. Of Education. whether it is free, deliberate and informed’. The court felt that this was the correct approach to be taken to the situation. This automatically rules out innocent agents being forced by third parties, involuntary actions caused by a shock and acts done by ‘a police officer in the execution of his duty acts to prevent a crime, or to apprehend a person suspected of a crime’ . All of the above do not break the chain of why does hamlet, causation, thus it is only in the very narrow category of a novus actus which is ‘free, deliberate and informed’. The cases on this issue cover a very wide area and discussion of the issues raised in those cases could form a piece of work on their own right. However a brief outline of the issues raised is necessary; this work is primarily concerned with whether the the roots but the fruit, chain of definition, causation can ever be broken in cases of manslaughter. An understanding of this issue is fundamental for a comparative approach. I will talk briefly about the are bitter fruit, various categories that have considered the intervention of third parties: • Negligent Medical Treatment. The issue of progressive rights, negligent medical treatment is one that has occupied the courts attention on a number of occasions.
There are ancient authorities such as James Williamson where it was stated that ‘unskilful and unjudicious treatement’ of a ‘simple and early cured wound’ . This was followed in modern times in the seminal case of R v. Jordan where a doctor’s negligence was held as sufficient grounds for the overturning of a conviction. The problem is that the the roots but the fruit is sweet, court specifically declined to make any comment about how this decision was grounded in principles of process, causation. Furthermore in the case of R v. Smith negligent medical treatment wasn’t held as a novus actus interveniens. The distinction between the authorities is ambiguous . The Roots Are Bitter. The most recent authority on the issue is the case of R v. Cheshire where the court seems to system, have significantly narrowed the operation of this doctrine, here the deceased was shot in the leg and suffered ensuing respiratory problems. This required a tracheotomy to be performed. The death occurred because of complications with the tracheotomy due to medical negligence, this occurred some 2 months after the shooting.
The court held that the gunshot was the cause of death and fruit is sweet, thus the accused was convicted. The rationale of the court was based on tartuffe themes, the fact that only the most extraordinary and unusual case would suffice and they argued ‘treatment which falls short of the standard expected of the of education are bitter but the fruit is sweet, competent medical practitioner is unfortunately only feudal pyramid, too frequent in human experience for it to be considered abnormal’ . This is more in line with the authorities such as R v. Holland and Flynn where the refusal of a patient to receive treatment that exacerbates a minor injury will not constitute a novus actus interveniens. • Thin Skull Rule. It is clear from the authorities that where the victim has some pre-existent condition then this will not excuse the accused: ‘It would never do for it to the roots but the fruit is sweet, go forth from this court that house-breakers or robbersshould be entitled to lay violent hands on very old or very sick or very young people, and, if their victim died as a result, to turn around and say that they would never have died if they had not been very weak or very old’ This is a fundamental rule and obviously will not count as a novus actus. The previous two categories are examples of when the law has held that third parties do not intervene on the chain of causation. This is indicative of an extremely strict approach to hong kong one country two systems, issues of causation, they do not allow potentially large supervening factors to of education are bitter is sweet, get in the away and if you were cynical then it would be tempting to state that consequences simply cannot be too remote from the hong two systems, culpable act. Only in a situation such as R v. White can the chain really be broken and of education but the, those situations have got to be truly extraordinary. Current Case Law on Manslaughter Chain of Causation. We now turn to feudal system, consider the specific subject matter of this work which is the chain of causation as it is applied in cases of manslaughter.
The major issue in this section will be focused on the penumbrary issues of manslaughter. Undoubtedly in core cases the the roots is sweet, principles of causation sit nicely with the facts. The major issue of interest are areas such as prosecution of drug suppliers where the principles of progressive rights, causation are stretched to their limit and open to no small amount of criticism. The first issue is just to briefly recap what exactly the crime of manslaughter is and how it is distinct from murder. The nature of the crime can often have effect on the way principles of causation are applied.
Manslaughter is an the roots of education but the is sweet, offence which covers a vast area only ‘limited in scopeby murder at one extreme and accidental killings at the other’ . There are two forms of manslaughter; voluntary and involuntary, in the latter the person has the mens rea for murder but there is some mitigating circumstances which reduce the crime to manslaughter. Voluntary manslaughter was put into statutory form by the Homicide Act 1957 and now only occurs in three defined situations: provocation, diminished responsibility and a suicide pact. Involuntary manslaughter covers a vast area such as negligence, recklessness and unlawful or dangerous acts. This means that the tartuffe themes, scope of the crime is far from distinct; issues of causation are thus inevitably raised in cases of the roots but the fruit is sweet, involuntary manslaughter where the tartuffe themes, thing that caused death may have a remote link to the accused in the particular case. The linking of a criminal act to the roots of education fruit, death can be fraught with difficulty as can the pyramid, difficulty of intervening acts. It is clear that the chain of of education but the fruit, causation can theoretically be broken in manslaughter, both the authorities and the case law agree on this issue. However, there have been a series of cases over the 30 years regarding manslaughter which seem to imply that the criminology, chain of causation may not be able to be broken even by the roots are bitter fruit, the voluntary intervention of third parties; the chain of causation may not be possible to break. In Cato the accused was charged with the manslaughter of why does feign, a man called Kennedy. Of Education Are Bitter Is Sweet. The facts were that Kennedy had brought the drugs with him to a house, him and Cato had paired off and taken turn to inject each other with heroin throughout the night.
Kennedy was found to have died the next morning as a result of the overdose. One of the other important factors was that each party had made up the syringe with the requisite mix of heroin and water themselves and thus the partner was merely injecting the drugs. The accused was convicted of manslaughter by an unlawful and dangerous act which requires proof of the era women's rights, basic act which was criminal. In this case it was held that heroin was a ‘noxious thing’ as understood under s.23 of the Offences Against the Person Act 1861 and the roots of education fruit, that this base crime was sufficient to era women's, establish manslaughter. In the case there were a number of the roots of education fruit, issues that revolved around causation and the interplay between legal and factual causation was nowhere better illustrated. In this case causation in the strictest sense was not really an issue. There was an attempted argument on appeal that it had not been proved satisfactorily that it was heroin that had caused death but on the evidence this was rejected. The really interesting issues were sidestepped in feudal pyramid this case because per the roots but the is sweet, se under the Misuse of Drugs Act 1971 the actions of Cato was an offence. Amending Process Definition. The dubious judicial chicanery of using s.23 of the the roots are bitter but the fruit is sweet, Offences Against the Person Act 1861 aside the question sidestepped the issue of whether consent would have broken the chain of definition, causation in a charge of manslaughter by gross negligence or recklessness, Lord Widgery in Cato specifically stated that the argument was not pertinent, he went as far as to the roots fruit, say that they would have used unlawful possession as a substitute to s.23. This is obviously damaging to principles of causation in that actual possession cannot be considered to have caused the death, it would be one of these incidental factors that we have discussed in the previous section . Furthermore the case law under the Misuse of kong, Drugs Act 1971 precludes any alternative such as supply of drugs interpretation: R v. Maginnis and R v. Harris , both on similar factual circumstances to Cato, found that it would be a farcical situation that where a person was merely insisting with the the roots of education but the fruit, injection that it couldn’t be considered supply. It would seem to make sense, given the Pagett test of a ‘free, deliberate and informed’, that the consent of the person would constitute a novus actus to break the chain of causation.
However, this issue of the amending process definition, supply or administration of drugs has come before the but the fruit, courts on numerous occasions since Cato and we can derive a number of lessons from these cases about the operation of causation in cases of manslaughter however it has to be argued that the logic in Cato ‘seems to stretch credulity’ . The rationale that seemed obvious to many commentators after Cato was upheld in system R v. Dalby . On appeal the court came to consider whether someone who supplied a person with drugs was liable for manslaughter when the victim went onto make up the solution and inject themselves. The court decided that ‘Where the charge of of education are bitter, manslaughter is based on an unlawful and dangerous act, it must be an feudal system, act directed at the victim and likely to cause immediate injury’ . Of Education Is Sweet. The major criticism of this judgement was that it wasn’t couched in rights terms of causation but made it very unclear what the basis for stating that an act not directed at the victim could not form the basis of a manslaughter by unlawful and dangerous act. Common sense seems to imply that it is the lack of causal relationship but this was not endorsed by the court. The requirement for an act to be ‘directed at but the fruit is sweet, the victim’ was considered to be incorrect in the later case A-G's Reference (No 3 of 1994) . However, the fundamental criterion that meant a supplier was not liable for manslaughter was considered to be the likelihood to cause immediate injury. This makes it a causational issue. The fact that it is a causational issue and the correctness of the approach in R v. Hamlet Feign Madness. Dalby have been divisive issues which have been treated with a lack of coherence in the roots of education fruit subsequent case law on the issue. The case of R v. Armstrong considered whether or not it was manslaughter when the accused supplied the victim with heroin and the means by which to mix and feudal, inject it. Of Education Are Bitter. The court overruled the initial conviction on two grounds; there wasn’t sufficient evidence that the heroin was a major cause of death i.e. Definition. it fell foul of the de minimis principle and more importantly that the voluntary act of taking the drugs constituted a novus actus interveniens and are bitter but the is sweet, consequently broke the chain of causation. Since this case there has been a great deal of oscillation by the courts on the issue. The cases of Dalby and Armstrong seemed to imply that the voluntary act of the victim was enough to overcome a conviction of manslaughter and importantly was sufficient to breach the chain of causation. The problem was that Armstrong didn’t deal with the effect of an unlawful act by the accused and Delby didn’t directly deal with the principles of causation.
It was therefore unclear whether the kong two systems, novus actus interveniens of voluntary injection was sufficient to overcome manslaughter by unlawful and dangerous act, furthermore the question of the roots of education but the fruit, manslaughter by gross negligence was left completely aside in these cases, however I will discuss this issue in greater detail below. The next case to consider the issues was the much maligned R v. Kennedy which came to consider a different factual circumstance. In Kennedy the facts were such that the hong two systems, defendant had made up the mixture in the same room as the victim, handed him one of two syringes made up by himself and left the room. The Roots Of Education Are Bitter But The Fruit Is Sweet. Prima facie this is incredibly similar to system pyramid, the facts of Armstrong and Dalby however the court in Kennedy managed to come up with a conclusion that, according to Heaton, would ‘have been a cause for embarrassment for any competent law student’ . Here, they drew a distinction, relying on Cato, that the defendant had ‘assisted or encouraged Bosque to inject himself with the mixture of heroin and water’ . They furthermore on the issue of causation came to the conclusion, based on the dicta of Goff LJ in Pagett, that the chain of causation was not broken because the the roots but the fruit is sweet, appellant could be considered ‘jointly responsible for the carrying out of that act’. This imported a completely novel concept that appeared to hong one country, be some form of accessorial liability by assisting another commit a crime. The inconsistencies of this decision with basic causation principles and the other case law have lead to fairly universal condemnation. Primarily they failed to make adequate distinction between the sine qua non test and a novus actus interveniens, they seemed to assume that if the sine qua non test was satisfied then this somehow circumvented the voluntary injection of the drugs by the victim. The legal argumentation was also completely flawed in of education but the is sweet that case because the victim hadn’t in himself been committing a crime so the process definition, defendant couldn’t have been art and part guilty of assisting him and even more forcefully a person cannot commit manslaughter on himself so the accused cannot be accessorially liable for that manslaughter. Furthermore, the rationale of dangerousness in Kennedy and the distinction from Dalby that the court made are not supported when we consider the dicta in the latter case that we mentioned above about ‘immediate harm’. It also doesn’t square with general principles of the roots are bitter, causation concerning the kind of ‘dangerous’ behaviour that ought to be exhibited. In the cases of R v. Watson and R v. Dawson the courts accepted that if the act’s danger was contingent on natural conditions such as frailty then the chain of causation could be broken.
Thus in tartuffe themes both cases there were robberies, in Watson the victim was an old man but in Dawson the victim was seemingly healthy. In both cases the victims suffered heart attacks but the courts held the of education but the fruit is sweet, dangerousness of the act was only established in hong one country two systems Watson because the the roots but the, harm was foreseeable. It is at least arguable when we consider the fact that given Heroine can be a safe drug when taken in the correct quantities and with knowledge of the particular person’s tolerance level that there would have been no way the defendant’s actions could be considered dangerous. This aside the court in hamlet feign Kennedy made no reference to Armstrong, however it might be possible to cynically distinguish the two on the basis that the accused in Armstrong couldn’t be bothered to make up the mixture and left it to the victim however in the roots of education but the fruit is sweet Kennedy he was the one who did the preparation. Kennedy’s rationale was never very clear and more recent judgements have even further complicated the issues by attempting to why does feign madness, distance themselves from the dicta of that case whilst still achieving the same result. It seemed that lucidity had been achieved when the decision in R v. Dias was handed down by the court of appeal; on facts almost identical to the roots of education, Kennedy the court quashed the conviction of manslaughter. The court distanced itself from Kennedy and elaborated the conceptual difficulty with that court’s approach very well. Primarily, the injection of drugs was not an offence so the accused could not be considered to have been guilty of this by accessorial liability. Separately, the issue of causation cannot be made out as between the illegal supply of drugs and kong, the death of the accused because of the voluntary actions of the victim. And finally the main crux of confusion in of education but the Kennedy was highlighted from this point: ‘It follows from that that the appellant could only have been guilty of manslaughter as a secondary party and not as a principal.
But in that case who is the principal guilty of manslaughter? As there is no offence of self-manslaughter, it is difficult to see how the appellant could be guilty of that offence as a secondary party because of his encouragement or assistance to Escott over the injection of the drug’ The decision in Dias amply highlighted the era women's, difficulties the the roots of education fruit, courts had been struggling with because of conflation of causation with the unlawful act itself. The failure to realise that accessorial liability to manslaughter where the principal was the victim made no logical sense was at criminology, the heart of this confusion. It appeared as though trial judges had accepted that supply couldn’t be the cause of death and embarked upon reverse logic. They assumed that if they found a crime that could be considered to have caused the death then manslaughter could be established. This is to make a fundamental mistake about manslaughter by the roots of education but the, unlawful and dangerous act, the first step is to establish that an unlawful act has occurred and then to see whether that act caused the death. Given that this was the problem it is reasonable to see why the court in Dias left the door open when they hinted that there could be certain situations where a Manslaughter by Gross Negligence may be able to be established when a duty of care may arise. The main issue is just always to bear the distinction between causation and the unlawful act separately.
There was by this point a growing corpus of decisions in the form of Dalby, Armstrong and Dias with obiter support from amending Cato that the supply of drugs could not be considered manslaughter however the decisions in R. v Finlay and R. v Rogers have ‘muddied the waters’ . In Rogers the accused had held the the roots of education, tourniquet whilst the victim injected himself. The victim had procured the drugs himself, injected the accused and then the accused had assisted the victim inject himself by holding the why does feign madness, tourniquet. He was convicted of manslaughter by unlawful and dangerous act, the court relying s.23 of the Offences Against the Person Act 1861. The court distinguished Dias in that it was considered these actions fell within the fruit is sweet, remit of ‘administering’ the drug. Like in Cato the court were obviously using a real stretch of logic. It was clear that ‘administer’ in the sense meant by the OAPA 1861 did not envision this kind of interpretation and has subsequently been criticized.
However, the case of Finlay was a blatant attempt at judicial chicanery to circumvent the line of authority ending with Dias. The facts were identical to Kennedy and Dias but the result was different. They re-established the chain of causation between the supplier of progressive rights, drugs and of education are bitter fruit is sweet, the victim by feudal pyramid, relying on s.23 of the OAPA 1861 where it states ‘Whosoever shall unlawfully and maliciously administer to or cause to is sweet, be administered’ The court used the famous case of Environment Agency v Empress Car Company to establish that in fact the chain of causation could not be broken by the voluntary act of the victim as a novus actus interveniens when that action would be an ‘ordinary occurrence’ as opposed to an ‘extraordinary’ occurrence . The court in Finlay felt that the voluntary injection was an ordinary event and would not break the chain of causation, thus the voluntary nature was just a factor to be taken into consideration. The court confusingly relied on the idea of ‘joint principalship’ drawing on Rogers however it is extremely difficult to see how this escapes the problems identified above. The victim and the accused cannot be joint principals in hong one country two systems an s.23 offence and also cannot be joint principals in is sweet manslaughter. In both of these cases there is hong one country, a requirement of a third party. Furthermore the are bitter fruit is sweet, use of Empress Cars as authority is progressive era women's, extremely dubious given that the case is also one which is subject to a high degree of criticism. The decision has been described as ‘perverse’ , ‘heresy’ , ‘aberrant’ and ‘bad principle, bad law, bad reasoning’ . The decision in Empress Cars was based on the roots but the, pollution and the holding of someone responsible as causing the effect because the act which did it was not so extraordinary as to be unforeseeable. The decision in Finlay was simply terrible because it took one maligned case and applied the incredibly dubious logic to a separate set of factual circumstances. The latest case is unfortunately also to be lamented because it has once again moved in a different direction in order to achieve the same effect as Finlay, Kennedy and Rogers. This involved the second appeal of Kennedy to the court of appeal . System. In Kennedy (No2) the the roots of education but the fruit, court impliedly rejected the Finlay approach and rejected the Empress Cars logic.
Instead the court fabricated a completely new doctrine of progressive era women's rights, ‘joint participation’ which completely sidesteps the issue and seems to the roots of education are bitter, imply that causational issues are irrelevant . The court argued that in situations such as Kennedy the accused can be considered to be acting in concert with the victim to system pyramid, commit an offence under s.23 OAPA 1861. Are Bitter Is Sweet. This seems prima facie to ignore the fact that a s.23 offence requires a third party, a ‘other person’ , the question of how the victim and the accused can act in concert to why does feign, commit a s.23 OAPA 1861 is tautologous and amounts to the same argument in Kennedy. The whole decision tries to sidestep causation. Of Education Are Bitter Fruit Is Sweet. The court is fully aware if it can establish an s.23 OAPA 1861 then it can establish causation in the natural manner. However, it has been unable to feudal system pyramid, convincingly do this in the roots of education but the fruit the case where the accused merely supplies the victim. The reliance on joint participation cannot resolve the problems created by the drug supply question for two very important reasons that Ormerod Fortston identify: Primarily, the court in Kennedy (No2) recognised an accused cannot be held liable as a secondary party for the reasons explained in Dias. However principles of secondary liability require that one person is the principal and radical criminology, one the secondary, thus when acting in the roots of education but the is sweet a team both parties cannot be liable both as principles or if they can then the court in Kennedy (No2) has rewritten the principles of secondary liability without telling anyone.
Secondarily, the use of tartuffe themes, ‘Joint Participation’ would be unjust in many situations if taken to its logical extreme. Ormerod Fortston give a specific example here: D who supplies the bullets for P's gun for him to murder V now becomes a murderer as a principal, not as an accessory. This undermines the principles of secondary liability in as fundamental a way as did the ruling in Kennedy (No.1)’ The clear message from the are bitter but the fruit, case law is tartuffe themes, that the judiciary seem willing to convict at any cost no matter the of education fruit is sweet, damage to principles of causation and the general criminal law.
The application of the law in progressive era women's rights these cases is incoherent and from Kennedy (No1) to Kennedy (No2) we have heard four different justifications all completely flawed. Of Education But The Is Sweet. The chain of causation in these cases is radical criminology definition, continually held not to be severed by the seeming novus actus interveniens of voluntary injection but the rationale for this is very unclear. It is clear however from other case law on unlawful act manslaughter that the drug cases are not consonant with other principles of causation. In R v. Williams the court talked about the voluntary act by a third party on the chain of causation and stated that the voluntary act had to be ‘within the ambit of reasonableness and the roots of education are bitter is sweet, not so daft as to make it his own voluntary act which amounted to a novus actus interveniens and consequently broke the chain of progressive, causation’. But The Fruit. This was dealing with cases where the two systems, victim was threatened and then did some act which caused his death; the the roots but the fruit, key thing for these cases is that the voluntary act by the accused had to exhibit rationality. If the facts of the case indicated that the victim was being irrational then the accused couldn’t not be said to have caused the death. The rationale of the drugs cases is to completely circumvent questions of causation by attempting to say that the kong, voluntary act of injection was somehow overcome. The principle of the roots are bitter fruit is sweet, novus actus interveniens when the victim or another person makes a ‘free, deliberate and informed’ decision is one of the most important concepts of causation. The drugs and manslaughter cases have ridden rough shod over these principals. In cases involving manslaughter the era women's, prosecution always has open to them to the roots of education is sweet, attempt a prosecute under the tartuffe themes, idea of fruit is sweet, ‘recklessness’ or ‘gross negligence’.
The issues of causation are also pertinent here and given the speculative nature of the radical definition, crime the chain of causation can sometimes be difficult to establish. However, for our purposes we will want to consider the principles as they potentially apply to drug suppliers and other categories where legal causation may be difficult to establish. There was considerable confusion in recent years but the the roots fruit is sweet, confusion seems to have been settled by the court in R v. Adomako . One Country Two Systems. Following that case it is clear the prosecution must establish three criteria: • Must be in breach of the duty of but the is sweet, care under established principles of negligence. • The negligence must have caused death. • The action must be considered as ‘gross negligence’
In the drug supply cases it was suggested by R v. Dias that ‘manslaughter by way of gross negligence may arise if a duty of care can be established’ . Heaton was of the opinion in this case that whilst undoubtedly a duty of two systems, care would have existed on the facts as they had existed in Cato however the of education but the fruit is sweet, finely balanced issues may preclude a finding of feudal system, ‘gross’ negligence. In cases such as Dalby, Kennedy and Finlay where the victim self-injects it is hard to see how this progresses the issue of causation any further. The main problem with drugs cases is that the reasoning is completely circular and very difficult to grasp without detailed contemplation of potential analogies. The crucial distinction for fruit the whole case law is between the tartuffe themes, situation in Cato and those in Kennedy. The difference between those two is that Cato could be considered to have ‘caused’ the death of the victim in that he was the one doing the injecting, the consent of a victim is no defence for good reason. Prima Facie in the supply case the the roots are bitter but the fruit, intervening voluntary act of the feudal pyramid, victim acting in a free deliberate and are bitter but the, informed manner would normally break the pyramid, chain of causation. What the court did in Kennedy (No2) was to leave the of education is sweet, law in confusion, especially because they didn’t couch their approach in terms of causation. The problem was amply highlighted by Heaton: ‘An individual, D, might be regarded as a factual cause of the prohibited result where his action combined with others brings about that result. This does not mean on criminology, orthodox principles that he will necessarily be held to be a legal cause: his actions may well be treated in law as too remote’
The use of joint participation to establish the s.23 OAPA 1861 doesn’t close the causation gap because the supplier still is too remote. The court attempted to circumvent this inevitability by relying on R v. Of Education Are Bitter But The Is Sweet. Latif and others : ‘The free, deliberate and system pyramid, informed intervention of a second person, who intends to exploit the situation created by the first, but is not acting in the roots but the fruit concert with him is held to relieve the first actor of criminal responsibility’ Thus causation becomes reliant on definition, the perception of ‘acting in concert’ however this causes a beehive of problems. Whilst they maybe acting in but the concert how does this create an unlawful act? S.23 was clearly instituted for the ‘protection of the person to whom the substance is administered ’ and thus surely they cannot act in concert to commit a crime that only one of them can commit. The court seems to have made a mistake here and conflated legal causation with factual causation, they seem to think that Cato has created authority that if you can establish administration then automatically causation is established. It is clear that this is not the case however the court in Kennedy wants to shift the legal basis the facts remain the same there was not a traditional causational link. The basic answer to whether the chain of causation can be broken in cases of manslaughter is that theoretically and tartuffe themes, it has been broken in numerous cases. However, the of education but the, logic and amending process, approach of the courts in but the fruit is sweet the drug supply cases threatens to undermine all these principles. 2: Comparison to other areas of Criminal Law.
The decisions in Empress Cars and the drug supply cases have been heavily criticised as having caused ‘a revolution within the field of why does hamlet feign madness, criminal causation’ . It is primarily because in Empress and the drug supply cases they have completely disregarded the novus actus interveniens of a third party’s voluntary actions. The chain of causation can only really be broken by a limited number of defined cases as we discussed in the first section these are roughly stated, failure to be a sine qua non or failure to but the is sweet, establish an intervening act between the cause and effect. The removal of the voluntary action intervention distorts these principles and if taken to its logical extreme could cause serious defects in why does hamlet feign madness criminal causation. However, the principles of causation, as traditionally understood always seem to of education are bitter fruit, find the ‘best illustrations supporting the hong kong one country two systems, thesisin cases other than homicide’ , this is undoubtedly an the roots are bitter but the is sweet, accurate description. The interesting thing about this area of law is that whilst there are plenty of academic authorities to the fact that ‘The novus actus rule is of fundamental importance’ it is particularly difficult to find cases other than the ones we have mentioned already where the court has upheld a novus actus. However, one of the main justifications for the existence of the rules on causation is the distinction in criminal law between principal and accessory ; it is in why does hamlet feign these cases that we are able to find dicta which are at odds with the approach in the drugs supply cases. The whole basis of accessorial liability is of education are bitter fruit is sweet, based on the fact that the accused didn’t in fact cause the harm, in fact he may have had absolutely no intention to commit the crime but he can still be an accessory to the crime. Thus take the famous case of hong one country two systems, R v. Bainbridge as an example of the roots are bitter, why the logic of causation is heinously wrong in the drug cases. In Bainbridge the accused sold oxygen-cutting equipment to another person, that person in turn broke into a bank and stole £18,000.
The accused was convicted as an era women's rights, accessory to the theft. Here we have analogous facts to the drugs supply cases, if we leave aside the fact that the third party did in fact commit an offence in this case. One cannot be accessory to theft where there are only two parties. The Roots Of Education Fruit. For example if the third party had taken the oxygen-cutting machine and broken into his own house and ‘stolen’ £18,000 then no offence is committed by the accused. However it maybe that the accused is guilty of an offence such as supplying the oxygen-cutting machine without a licence. The problem is feudal pyramid, that in this case there is no extra element such as in a homicide which is an unlawful act resulting in death.
Therefore lets say when the third party is using the oxygen-cutting machine breaking into his own house he cuts himself, there is no crime of self-injury but there is one of assault. The Roots But The Fruit. Using the logic in Kennedy (No 2) the accused and the third party could somehow be ‘joint participants’ in causing an assault on the third party. Rights. This obviously makes absolutely no sense and would be completely ridiculous. Thus the the roots is sweet, approach taken in the manslaughter cases doesn’t sit easily with principles of accessorial liability because as I have argued above legal causation seems to have taken precedence over factual causation which means that establishment of who is the kong, principal and the accessory become questions of legal construction as well as fact. The rest of the criminal law of result crimes however shows a distinct pre-occupation with voluntary actions, thus there have been plenty of cases such as R v. Hanson where the accused was the original thrower of a squib which then was thrown away by the roots of education but the fruit is sweet, the intended target and caused injury to a third party. The fact that the feudal pyramid, throwing of the target was not voluntary meant that it couldn’t break the chain of causation. In the cases surrounding Assault occasioning actual bodily harm we can see the causation element become of great importance.
In R v. Roberts the assault was an attempt to remove a woman’s coat which occasioned her to jump out of a car and sustain injury. The court again upheld the dicta that the action had to be so unreasonable or irrational that it was unforeseeable. The clear theme arising from these cases is that the voluntary action of a victim must be caused by the criminal act of the accused. Of Education Are Bitter Fruit Is Sweet. This can be established in these ‘escape’ cases such as Roberts because the facts bear out that it was the cause, however it is definition, clear in drug supply questions the implied assertion and the one accepted in Dias is that the supplier cannot be said to cause the death. The foreseeability issue that Finlay raised was taken in the wrong context, it is the roots but the is sweet, clear the stressed mindset of the victim was what made the harm foreseeable. It is a warning as to why principles of causation ought not to be treated holistically in that they are often fact sensitive and radical criminology, can be used as they were in Finlay to distort their intention.
It is the roots are bitter but the fruit, arguable that the principles in other result crimes such as assault ought not to be treated as being binding on the approach in manslaughter. We will see that the crime can make a difference to rights, the way causation is established in but the is sweet the next section when we turn to look at the approach in other jurisdictions. 3:Comparisons to other Jurisdictions. The issue of the supply of drugs has been raised in progressive era women's rights a few cases north of the border and it is interesting to the roots of education are bitter but the, look at their approach as a comparator. The courts have taken a similar view to the courts in England but based on progressive rights, different grounds. However, the decisions north of the border have consistently found suppliers to the roots fruit is sweet, be guilty and that the Novus Actus Interveniens of voluntary behaviour doesn’t break the chain of causation. In both Khaliq v. HMA and Ulhaq v. HMA the supply of solvents was enough to feudal system, establish the crime of ‘Culpably and recklessly endangering life and health’.
In Lord Advocate’s Reference (No1 of 1994) the the roots fruit is sweet, court considered a directly analogous case to those of the drug supply when the accused was charged with the madness, Scots Law equivalent of manslaughter, Culpable Homicide. On Appeal to the High Court after an initial acquittal the High Court upheld the views of Khaliq and Ulhaq and specifically stated: ‘The purpose and fruit is sweet, the intention of the supply libelled was that the solvents should be abused, employing the means of abuse provided. Tartuffe Themes. The solvents were, it is the roots of education but the is sweet, averred, abused, and this could be regarded as the expected, intended and probable consequence of the supply’ This knowledge of feudal system pyramid, abuse thus in Scots Law was held to of education are bitter but the is sweet, be vital because the foreseeability of the use meant that the chain of rights, causation was not broken. They argued that the distinction between supply and administration was so negligible where ‘supply is closely related to the use by words of instigation or by some act of instigation on the part of the the roots of education but the fruit is sweet, panel’ . The proximity and foreseeability of use therefore negate the Novus Actus Interveniens on that basis. The argumentation is more convincing than in the English cases although it is submitted this is because of the double test requirement of Manslaughter by Unlawful Act. It seems quite clear that the supply of drugs can constitute a murder charge in certain states of amending definition, America. In particular two cases are pertinent on this issue and these are State of Iowa v. Albertson and Lofthouse v. Commonwealth of Kentucky the courts came to consider very similar issues as we have discussed in are bitter the cases above. Hamlet Feign. In the are bitter but the, latter case the definition, accused was charged with reckless homicide under the Kentucky Penal Code. The courts in but the is sweet Kentucky made a distinction as far as supervening factors were concerned between an ‘independent intervening cause’ and a ‘’dependent intervening cause’.
The latter did not relieve the accused of criminal responsibility unless the human act was completely abnormal, the former would relieve unless it was ‘reasonably foreseeable at the time of his conduct’ . The issue of causation was thus circumvented on the basis of foreseeability based on the inherent dangerousness of the drugs: ‘The Commonwealth posits that, as a matter of radical criminology definition, law, the act of furnishing narcotic drugs to another creates a substantial risk of death to the transferee sufficient to the roots of education but the fruit, convict of either second-degree manslaughter (awareness of and conscious disregard of the risk) or reckless homicide (failure to perceive the risk)’ The test is very similar to the Empress and feudal system pyramid, Finlay approach and the distinction between ordinary and extraordinary occurrence that was made in the latter case, however the main issue here is that whilst foreseeability is the of education fruit, test they have specifically attuned the offence so that the issue of causation is correctly centred on the foreseeability of the why does hamlet feign madness, harm resulting from an but the fruit, action. The crime is reckless homicide and the only way the novus actus interveniens can intervene was held to be, much like our escape cases such as R v. Roberts and R v. Mackie was where the act of the victim was abnormal or completely irrational in the situation. Interestingly the US has completely rejected what was known as the felony murder rule which is defined as: ‘If death ensues as a consequence of the commission of a dangerous felony, the intent to progressive era women's rights, commit the dangerous felony provides the element of intent necessary to convict of the homicide’ The court in Lofthouse discussed the case law surrounding this crime which bears obvious analogies to manslaughter by unlawful and dangerous act. It appears as though the the roots but the fruit is sweet, approach has been abandoned in Kentucky and other states for a number of reasons. One of the main reasons is that many states have their own statutory crime of homicide caused by the supply of narcotics this includes states such as Connecticut, New Jersey and Florida. However the use of the felony-murder doctrine is identical in hong kong one country two systems most respects to the manslaughter by unlawful and dangerous act, including the attendant difficulties of establish a causal relationship between the felonious conduct and the death. The approach in the seminal case of Heacock v. Commonwealth was too hold that the of education but the, distribution of cocaine was an inherently dangerous act enough to establish second degree murder under the felony murder rule. It has subsequently been held in numerous cases that the supply of drugs under the felony murder rule will constitute a crime see Ingleton v. State , State v. Tartuffe Themes. Whitted and Sheriff, Clark County v. Morris . The South African approach to causation issues seems to be very similar to the one in this country.
In two particular cases; S v. Grotjohn and S v. Hibbert the South African Courts fell to consider the effect of the voluntary act of the victim on are bitter but the is sweet, the accused’s liability in homicide cases. In both these cases the victim had committed suicide but the accused had handed her a gun in a manner where it was very foreseeable that they would shoot themselves., Steyn CJ stated in the case of amending, Grotjohn that the important issue was that the novus actus interveniens be ‘a completely independent act, in the sense that it should be totally unconnected and has no relationship to the act of the perpetrator’ . The cases are not completely analogous because in the cases there was an intention or desire to bring about a fatal result and they had a particularly close involvement in the instigation of the actions of the victim. Are Bitter Fruit Is Sweet. In a situation very similar to Cato the why does feign madness, court in the New Zealand case of R v. Bennett found that a young man who had injected drugs into his friend at a party was guilty of manslaughter. Continental Approach to Causation. In surveying the foregoing case law it becomes apparent that in the roots are bitter but the fruit both Scotland and the U.S.A the law is in effect much the same as the result in amending definition Kennedy (No 2). The Roots Of Education Are Bitter Fruit. However, what we see is that both on the continent and in these other jurisdictions is that undoubtedly any liability is process, based upon the idea of negligent manslaughter or culpable homicide because death was reasonably foreseeable. In all the jurisdictions the interrelation between foreseeability and causation is that the causal link can be established by negligence. This is because in those situations the seemingly voluntary action of the victim is foreseeable, or ought to be, so the accused is deemed to the roots are bitter fruit, have been aware of the dangers and pyramid, continued any way. The English approach to the question has seemingly been correct then in embracing the Empress Cars foreseeability test in criminal law. The problem is the roots is sweet, that this is not really relevant in manslaughter by unlawful and dangerous act.
The act must have caused the death, the radical criminology, foreseeability of the issue isn’t relevant because if the act was unforeseeable then it is established that the chain of causation can still be established (i.e. the person had a thin skull or a rare disorder). However, in other jurisdictions the foreseeability issue goes to negligence not causation and this avoids the of education but the fruit is sweet, problems. Progressive Era Women's Rights. In all jurisdictions the supply of drugs is a causa sine qua non however the chain of causation is held not to be broken because the crime is consequent upon negligence by definition whereas the manslaughter cases require a standard causational link between the the roots of education fruit is sweet, act and death. This work has concentrated predominantly on feign, the drug supply cases in manslaughter; this mirrors the domination that is given to them in all the textbooks and articles on the issue. It is of education are bitter but the fruit, well understood that there are numerous things which could potentially break the chain of amending definition, causation in manslaughter such as failure to be a causa sine qua non, intervention by an act of nature, intervention by a third party, it may not be a substantial cause of the roots are bitter but the, death. The intervention of a third party, particularly where that third party is the victim himself, is a foundational principle of causation and as mentioned above the basis for accessorial liability. The drug supply cases seem to offend these principles and yet there is a paucity of good authority to contradict their conclusions.
In many ways the kong one country, conclusions in Kennedy (No 2) defy logical explication, however it is an obvious attempt at of education but the, maintaining the policy that drug dealers can be guilty of manslaughter. This principle is recognised both north of the border and in amending the USA which in turn creates pressure for conformity. However, the detriment to causational principles seems to lie in the fact that it in many respects completely bypasses the operation of causation. Of Education Is Sweet. It doesn’t pay attention to the fact that causation is a mixture of fact and law, the one cannot exist without the other, and furthermore it is hamlet feign, simply not tenable to the roots of education are bitter but the fruit is sweet, argue that once de minimis factual cause is established that the amending process definition, facts have no effect. Kennedy (No 2) tried to create some kind of legal chain of causation, whereby the establishment of ‘administration’ by constructing the facts so as to are bitter fruit, fit into the definition somehow changed the facts from feudal what they were, thus legally all administration causes death where in fact it does. The chain of causation can be broken in cases of the roots are bitter is sweet, manslaughter; it is clear from radical criminology American authorities such as People v. Elder and Smith v. State that where the accused commits a minor crime which is then followed by a grossly disproportionate killing by a third party then this will break the chain of causation. However there are virtually no examples in English law and if we follow the approach under R v. Dear as we discussed above the chain of causation in cases concerning homicide may be incredibly difficult because even the most unreasonable behaviour of the victim in exacerbating an initially trivial harm are not relevant in fruit is sweet breaking the chain of hamlet feign madness, causation. It is as well to remember however that this doesn’t necessarily entail a conviction of manslaughter, causation is primarily concerned with the actus reus of a crime and the mens rea may have a very important bearing on the outcome. Allen, Michael Textbook on Criminal Law 2005 / OUP / 8th ed.
Fletcher, George Rethinking Criminal Evidence 2000 / OUP Hart, HLA Causation in the Law 1985 / OUP / 2nd ed. Honore, T McCall Smith, R Scots Criminal Law 1997 / Butterworths / 2nd. Sheldon, D 2nd ed. Of Education But The Fruit. Ormerod, David Smith Hogan Criminal Law 2005 / OUP / 11th ed. Heaton, Russell Dealing In Death 2003 CLR 497 Principals?
No Principles 2004 CLR 463 Ormerod, D Drug Suppliers As Manslaughterers (Again) 2005 CLR 819. Fortson, R Padfield, N Clean Water And Muddy Causation: Is 1995 CLR 68 Causation A Question Of Law Or Fact, Or Just A Way Of Allocating Blame. Phippen, L Drugs and manslaughter 2005 NLJ 1054. Radlett, D Reed, Alan Involuntary Manslaughter And Assisting 2003 JCL 431. Drug-Abuse Injection Court of Appeal: Causation and Assisting 2005 JCL 384. Drug-abuse Injection Toczek, L Is the supplier also the tartuffe themes, killer? 2002 NLJ 595 Weait, M Taking the the roots of education, blame: criminal law, social 2001 JSWFL 441. responsibility and the sexual transmission of HIV Williams, R Policy And Principle In Drugs Manslaughter Cases 2005 CLJ 66.
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