Confusing Preposition Pairs in English

Confounding Preposition Pairs in English Confusingâ preposition combines in English is one of the most widely recognized missteps for ESL understudies. To assist you with keeping away from this error, reviewâ some of the most generally confounded sets of relational words below.â In/Into The key contrast among in and into is that in shows a condition, though into demonstrates movement. For instance, into is regularly used to portray the development of something from outside to inside, for example, in the sentence, I strolled into the house. By contrast,â in is utilized when a thing or individual is fixed. For instance, I found the book in the cabinet. Models Jack drove his vehicle into the garage.My companion lives in that house.The instructor came rapidly into the room and started the lesson.The dishes are in that cupboard.â On/Onto Like into and in, onto shows movement where on doesn't. Onto ordinarily shows that something is put onto something different. For instance, I put the dishes onto the table when I set it. On shows that something as of now lays on a surface. For instance, The image is holding tight the wall.â Models I deliberately positioned the image onto the wall.He put the book onto the desk.You can discover the word reference on the table.Thats a lovely picture on the divider. Among/Between Among and between are actually the equivalent in significance. Notwithstanding, between is utilized when something is set between two articles. Among, then again, is utilized when something is set among numerous articles. Models Tom is among Mary and Helen in that picture.Youll discover the letter among the papers on the table.Seattle is situated between Vancouver, Canada, and Portland, Oregon.Alice is among companions this end of the week. Next to/Besides Adjacent to - without a s-implies close to. For instance, Tom is situated adjacent to Alice. Interestingly, Besides - with a s - states that something is notwithstanding something different. For instance, Besides math, Peter is getting An ever. Models Balance your jacket close to mine over there.There is such a great amount of work to do other than the ordinary tasks.Come plunk down next to me.Besides potatoes, we need some milk.

Working with children from birth to age 5 years Assignment

Working with youngsters from birth to age 5 years - Assignment Example They need a sheltered domain alongside legitimate consideration to have a solid existence. This paper intends to give the essential comprehension about the earth which ought to be organized their dynamic learning and wellbeing. This paper is a rule for the setting for little youngsters from birth to age 5 years. Security and Health Requirements Safety is one of the principle concerns when managing youngsters as long as 5 years old. The infants and little youngsters ought to be kept from bed demise. They should be appropriately put down for rest for example ideally ‘feet to foo’ position. The temperature of nature ought to be typical for the security of youngsters and the anticipation of sickness and different issues. Infants ought not be disregarded at any example particularly for longer periods. Smoky condition is especially unsafe for babies and thus, grown-ups ought to never smoke before them. Kids will in general ascension furniture, steps and different surfaces high er than the floor and for a sheltered domain it is fundamental that the child is avoided all surfaces which may prompt a fall. An individual who can watch the child all the time can guarantee that the infant doesn't fall. Stay away from any articles which the kids may place into their mouths. Get such items far from the scope of youngsters as they are risky for them. Gagging and gulping occurrences might be kept away from via cautious thought given to little items which a youngster may spot. The electric lines and outlets ought to be far from the youngsters. They may get electric stuns either by contacting, gnawing or playing with those electric strings and outlets or by jabbing metal material in them. The counteractions against electric shock are subsequently, fundamental. Putting substantial furniture before the outlets, keeping lines path higher than their compass and spread the electric outlets firmly are some of measures to forestall electric shock mishaps. Every one of these a nticipations are important to guarantee that the kids get a free from any danger condition (Heberle and Scutella p 44-48). The kids from an exceptionally young age have certain physical and wellbeing prerequisites which should be satisfied. Guardians are encouraged to send lunch with kids so they can concentrate with a solid psyche. The offspring of a youthful age need to have their morning meal every day so they can be sound. Youngsters need a domain wherein they can get toys to play with and subsequently to advance a superior learning condition it is important a toys are given to them (Tassoni 2007 p.516). Setting required for an instructive situation All over the world it is seen that training has become an essential need for each person. Today the class or race doesn't make a difference much yet rather the training one accomplishes has a more noteworthy significance. Uncommon understudies have likewise been given inclination with regards to considers. Study hall Management Plans are intended to assist understudies with achieving a superior evaluation and better condition to consider (Khalsa 2007). Little youngsters have explicit prerequisites of these homeroom the executives plans which rotate around the visual condition and the physical course of action in the class. Visual learning is a route through which the youngsters can be urged to concentrate as they are pulled in towards the hues and drawings. Thus dividers are likewise brightened so that the understudies are pulled in to the diagrams on the dividers. Various banners about the homerooms are put on the dividers which are there to draw in understudies. These visuals are very significant for the youngsters who are contemplating nowadays as this would advance better comprehension in the class (Tassoni 2007 p 27-30) Physical course of action of the seats on which the kids sit are likewise viewed as significant on the grounds that it would permit more space to the kids. Kids at a

The 2019 National Book Award Winners have been announced!

The 2019 National Book Award Winners have been announced! The winners of the 2019 National Book Awards have been announced! In his rousing speech to open the 70th National Book Awards, acclaimed literary advocate and host  LeVar Burton stated, It is storytelling that holds our civilization together. And in a year where none of the 25 finalists had previously won a National Book Award and the majority of the finalists were first time nominees, it was a night of storytelling, of new storiesâ€"a night where the winners told their stories of how they came to be there, the struggles and inspirations, and people along the way. Winner of the nonfiction award for her memoir The Yellow House, Sarah M. Broom spoke movingly of her mother and her presence in Brooms life and memoir. And Hungarian novelist László Krasznahorkai, winner of the translated literature award now in its second year in this iteration, thanked the foundation for the creation of the award and his  translator Ottilie Mulzet, saying that through translators international writers can also be at home in America. Among the other stories told was that of Oren J. Teicher,  chief executive at the American Booksellers Association, who won this years Literarian Award for service to the wider literary community. The award was presented by author and bookstore co-owner Ann Patchett who remarked on Teichers tradition of working at  the counters of various independent bookstores during the busy holiday season. And novelist and activist Edmund White who won the award  for Distinguished Contribution to American Letters, a lifetime achievement award, for his pioneering contributions to gay literature. His award was presented by the author and director John Waters. Watch all 25 #NBAwards Finalists read from their honored books at last night’s NBA Finalists reading: https://t.co/uheCQJRwoz National Book Foundation (@nationalbook) November 21, 2019 And now to present the winners  in each of the five categoriesâ€"Young People’s Literature, Translated Literature, Poetry, Nonfiction, and Fiction! Young Peoples Literature Pet by Akwaeke Emezi Look Both Ways: A Tale Told in Ten Blocks  by Jason Reynolds Patron Saints of Nothing  by Randy Ribay Thirteen Doorways, Wolves Behind Them All  by Laura Ruby 1919 The Year That Changed America by Martin W. Sandler (Winner) Judges this year: Elana K. Arnold, Kristen Gilligan, Varian Johnson, An Na (Chair), and Deborah Taylor Translated Literature Death Is Hard Work  by Khaled Khalifa Translated from the Arabic by  Leri Price Baron Wenckheim’s Homecoming  by László Krasznahorkai  Translated from the Hungarian by  Ottilie Mulzet (Winner) The Barefoot Woman  by Scholastique Mukasonga Translated from the French by  Jordan Stump The Memory Police  by Yoko Ogawa Translated from the Japanese by  Stephen Snyder Crossing  by Pajtim Statovci Translated from the Finnish by  David Hackston Judges this year: Keith Gessen, Elisabeth Jaquette, Katie Kitamura, Idra Novey (Chair), and Shuchi Saraswat Poetry The Tradition  by Jericho Brown I: New and Selected Poems by Toi Derricotte Deaf Republic by Ilya Kaminsky Be Recorder by Carmen Giménez Smith Sight Lines  by Arthur Sze (Winner) Judges this year: Jos Charles, John Evans, Vievee Francis, Cathy Park Hong, and Mark Wunderlich (Chair) Nonfiction The Yellow House  by Sarah M. Broom (Winner) Thick: And Other Essays  by Tressie McMillan Cottom What You Have Heard Is True: A Memoir of Witness and Resistanceby Carolyn Forché The Heartbeat of Wounded Knee: Native America from 1890 to the Present  by David Treuer Solitary  by Albert Woodfox  with  Leslie George Judges this year: Erica Armstrong Dunbar, Carolyn Kellog, Mark Laframboise, Kiese Laymon, and Jeff Sharlet (Chair) FICTION Trust Exercise by Susan Choi (Winner) Sabrina Corina: Stories by Kali Fajardo-Anstine Black Leopard, Red Wolf by Marlon James The Other Americans by Laila Lalami Disappearing Earth by Julia Phillips Judges this year: Dorothy Allison, Ruth Dickey, Javier Ramirez, Danzy Senna (Chair), and Jeff VanderMeer Curious about the other nominated titles? Looking for more great recommendations? Check out the 2019 National Book Awards Longlists. Sign up to Today In Books to receive  daily news and miscellany from the world of books.

Professional and Effective Ways to Use Social Media Through Business Communications - Free Essay Example

Sample details Pages: 2 Words: 531 Downloads: 6 Date added: 2019/04/10 Category Society Essay Level High school Tags: Social Media Essay Did you like this example? The most significant lesson that professors can teach todays students is the success inside and outside the classroom that technology can deliver. In an era where the usage of technology and smart devices are rising, those whom use technology have grown to use the devices, social media platforms, etc. and put them to an effective use whether it is through their studies, or during their post-graduate life. Within this new era, students have used the advantages of growth in technology throughout their class instruction time. Many often look at the rise of social media and technology advancements as a negative trend in todays students, but in the business perspective of ones college career and future post-graduate life, the usage of technology has not only been effective, but also proven to enhance the skills needed to succeed in the field of business communications. Since the rise of social media and advancement of technology, students have begun to thrive in applications and other software programs such as Adobe and Microsoft. Due to the evident success social media has played in the business world, it has become a vital element in communicating between employees, other businesses, and more importantly customers. Don’t waste time! Our writers will create an original "Professional and Effective Ways to Use Social Media Through Business Communications" essay for you Create order Although in-person communication has always been a staple for communication within a business, social media has allowed employees to push themselves to advance their skills, use strategic thought processes, and be able to quickly react to problems that arise in the work place. The usage of social media in classroom settings has prepared students for the real world of business through using media and implementing it into daily assignments for classes. In order for students to truly realize the impact social media has in their future careers, professors have included assignments that encompass social media and create challenges in real life scenarios (Sapkota and Putten). Not only has social media proven to enhance the image and flow of a business, but it has also allowed employers to find their new employees. The hiring process has become easier for recruiters and Human Resource departments within a company, as the range of who they want to work for them, and why they want that person to work for them can easily be narrowed down by using different features and search settings within social media networking apps. The usage of social media in classrooms has also given students an ethics, morals, and skills lesson when deciding the appropriate times to properly use social media in terms of communicating through business. Although social media has been useful in the business world, students must know that there is a fine line between a business profile and an individual profile. Even though social media can enhance ones job search and networking, it could also ruin ones image. In an era where social media is often looked down upon, colleges have found technological advances to be an advantage when teaching business courses, and businesses have found the advances to be equally as rewarding upon hiring social media educated employees. Research has shown that there is a positive correlation between social media usage inside and outside the classroom/work place and an individual/businesss success in growth, networking, and expansion of skills.

Tragic Family Relationships in Wuthering Heights by Emily...

Introduction: In 1800 Century, Catherine and Heathcliff grow up together at Wuthering Heights, Catherine family home on the northern English moors. Heathcliff arrives as a gypsy founding. Catherine father Mr. Earnshaw raises him as a son. Catherine is a strong and wild beauty who shares Heathcliff wild nature Alone together on the moors Catherine and Heathcliff feel as if they are soul mates. But to Heathcliff despair outside forces begin to pull them a part. After falling in love with Catherine .She reject him for Edgar Linton who has money and status. Heathcliff run away with Isabella Edgar sister. Heathcliff becomes wealthy and respected. He takes over Wuthering Heights and Thrush cross Grange Heathcliff love Catherine in the story,†¦show more content†¦Ruled by a wish for vengeance, Heathcliff makes the two of them suffer as he has previously suffered under Hindleys cruelty. As part of his revenge, Heathcliff also marries Edgar Lintons sister, Isabella, and cruelly mistreats her. He also unintentionally hastens Catherines death, which is the point of climax for Heathcliff. The unraveling of Heathcliffs revenge forms the falling action. He lures the young Cathy, the daughter of Catherine and Edgar, to his house and forces a marriage between her and his son, Linton. Since Linton is a sickly young man, Heathcliff knows he will soon die, putting Heathcliff in a place to control both Thrush cross Grange and Wuthering Heights. After Lintons death, he forces Cathy to stay on at the Heights, a situation that allows affection to spring forth between her and Hareton. She does her best to educate him and eventually falls in love with him. Heathcliffs desire for revenge eventually wears out, and he allows Cathy and Hareton to pursue their relationship. All Heathcliff longs for now is death, which will at last reunite him with. Authors Style: Evaluation of technical skills used for enriching the structure and the revival of the goal of the novel. - To clarify the meaning of the symbols and images in the novel and aesthetic judgment to the extent it relates to strengthening the effectiveness and objectivity in the structure of the novel. - To support the structure of the novel andShow MoreRelatedEmily Bronte s Wuthering Heights Essay1220 Words   |  5 Pagesand literate family background, the Brontà « sisters have both written novels centered on orphans’ pursuits of love that may have challenged civilized society. Emily Jane Brontà « and Charlotte Brontà « are among the six children born to Reverend Patrick Brontà « and Maria Branwell Brontà « (â€Å"Emily Brontà «Ã¢â‚¬ ). The loss of their mother and two eldest sisters resulted in different responses between Charlotte and Emily, while Emily became shyer, Charlotte developed a dominant attitude (â€Å"Charlotte Brontà «Ã¢â‚¬ ). InitiallyRead MoreWuthering Heights by Emily Brontà «1111 Words   |  5 PagesIntroduction: Catherine and Heathcliff grow up together at Wuthering Heights, Catherine family home on the northern English moors. Heathcliff arrives as a gypsy founding. Catherine father Mr. Earnshaw raises him as a son. Catherine is a strong and wild beauty who shares Heathcliff wild nature Alone together on the moors Catherine and Heathcliff feel as if they are soul mates. But to Heathcliff despair outside forces begin to pull them a part. After falling in love with Catherine .She reject himRead MoreThe Lives of Emily and Charlotte Brontà «2000 Words   |  8 PagesEmily and Charlotte Brontà « retained exceptional novels throughout history. Their stories captivate the minds of readers alike, taking them to a world of dark, eerie hatred, and overcoming the obstacle faced with love and devotion. However, both sisters have diverse styles of writing. Charlotte Brontà « tends to use more humor through her works, while Emily Brontà « uses more satire along with a sardonic tone. T hey both come together to have somewhat similar themes, making the moral of the story mentallyRead MoreThe Sinusoidal Nature Of Generations1310 Words   |  6 PagesThe Sinusoidal Nature of Generations Emily Bronte’s melodramatic sensational novel, Wuthering Heights, is a heart-rending love story illustrated by a spectator narration. The story consumes the life of two romantic â€Å"soul mates† predestined to never ultimately be together and the impact of their lives on those who surround them. Each novel follows an undefined different story of a sole family. Gabriel Marquez’s One Hundred Years of Solitude explores comparable themes as those in Bronte’s novel unravelingRead MoreThe Invention Of Wings Of Wuthering Heights 1477 Words   |  6 PagesAllen Chen Mrs. Tanksley AP English IV 28 October 2014 Invention of Wings Connected to Wuthering Heights The Invention of Wings follows the peculiar institution of slavery through the eyes of two young girls, Sarah and Hetty. They both struggle with the realities of societal customs pitched against them. Sarah is futilely vying against the strong patriarchal customs of her society while Hetty has to bear with the fact that as a slave, she is unequal to those around her. They are both driven byRead MoreWuthering Heights by Emily Bronte1075 Words   |  5 Pagescalled â€Å"Wuthering Heights† by Emily Bronte. She combines more than one element of a gothic novel and that is craziness, obsession and villain heroes. The novel is formed around the two similar love stories of Catherine Earnshaw and Heathcliff and the young Catherine Linton and Hareton Earnshaw. The motif of this book is full of doubles and repetitions; it has two protagonists as mentions earlier, Catherine and Heathcliff, two narrators, Mr. Lockwood and Nelly, and two houses, Wuthering Heights and ThrushcrossRead More Great Expectations By Charles Dickens1948 Words   |  8 PagesIntroduction Wuthering Heights was composed by Emily Bronte and Great Expectations was composed by Charles Dickens as they were illustrations of the Victorian novel. Both novels reflect the conditions of the 19th century in England which showed a lot of progress in many aspects. Through the growth and development of the English Empire, industrialism and capitalism which caused a lot of dramatic changes in the society. Causing cultural differences among the classes, changing the social roles, meanwhileRead More Physical and Emotional Destruction in Emily Brontes Wuthering Heights1235 Words   |  5 PagesDestruction in Wuthering Heights  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚      Often the lifestyles of a person and those around them are affected by ones concern for his/her own welfare and neglect of others. This attitude is a reflection of self-love and a feeling of self-righteousness. In the novel, Wuthering Heights , Emily Brontà « describes the lifestyles of late 18th century and early 19th century rural England emphasizing selfishness. From the very beginning, there is an obvious tension between the households at Wuthering HeightsRead More Remoteness and Loneliness in Wuthering Heights by Emily Bronte2220 Words   |  9 PagesRemoteness and Loneliness in Wuthering Heights by Emily Bronte Emily Bronte loved nature and spent most of her childhood on the remote Yorkshire Moors near her home in Haworth. Emily found that the Moors were a place of peace and sanctuary where she could retreat to relax and follow one of her most favourite past times, which was writing. However she knew that in a matter of seconds the Moors could change into a wild and savage wilderness. Emily chose this ever-changing setting for herRead MorePride and Prejudice vs Wuthering Heights3113 Words   |  13 Pagesvs. WUTHERING HEIGHTS About structure and mood There are a number of differences. First of all, the narrative structure is very different. Pride and Prejudice is chronological, told by a limited 3rd person narrator. Wuthering Heights begins at present, and then is told as a series of flashbacks, sometimes through letters, but with two different first-person narrators. Pride and Prejudice reads chronologically, with someone telling you about the characters. Wuthering Heights

Aristotle’s Definition Of Virtue Free Essays

Nowadays, virtues are associated with refinement and nobility of one’s character. Aristotle believed that virtue is a function of the soul that guides every action of an individual. Thus, every action illuminates the discretion of an individual to act freely the chosen disposition. We will write a custom essay sample on Aristotle’s Definition Of Virtue or any similar topic only for you Order Now Since every human has a soul and virtue is its activity, can we classify every action as virtuous action? In Nicomachaen Ethics, Aristotle examined the inter-relations among the purpose of every human action, virtues, and vices in the achievement of happiness. Aristotle believed that the supreme good is the ultimate goal of every human endeavor. What then is the â€Å"good† for a man that can be possibly attained through his endeavors? It is happiness but relatively defined; vulgar men associated it with pleasure while people with refined character ascribed it to honor. While these things are pursued to achieve happiness in one’s self, but â€Å"good† should be pursued not only for happiness but for the â€Å"good† itself—as an end. The â€Å"good† brings happiness and is associated with function or activity. For instance, if you are a behest pianist then, you are good in playing piano for you are functioning well. The well-performance of your function creates happiness not only for yourself but also for the others, thus, giving you a unique identity. In the same line of reasoning, soul is an aspect of humans that differentiated them from the rest of the animals. Thus, man’s function concerns the soul. The rational component of the soul controls man’s impulses, thus, makes him virtuous. Therefore, â€Å"human good turns out to be an activity of the soul in accordance with virtue, and if there are more than one virtue, in accordance with the best and most complete. † As such, the nature of virtue then should be explored. Moral Virtues The product of teaching is the intellectual virtue while moral virtue resulted from the habit. Thus, it is never the case that moral virtue arises spontaneously on man’s being. Moral virtues are inculcated in man’s soul and perfected by habits. â€Å"For the things we have to learn before we can do them, we learn by doing them. For if all men are naturally born good or bad, adept or inept in certain skills, teachers have no sense at all. On the same ground, moral virtues can be learned or destroyed in one’s soul: by interacting with others we may become just or unjust; by experiencing perils we may become brave or coward; and other circumstances may impart hedonism, ill-temperance, or self-indulgence. Moreov er, by absorbing moral virtues at very young age, great difference will be made in one’s soul. Since it is through training, virtues are acquired; training then at very young age can mold virtuous personality. Conditions for the Conduct of Virtues Just and temperate actions are done by a man who has the sense of justice and temperance. â€Å"But if the acts that are in accordance with the virtues have themselves a certain character it does not follow that they are done justly or temperately. † Several conditions are necessary for the conduct of every virtuous action: knowledge of virtues; disposition for virtuous actions; and power to do virtuous actions. Hence, knowledge on virtues is not enough to become virtuous; rather, the disposition to put virtues into actions is a must. It is common sense to us, for example, that insufficient food and water taken into the body results to poor nutrition while a balanced diet ensures good health. â€Å"So too is it, then, in the case of temperance and courage and other virtues. † Avoidance of fears leads to timidity while extreme braveness endangers one’s life; absolute abstinence creates insensibility while hedonism shapes one’s indulgence. Since wrong doings are committed due to pleasure and noble character is avoided due to pain, pleasures and pain then are subjects of every virtue. The Doctrine of the Mean â€Å"Now neither virtues nor the vices are passions, because we are not called good or bad on the ground of our passions, but are so called on the ground of our virtues and our vices. † Passions, faculties, and states of character exist in the soul: passions are desires; faculties are abilities to perceive passions; and states of character are the choices to either put the passion in action or not. Feelings of pains and pleasures or passions, and the knowledge on good or bad are not virtues for virtues involve modes of choice. In addition, we naturally have faculties and desires. The man’s virtue then, involves the state of character that makes the realization of every desire that either good or bad. â€Å"For instance, both fear and confidence and appetite and anger and pity and in general pleasure and pain may be felt too much or too little, and in both cases not well; but to feel them at the right times, with reference to the right objects, towards the right people, with the right motive, and in the right way, is what is both intermediate and best, and this is the characteristic of virtue. The deficient and excess among the activities that give pleasure or pain is a vice while moral virtues lie in between of these deficiency and excessiveness, hence, the mean. However, the â€Å"mean† can not be found among actions which are entirely wrong such as crimes and envy. For the â€Å"mean† among entirely wrong actions is either its excess or deficiency, â€Å"but however, they are done they are entirely wrong; for in general there is neither a mean of excess and deficiency, nor excess and deficiency of a mean. Also, an extreme of a particular activity can be closer to its mean such as in the case of courage; courage is more of rashness than cowardice. This is so because of the things that are farther from its â€Å"mean† are its opposites. Moreover, Aristotle’s concept of the â€Å"mean† is not a strict doctrine; since the things and degree of happiness for each individual varies, so as the extent to which the â€Å"mean† for every case lies. It is only through the aid of our practical reason that we may determine the mean in a particular situation. Thus, virtue is a set of innate dispositions for the governance one’s action towards the attainment of happiness. Happiness then is not achieved unless one acted in accordance with his virtuous dispositions. Since actions are the concern of moral virtues, the attributes then of which should be examined. The Nature of Actions The nature of actions was classified by Aristotle as voluntary, nonvoluntary and involuntary. Involuntary actions are done against one’s disposition; voluntary actions are in accordance with the disposition; and nonvoluntary actions are accidentally done due to ignorance. Since virtue governs one’s disposition to act in accordance with the â€Å"mean,† the primary basis then of a virtuous action is the goodness of choice. For an action is always a product of premeditated choice of an individual for the attainment of one’s purpose, it is therefore voluntary. This also satisfies the conditions that Aristotle believed are necessary for virtue: knowledge, volition, and doing. On the other hand, if an individual was forced for a certain action, although seem involuntary, he is still responsible for that action for he has a choice for not doing. Meanwhile doing things because of ignorance is involuntary if at the end, one recognizes ignorance while failure to do so, makes it nonvoluntary. For instance, if a drunkard is addicted to liquor due to inability to discern virtuous things, the person then is guilty of ignorance and the action is nonvoluntary. If at some point of time, the person realized his ignorance, the action then becomes involuntary. With these, only ignorance can excuse an action to be called a vice but has limitation. If after realizing virtuous things, the person has continued to be a drunkard, then the action is voluntary and he is therefore vicious. Conclusion For Aristotle therefore, virtues are dispositions that acted in accordance with the doctrine of the mean towards the attainment of happiness. Happiness can not be achieved by merely just having or knowing virtues, rather by putting virtuous dispositions into actions. Thus, virtue is an active condition that makes one apt at choosing. How to cite Aristotle’s Definition Of Virtue, Papers

Research and Discussion on Earnings Management †MyAssignmenthelp

Question: Discuss about the Research and Discussion on Earnings Management. Answer: Introduction The organizations that are operating in the economy have an ultimate aim of engaging in profit so that they can maintain their market share and on the same time maintain their market share. Every company has various expenses which they have to undertake in order to sustain their business and it is the role of the management to take care of the expenses from the income it receives (Kothari et al., 2015). The income left after meeting all the expenses is known as the net income or profit. This is even known as earnings. The profit or earnings are significant for the shareholders as an entity performance measurement as it is helpful in identifying the degree to which the company has engaged in operational activities in order to add value to the firm (Chan et al., 2014). It is even used to evaluate the performance of the managers and to aid in estimating the future cash flows and to evaluate the risk. This paper has been designed in order to assess the process of earnings management and the three underlying issues that would reveal the engagement of the managers in the process of earnings management. These discussions would be undertaken next in the paper. The process of earnings management has been explained as the numerous ways like the managers using their judgment during financial reporting and in framing the transactions to transform the financial report in order to either mislead certain stakeholders about the distinct economic performance of the organization or even to manipulate the contractual results that is dependent on the accounting numbers. On the other hand, Fang et al., (2016) has defined earnings management as a legal and reasonable decision making of the management and documenting the same in order to accomplish predictable and stable financial outcomes. Barth et al., (2016) has discovered a positive relationship that is existent among the degrees of information irregularity and earnings management and therefore has provided evidence recommending that irregularities in the information is an essential situation for the earnings management. The higher degree of information irregularities makes it complex to gain access to the precise information that would make sure efficient supervision of the management decisions, actions and choices. Hence, the theory of agency has constructed a solid model for gaming knowledge about the earnings management as gives the management with economic enticements and to influence the financial outcome. There are various issues that manipulate the managers in engaging in earnings management (Enomoto et al., 2015). However, in this paper only three underlying issues require to be mentioned that have will be discussed. Managerial Compensation Incentives One of the most general remunerations for managing earnings is the managers compensation package. In most of the organizations the managers are eligible for cash bonuses or options for share on accomplishing prearranged reported earnings. It is due to this factor that the managers make use of any strategies to accomplish their target. Cohen et al., (2014) made use of accruals and transformations in the accounting policies and discovered that managers select income raising accruals as long as the revenues are within the minimum and maximum boundaries and they tend to move towards income falling accruals of the incomes are over the maximum level. Thus this has been one of the issues in managers supervising earnings. It is seen that earnings are handled and managed for the assistance of the entity, in order to meet the estimations and the expectations of the shareholders and the analysts so that the management and the shareholders are satisfied with their work. The managers look to manage earnings in order to maximize the value of the organization and to communicate the private and secret information and to restrict the violating the limited debt covenants (Doukakis, 2014). The managers look to undertake these activities so that the earnings can be managed with ease. The regulatory issues can even persuade the management to employ in earnings management. The organizations that are generally susceptible to the investigations that are anti-trust and the companies looking for government subsidy have a large amount of remunerations to manage the earnings that look to be less profitable. Degeorge et al., (2013) has investigated that whether regulatory assessment raises the earnings management likelihood for the companies that gets assistance like relief of import in the form or reductions in quota and increases in tariff. This has revealed that the companies making use of the income reducing earnings management in order to be eligible for the assistance of import relief. Thus, these have been the issues for the managers undertaking earnings management. Conclusion The completion of the paper has expressed that earnings management has been one of the significant issues that influences the managers to accomplish their remuneration packages by completing their prearranged tasks and even providing satisfaction to the shareholders with the help of maximising the valuation of the organization and in certain circumstances the companies looking to gain government subsidies and faces political consequences makes use of regulatory review in order to gain relief assistance. Thus this process is a significant procedure implemented by most of the organizations. Reference List Barth, M. E., Gmez Biscarri, J., Kasznik, R., Lpez-Espinosa, G. (2016). Bank earnings and regulatory capital management using available for sale securities. Chan, L. H., Chen, K. C., Chen, T. Y., Yu, Y. (2014). Substitution between real and accruals-based earnings management after voluntary adoption of compensation clawback provisions.The Accounting Review,90(1), 147-174. Cohen, L. J., Cornett, M. M., Marcus, A. J., Tehranian, H. (2014). Bank earnings management and tail risk during the financial crisis.Journal of Money, Credit and Banking,46(1), 171-197. Degeorge, F., Ding, Y., Jeanjean, T., Stolowy, H. (2013). Analyst coverage, earnings management and financial development: An international study.Journal of Accounting and Public Policy,32(1), 1-25. Doukakis, L. C. (2014). The effect of mandatory IFRS adoption on real and accrual-based earnings management activities.Journal of Accounting and Public Policy,33(6), 551-572. Enomoto, M., Kimura, F., Yamaguchi, T. (2015). Accrual-based and real earnings management: An international comparison for investor protection.Journal of Contemporary Accounting Economics,11(3), 183-198. Fang, V. W., Huang, A. H., Karpoff, J. M. (2016). Short selling and earnings management: A controlled experiment.The Journal of Finance,71(3), 1251-1294. Kothari, S. P., Mizik, N., Roychowdhury, S. (2015). Managing for the moment: The role of earnings management via real activities versus accruals in SEO valuation.The Accounting Review,91(2), 559-586.

F.Scott Fitzgerald free essay sample

A discussion of F. Scott Fitzgeralds life and the typical female characters in his writings. (more)

Womens Writing Changes essays

Womens Writing Changes essays Women's writing styles have changed over the years as women's roles have changed in this world. The more that woman's roles have changed the more that their writing changes. There are many reasons to account for the changes in women's writing. At first, in the early years, women were not even allowed to be writers. After women were allowed to become writers, they didn't write about what interested them, they wrote about what about what would interest men. Women writers were writing for a male audience. That soon changed women were writing more about things that were of interest to women because now women were writing for a female audience. Another reasons that can account for the change in women's writing is that woman's role in life have changed. Women don't all have the same role in life, taking care of the home and family. When women's roles only consisted of taking care of the home, their children, and husband, their writings were very different than when the women were out in the world doing different things. Some women's writing inferred that they were being suppressed because they wanted more out of life that what the men would allow them to have. When women felt suppressed in their lives they brought that feeling into their writing. Later, after women could do more with their lives and didn't feel maybe as suppressed by men, women's writing changed. Another reasons that can account for the change in women's writing are the change in what concerns women now from what the concerns of women years ago. When the concerns of women change, the writing changes too. At one point the only major concern that women had was their family and the home. Now, women have more concerns about themselves and their careers. It's not to say that women are not concerned with their family and home anymore, it's just to say that now women have more to be concerned with, and that can accoun ...

Critical Analysis of the Article from both POSITIVE and NEGATIVE Essay - 2

Critical Analysis of the Article from both POSITIVE and NEGATIVE aspects - Essay Example The author therefore does not see products and services as two different acts but visualize it as a combination of complex processes that must be undertaken together in order to deliver something of value to the customers. The author has also provided a visual representation of the molecular model and how it can integrate with marketing processes to provide a comprehensive view of how marketers should view services and other aspects of marketing jointly. This approach therefore provides a visual picture of the different relationships and proportions of the elements. Further, author has attempted to consider services with evidence as it is the evidence only which can effectively provide a comprehensive understanding of how one can actually measure the effectiveness of the services. The author therefore provides modeling as well as blueprinting as two important methods that can effectively provide marketers an opportunity to design services in such a manner that it can offer relatively better opportunity to understanding marketing in larger context and design the overall offering in such a manner that achieve the objectives. It is however, critical to note that the author has fall short on different occasions. Services essentially are of perishable nature therefore effectively they cannot be dynamic as assumed by the author. The dynamic nature of the services can only be assumed when they are provided on the consistent basis and the customers have the ability and opportunity to provide effective feedback about the overall quality of the services. Further, services can be separated from the products as it depends upon the overall nature of the offering made by the firm. Since some products are delivered with minimal service promise therefore services essentially cannot be considered as important for designing an effective product. Lastly, the overall argument is not

The Japanese model of human resource management is no longer relevant Essay

The Japanese model of human resource management is no longer relevant to firms in the contemporary business environment. Critically assess this statement - Essay Example In this case, an individual may argue about the extent to which Japan should adopt Western management practices so as to boost its performance in the global marketplace (Sakikawa, 2012). This paper will evaluate whether the Japanese HRM model is relevant to the contemporary business environment. The Japanese HRM model is characterized by information flow and collaboration that is dominated by the Japanese culture. Japanese people believe in getting their hands dirty to help them identify the prevailing problems and come up with relevant solutions to address the challenges, and the leaders are not exempted from this initiative. These principles are usually mistaken by most western managers who believe in micromanagement, which is an unprincipled and constant practice that interferes with the processes (Rowley & Benson, 2004). However, according to the Japanese society, these tools are essential in terms of shepherding the underlying processes. The decision making process according to the Japanese is aimed at providing an opportunity that fosters equal ranking among employees and managers in a particular group in order to incorporate the idea that an individual stipulates. This process rhymes with the Japanese culture that focuses on harmonizing people. The physical action that is attributed to the decision making process aims at creating an environment that offers support as well as an agreement for a decision in case a manager who is in a higher position accepts and recommends a particular decision (Ruysseveldt, 2004). The Japanese people believe in the ringi decision making process. This means that a person should submit a proposal to his or her supervisors, and await their feedback. Though the executive leadership does not define the corporate policy clearly, all the managers regardless of the levels that they occupy are supposed to raise their decisions that

Use Case Diagram Details For Library Management Computer Science Essay

Use Case Diagram Details For Library Management Computer Science Essay The Library Management System would be a Web application. A simpler form of library based management system provides multi functional processes to log in, register, add books, add categories, search or issue or return the books. The basic language used in the follow up of this system is C# and the data base used for the same is SQL Server and SQL Client. These all have been used in the code of processing a Library Management System at any place (Gupta). There are certain advantages of using visual basic in Library Management System that it provides a very decent atmosphere for all the programmers to develop a graphical user interface which is considere4d to be a ready to use component in the main working of Library Management System. This will be providing all functionality for Abu Dhabi University library operations. The specific details of each user are given below in this document.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  A librarian can add all details of new books / journals / periodicals / CDs / DVDs using create new book menu from his administrative panel, from this administrative panel librarian can also delete any previous entry of books / journals / periodicals / CDs / DVDs and if librarian just want to update status of books / journals / periodicals then he can update details of books / journals / periodicals / CDs / DVDs details also but in this case if library management system found any invalid id of any invalid book details then it will give and immediate alert pop-up to administrator of the system will also kept record of each alert and the most useful feature of this library management system is librarian can search any of the books / journals / periodicals / CDs / DVDs from the database using title or author name. Librarian can also update and of the user details and delete or block users if there fee or fine is not submitted or he found a nything wrong with and of the students user account. Librarian is also have privileges to see amount of fee and fine that any user have to pay and also overall money that is going to debited. A database manager can create a new database and took back-up of day to day updated database of library management system. Database manager have to design whole schema once and have to made changes time to time if needed. A guest user will have a limited or no access to data. Guest can register himself/herself and become a regular user of Student or Faculty type after getting approval of library management systems administer. In library management system for Abu Dhabi University there would be two types of user exist. First one would be student type and second type is of faculty type this faculty type users are having unlimited account for borrowing books but in place of student type account there would be some limit for borrowing books at a time. This student type user have to submit their book within a period or re-borrow them if they need it for more longer else the fine will be charged to students type user but in case of faculty type user there is no time limit for any borrowed new books / journals / periodicals / CDs / DVDs. A student type user can login to library management system after fulfilling his/her authentication if it library management system found any invalid account then will give a alert massage and will also report to administer at another hand after logged in he can check is his account which contains the amount that he/she has to pay including all fine details and this will also having all of history of his/her borrowed new books / journals / periodicals / CDs / DVDs. The student user can borrow books / journals / periodicals / CDs / DVDs and the system is also having an option for re-borrow of books / journals / periodicals / CDs / DVDs. The library management system facilitated more to students and faculties too there is an option to put a request of home delivery with any borrow request. The charges of home delivery will be automatically added to their accounts. The biggest useful feature of this library management system is user of all type can search any of the books / journals / pe riodicals / CDs / DVDs from the database using title or author name of borrowing it. The student and faculty type user can also request for any new required book in library and this request will directly goes to the administrator of this library management system which will precede this request to further steps. One more feature of this library management system is feedback the user of student type and faculty can rate for any books / journals / periodicals / CDs / DVDs and also put their comments for any of them which will help other users and librarian too to decide about that books / journals / periodicals / CDs / DVDs so that review also done in this library management system. There are some other categories of Use Case Diagram for Library Management System, for example E Draw Soft Diagrammer 4 which is a new UML Diagram and is considered to be a new type of diagram tool for the software engineers and various designers. E Draw is a short form of Easy to Draw diagram for UML model (Use Case Diagram For Library Management System).

Development of the learning process of students for progress through after school program Essay

The question of development of students in their childhood is extremely vital that has to be tackled carefully, if not various problems will arise not only at the individual level but also at the national level. To improve the condition, the sanction of fund by the government alone is not sufficient to solve the problems but question remains at the top for its use in right direction at the right time in right amount with consideration of grant, method of constructing the children in the limitation of time and space of adults, the capacity of the children for their success, the implementation of art in their education life with the question of implementation of their education in the development of the community with the help of after school program. If the problem is solved tactfully and effectively, the manifold benefit can be had for the development of the students. The proper implementation of the after school program will bring out the goodness in the students to the society in proper manner. The creativity, which is present in every student by birth, will come out to the society to give strength not only to the students themselves but also to the nation. The article ‘Children â€Å"At Risk†: Constructions of Childhood in the 21st Century Community Learning Centers Federal After-School Program’ by Sharon Verner Chappell is not only an informative one but also a fine creation of work of literature. This article may be termed as a vital literature, though it an article, in the contemporary situation due its wide range of data and analysis of the situation of the students of any country. The effectiveness of the article is without the any boundary of the community, language and the nations. The sanction of $4. 5 billion by U. S. government for after school programs through the 21st Century Community Learning Centers (Chappell, S. V. 2006) is an independent variable if we consider the fact about the budget allocation. The amount is decided at the time of budget and at the time of budget preparation other needs are not taken into accounts. Though the actual amount spent will become dependent variable when the number of school and students are taken into consideration. Another example of dependant variable can be seen as the number of good performing students that is directly proportional to increased skill in study and inversely proportional to decreased number of adverse behavior like teen pregnancy. Sanctioning money is very much essential for any project to be completed, considering this assumption the US government has sanctioned the money amount. This may be considered as an important hypothesis. A hypothesis that â€Å"children are active and academically successful (i. e. productive) when they attend a state regulated educational program, whereas those children who do not attend such programs are passive, unproductive, unsuccessful, and by extension, perhaps, not good people† is cited in the article by Chappell (2006). This Operational Research Question is universally acclaimed and it is studied here in the context appropriately. â€Å"The students and the parents both are needed high attention of care and support when they are from high poverty family†. This thought is also implemented in the article. When students are in low-performing school their self-performance is also decreased. In addition to this hypothesis another one like â€Å"when art is introduced in the curriculum, the performance of the students are better many fold from previous†. Another citation by Chappell (2006) from Vadeboncoeur (2005,123), is as ‘notions of time and space can be used â€Å"to map institutional and narrative landscapes of students. â€Å"‘ This is also an important operational research. The definition of term by the article writer is provided in between the sentence by proper explanation in next step in the advancement of the description. After stating some policy, additional information is provided to describe the policy, which act as invisible definition of the term in the article. Some time the definition is given in bracket as in â€Å"reduce the number of children in self-care (â€Å"latchkey children† who take care of themselves)†. The meaning of implemented sentence â€Å"reduce the number of children in self-care† in given in the bracket in later part. Population and sampling procedure is informative and given in between sentence without any tabular form. This keeps the flow of the article readable and enjoyable. One example of this in article is â€Å" Since 2003, 6,800 rural and urban public schools have been served around the country†¦Ã¢â‚¬ . Another sampling in the article is given at proper time and places with proper citation method to avoid the ambiguity due to copyright with gives the article a good ornamental decorating. Data source are very huge and the data are collected from the scholarly and valuable articles all related to the subject matter of the article. The tireless, extensive and enthusiastic efforts are given to collect the data from various books, magazines and the websites. The proper care has been taken to collect the data after exhaustive study of the collected materials to produce the article. The data are collected with proper estimation and measurement and the authenticity cannot be suspected as the whole matter is taken from the scholarly articles, authentic magazines and popular books. The psychological and mental estimation of the children are provided with the article with various hypothesis and theory. The data are not provided in any tabular form but are scattered throughout the articles in the manner of information with full lucrative and informative sentence. In the beginning of the article â€Å"amount of $4. 5 million† is mentioned as the sanctioned amount for 21st Century Community Learning Centers (21st CCLC). Another data is â€Å"6800 rural and public school† but in no any data table. Presentation and interpretation of findings are in very intelligent and economical manner. The various divisions have been done with different sub-heading the article to provide the information in proper and chorological manner. The required data and information can be easily had due to the excellent presentation of the article. Findings have proper interpretation and placed at appropriate place. In this article main theme is the construction of childhood with the help of the ‘after school programs’ to be implemented with the help of various funds allocations by concerned institutions. The methods are described to obtained good results by good students. The need for improvement of economically improvised school along with the economically downtrodden family is emphasized. The need of arts is very much essential for the student to become a good student. Though the article is exhaustive in information and description in the problems mentioned in the titles, the need for further Research cannot be denied. There is a need to study the personal behavior of the students at the time of after school program. Many students may not be interested in such program. So they cannot be forced to do the implemented programs but s/he should be given proper attention to find out the actual need and interest of the students. There is need to conduct the research in the area of students behavior and their interests in the study at the very early age. Strength of the study remains in the area of research. The extensive and exhaustive research is done in proper subject matter. The method of citation is proper and the information put at proper places with the good structure of the paragraph with the flow of the information in one proper direction is always advancing. Weakness of the study is in the method of representation of the data in tabular forms without any comparison method. The compared data would have given better understanding of the situation of the students. The poverty level of the parents of the students and the economically degraded school with opposite situation could have been compared in tabular form for better understanding. The various opinions of the parents and the students could have given better improvement in the study.

Bhavnath Temple Case Study

GOSAI NILESH H. DIVISION – A SUB: CASE OF BHAVNATH TEMPLE SUBMITED TO: Dr. D. R. D. Introduction: The case is all about an increasing irrigation facilities after independence but there was certain problems with the removing location of BHAVNATH TEMPLE which is between the dam and people don’t want to change place of temple with that there are some other issue also there. After independence in 1947, the both central & state government want overall economic development. In undivided Bombay province a proposal given to build dam on river. It calculated 4700 million cu. ft.Water to develop 92000 acre of land, In 3 district. To do that 8 villages are totally submerged and resettled at other place. This all require to providing new livelihood to people. The reservoir was to have catchments area of 230 sq. miles. The average rainfall was 34†. In this 1 plan the F. S. L. , was 592 H. F. L. was 596 and R. L. was 601. Directed irrigable area was 19300 acres and the indirect irrigation flow to some 73600acre. It yields 15. 83 lacks revenue per year. Agricultural production increase as 30400 tons. It was 147. 74 lacks. This project was fully feasible in the eyes of government.If plan 1 was accepted than temple was saved by using gates to save from flood. After making 1 proposal government made 2 proposal. In that, if all of three levels rose so that ultimate capacity raise to 1000 million cu. Ft. in that F. S. L. 595 &H. F. L. 606. By doing this the agricultural production increasing and irrigation facilities provide to larger areas. But in 2 plan temple could not be saved but people remained adamant in there demand. IN 1960 state of Bombay bifurcated and now Gujarat PWD department began to think about reopened the plan again.They find this scheme was good for development. The problem is that what should do to become success of this plan. Objectives: †¢ To build the dam, †¢ To increase agricultural production, †¢ Do ultimate overall devel opment Problems: †¢ Temple get submerged, †¢ Religious sentiments, †¢ Opposition by villagers †¢ People get displaced. Constraints: †¢ Location of dam †¢ Religious sentiment can’t be changed. Criteria: †¢ Cost should be minimized †¢ Maximum returns †¢ Minimum people affected †¢ Minimum time in implementation Alternatives: †¢ Plan 1 if no plan 2 †¢ Resettlement of affected people †¢ Wall around the temple Help from religious leader †¢ Convincing people about benefit †¢ Raising the height of temple Suggestion: From all above alternative we compare it with objectives, problem, and criteria we can suggest that to succeeding this scheme government should increasing level of temple by above than flood level with using good construction peeler so ultimately height of temple raised and they saved from flood. By doing so peoples are permit to build dam on river. Contingency plan: If it is not possible to build temple by construction of piller then take help from the religious leader. THANK YOU

Lange vs Australian Corporation - Free Essay Example

Sample details Pages: 5 Words: 1638 Downloads: 10 Date added: 2017/06/26 Category Law Essay Type Compare and contrast essay Did you like this example? LWZ203 Constitutional Law Q(i) Do you believe that Lange vs Australian Podcasting Corporation (1997) 189 CLR 520 was correctly decided? The Constitution contains few express rights and freedoms. Amongst OECD countries, Australia and Israel are countries whose constitution does not have an explicit Bill of Rights. The High Court of Australia has recognized that the structure and the text of the constitution , including the system of à ¢Ã¢â€š ¬Ã…“representative and responsible governmentà ¢Ã¢â€š ¬Ã‚  may give rise to implied freedoms. Don’t waste time! Our writers will create an original "Lange vs Australian Corporation" essay for you Create order An implied Freedom of Speech has been identified on several discussions, including Nationwide News v Wills[1] and Australian Capital Television v Commonwealth [2]. (ACTV). This implied freedom was further extended in Theofanous v Herald Weekly Times[3] and Stephens v West Australian Newspapers Ltd[4]. From the cases above, the High Court reasoned that a system of representative government, as prescribed by the constitution, give rise to an implication that it is necessary to discuss political and government affairs. In the ACTV case, the court further recognized the existence of an implied freedom of speech. The Justices, however, arrived at this implication off free speech in different ways This gave uncertainty to the scope of this implied freedom. The Theofanous case and the Stephens case explored the outer limits of this implied freedom. The defendant in the Theofanous case argued that any views which the plaintiff deemed critical was protected by the implied freedom to discuss political and government matters. The High Court accepted the publication fell within the concept of political discussion. Deane J, stated (at R4) à ¢Ã¢â€š ¬Ã…“It is sufficient to say à ¢Ã¢â€š ¬Ã…“political discussionà ¢Ã¢â€š ¬Ã‚  includes discussions of the conduct, policies or fitness for office or government, political parties, public officers and those seeking pubic officeà ¢Ã¢â€š ¬Ã‚ . The High Court majority argued that this broader implied freedom is based on the priniciples of representative democracy. In Lange[5], the High Court took the opportunity to reconsider the divergent perspectives that had emerged in the previous free speech discussions. In Lange, the High Court formulated a two-stage test on whether a law violated the freedom. The second test which calls for balancing of competing public interests. The reformulated law based on Lange was applied in Levy[6]. The High Court found that regulations were necessary to protect the safety of the public and thus trumped freedom of political speech. The consensus that the High Court reached with Lange were short lived. In Coleman v Power[7], Coleman was charged with using à ¢Ã¢â€š ¬Ã…“insulting wordsà ¢Ã¢â€š ¬Ã‚ , assault towards police officer and was convicted under the Vagrancy Act of QLD. S7(1)(d). Coleman argued he was using words that implied political communications. If that was the case, then he would be protected under the implied right of freedom of political communication. The High Court found the conviction under S7(1)(d) to be unlawful by the was still conceited for assaulting the policeman. The High Court accepted that communication allegedly corruption of police ere protected and that political communication can include à ¢Ã¢â€š ¬Ã…“insultsà ¢Ã¢â€š ¬Ã‚ . The High Courts decision by a 4:3 marking showed that there were two views about reasonable limits on freedom of political communication. One view holds that offensive expression is a neces sary evil in political debate. This view feels that offensive expression is transient and unlikely to leave a long term mark on the intended recipient. Furthermore, if the law is too broad and all encompassing, it might stifle political debate and discussion. The other view, takes the harm caused by offensive expression more seriously but it also seems unconcerned about over-regulation of political communication. This view feels that if the laws overreach, the court will be able to restrain them. My opinion is that the High Court has à ¢Ã¢â€š ¬Ã…“backslidà ¢Ã¢â€š ¬Ã‚  from Lange in that the fine detail of cases fail to conform to the two steps formulated in the Lange test. Some justices argue that some elements in both steps are of no relevance and as such fail to proceed to the second step of the Lange test. (iii) Outline briefly the material facts and the reasoning of the Justices in Roach v Electoral Commissioner. As with the à ¢Ã¢â€š ¬Ã…“political speechà ¢Ã¢â€ š ¬Ã‚  cases, do you think that the reasoning is more judicial à ¢Ã¢â€š ¬Ã…“sleight of handà ¢Ã¢â€š ¬Ã‚  or instead that it is consistent with the Courts professed principles for the drawing of constitutional implications? Material facts: Vicki Lee Roach as a Victorian Woman of Aboriginal decent She was serving a six year term of imprisonment having been convicted of burglary, conduct endangering persons and negligently causing serious injury She challenged the validity of the Electoral Act 1918 (Cth) by the passage of the Electoral and Referendum Amendment (Electoral Integrity and Other Measures) Act 2006 (Cth). The amendments prohibited all prisoners who were serving a sentence for a Commonwealth, state or territory offence from voting in deferral elections Before the amendment only prisoners serving a sentence of 3 years of longer were excluded from voting Argument: Section 93 (8AA) is invalid as it does against the implied right to vote. Judgment: The Act was against the implied meaning of S7 and S24 à ¢Ã¢â€š ¬Ã…“directly chosen by the peopleà ¢Ã¢â€š ¬Ã‚  Parliament has power to withhold voting rights but this has to be for a substantial reason, such as people who have committed serious criminal conduct. However, imprisonment failed as a method to identify serious criminal misconduct. If one was imprisoned for say, homelessness, this was unrelated to the seriousness of the offense. Gummow, Kirby and Crennann JJ decided the validity of the legislation by applying an à ¢Ã¢â€š ¬Ã…“appropriate and adaptedà ¢Ã¢â€š ¬Ã‚  test similar to the second limb of the Lange test, respecting freedom of political communications The arbitrary reasons for imposing or not imposing, short terms of imprisonment mentioned by Gleeson CJ were used to support this conclusion[8]. Outcome: The High Court recognized that there is a const itutionally protected right to vote in Australia. The original provisions of the Electoral Act were upheld and Ms Roach was not able to vote as her term was longer than 3 years. In my opinion the High Court has constituted tests similar to that of Lange in this case to further entrench constitution rights which were implied only. (iv) Has Attorney-General for South Australia v Corporation of the City of Adelaide and Ors (2013) ACA 3 and Monis v The Queen, Proudis V The Queen (2013) HeA4 changed the Law? The first case was about two street preachers which were convicted by breaching a by-law of the Adelaide City Council which prohibited people from preaching (among other activities) in Rundle Mall without a permit. The street preachers appealed their conviction to the High Court citing their implied constitutional right of freedom of communication. The High Court found that the by-law did not interfere with political communication. Ità ¢Ã¢â€š ¬Ã¢â€ž ¢s aim was to promote road safety (the major objective of the by-law was the safely of citizens on the road- the road had to be safe for all users) and did so in a measured way. As the consequence of this law, as held by the High Court was not to restrict political communication, the by-law was not unconstitutional. In the Monis and the Droudis cases, Monis wrote spiteful letters to the relatives of deceased servicemen that had been kissed in Afghanistan. He was charged and conceited after Criminal Code (Cth) which prohibits using the postal service to promote offensive material. Droudis was also charged in aiding and abetting him. The High Court found, that, using the Lange test whether the political statement serves both a legitimate and proportionate purpose. Three of the High Court judges found that the Criminal Codis provision did have a protective purpose, which was the prohibit the misuse of postal services. The other three judges disagreed with the term à ¢Ã¢â€š ¬Ã…“offensiveà ¢Ã¢â€š ¬   and the vague nature of its purpose. The result of a 3-3 tie split in the High Court meant that the decision of the matter which was heard by the MSW Court of Criminal Appeal was upheld, the rule being when the High Court is tied, the discussion under appeal stands. From the cases above, it does not seem that those cases have changed the law. As it stands, the High Court will protect the freedom of political communication, within the limits of the Lange test. In the case of Monis and Droudis, had the letters been sent, even if à ¢Ã¢â€š ¬Ã…“offensiveà ¢Ã¢â€š ¬Ã‚  to the members of Parliament, then it is quite likely the High Court would have found in their favor as this would have encouraged political debate. (v) Do we have freedom of association and what are the ambits? With the implied freedoms in the constitution, one does not know how many exist and if they do, will the High Court affirm them one day and reject them the next, as it has to power to do so. à ¢Ã¢ ‚ ¬Ã¢â‚¬Å" that is it does not have to follow its own precedent. In Kruger[9] Gaudrom, suggested that freedom of association and movement were aspects of freedom of political communication and as such protected by the implied rights of the constitution. Kirby J and McHugh J supported these views is Mulholland[10]. The problem arises in that the other Justices did not shake these views. In Mulholland, Callinan J Specifically rejected the existence of any implied freedom of association. Unless the other cases in the High Court definitively favors the freedom of association, as much as these implied freedoms may be compelling, they have not been approved by the something or the High Court. (vi) What is gerry-manderring and boundary rigging and how do the courts approach the issue? [1] Nationwide News Pty Ltd v Willis (1992) 177CLR1 [2] Australian Capital Television v Commonwealth (1992) 177 CLR 106 [3] Theofanous v Herald Weekly Times Ltd (1994) 182 CLR 211 [4] Stephens v West Australian Newspapers Ltd (1994) 182 CLR 211 [5] Lange v Australian Broadcasting Corporation (1997) 145 ALR 96 [6] Levy v Victoria (1997) 189 CLR 579 [7] Coleman v Power (2004) 220 CLR 1 [8] Retrieved from à ¢Ã¢â€š ¬Ã…“https://en.wikiedia.org/w/index.php?title=Roach_V_Electoral_Commissioneroldid=622735408à ¢Ã¢â€š ¬Ã‚  [9] Kruger V Commonwealth (1997) 190 CLR 1 at 115-6 [10] Mulholland v Australian Electoral Commission (2004) 220 CLR 181