Thursday, September 3, 2020

Franklin Roosevelt essays

Franklin Roosevelt papers Franklin Delano Roosevelt was conceived on January 30, 1882 in Hyde Park, New York. For his instruction he went to Groton, a renowned private academy in Massachusetts. Following this he went to Harvard where he earned a Bachelor of Arts Degree in just three years. In the wake of procuring his degree he continued to examine law at Columbia University in New York City. He finished his BAR assessment and left Columbia without a law degree. In1910, he was chosen for the New York State Senate and in 1913; he surrendered this situation to become collaborator secretary of the Navy. In 1920, he was assigned to become Vice-President of the United States on the ticket of James M. Cox of Ohio. Notwithstanding, Republican Warren Harding won and Roosevelt came back to private life. In 1921, while traveling at Campobello Island, New Brunswick he contracted polio, and lost the utilization of his legs. In 1928, he was chosen Governor of New York. After his re-appointment in 1930, he started his battle for administration. In 1932, he won the selection and because of his lively crusading, he crushed Herbert Hoover by 7 million votes. In the months prior to his introduction the Great Depression was starting to intensify. During his initial 100 days, he worked with congress to pass enactment that would improve the countrys circumstance. He made a few associations that utilized youngsters, safeguarded bank stores, directed the securities exchange, sponsored home and homestead contract installments, and helped the jobless. Because of the fame of his enactment known as the New Deal, he was effectively reappointed to office in 1936. In any case, he before long confronted analysis and the Supreme Court started to feel that a portion of his strategies were unlawful. The court in the long run ruled for his enactment. These were destined to be not really important toward the beginning of World War II on September 1, 1939, when the German armed force attacked Poland. ... <! Franklin Roosevelt papers Franklin D. Roosevelt became President during the profundities of the Great Depression, the 32nd President had the option to impart his own quality and confirmation to a severely terrified American People. The nation needs and except if I botch its temper, the nation requests intense relentless experimentation!1 Franklin D. Roosevelt was a man of his words, he brought trust as guaranteed quick, fiery activity and helped the American individuals recover confidence in the administration and themselves. FDRs vivacious character enchanted heads of state as well as American voters too. During his twelve years he set up a bizarrely close affinity with the American individuals. Franklin D. Roosevelt was a certain man who dreaded nothing, as said in his debut address, The main thing we need to fear will be dread itself.2 Franklin Delano Roosevelt was conceived on the Hudson River home of Springwood in upstate New York on the 30th of January 1882. He was the lone offspring of James and Sara Delano Roosevelt. The family were rich landowners and regular excursions to Europe were not a remarkable thing in the Roosevelt family. FDRs childhood was very un-American as the family was exceptionally European orientated, from the age of five he was wearing a Murray Kit, a Scottish tribe with witch the Roosevelt family asserted a far off association. He was shown both Germen and French by his own private coaches and on his fourteenth birthday celebration his dad gave him a 21ft yacht, total with a little lodge containing two bunks and an oil oven. FDRs youth was amazingly shielded at Hyde Park as he was washed with affection by his folks and protected with riches and property. During 1900s when FDR was eighteen his dad died. This fixed Saras assurance to stay a significant piece of Franklins life as she needed him to grow up like his dad. She even moved to Boston while Franklin went to Harvard University. Before Harva... <! Franklin Roosevelt papers In 1932, Americans understood that they had an undeniably incredible monetary issue on their hands, and attempted to address it by unifying force. The President gained so much force that the country nearly turned into a socialism, particularly with Roosevelt's At the point when Franklin Roosevelt became President of the United States in 1933, the country was in the profundities of the most noticeably terrible wretchedness it had ever experienced. President Roosevelt, an extremely vivacious and energetic individual, enlivened the individuals with his own certainty and confidence later on. He assembled a gathering of individuals sharing his perspectives to support him, and gave food, attire, and safe house for many jobless and destitution stricken Americans. This was a piece of what he called the New Deal, of which his three goals were help, recuperation, and change for American residents. In another endeavor at recuperation, Congress endeavored to restore the country's horticulture and industry and spot the economy on a strong establishment. They printed additional cash to credit to ventures that immediately took care of it. By 1933 about 14 million Americans were jobless. Accordingly, the Roosevelt organization promptly propelled what appeared at an opportunity to be a brilliant program of direct help. In 2 years, government organizations conveyed 3 billion dollars to the states. Be that as it may, the individuals jobless needed occupations, not government assistance, in this manner the Works Progress Organization (WPA) appeared. This reestablished some of By 1936, the New Deal program confronted an enormous and developing body of restriction, some from inside the Democratic Party itself. Numerous pundits felt that the administration was meddling a lot with the free venture framework, and in doing as such, was compromising independence what's more, majority rule government. This assimilation of intensity by the president is what is ... <!

Saturday, August 22, 2020

Design Consulting Research Paper Example | Topics and Well Written Essays - 250 words

Configuration Consulting - Research Paper Example The targets and objectives must be broke down to have the option to build up the preparation program. The factor that is tended to in this stage is the technique that will be utilized and be helpful in the preparation. The preparation strategies might be utilized incorporate preparing by means of the web or preparing that happens in study halls (Bari, 2000). The originator of the instructional meeting at that point sets up a format that is helpful in building up an archive for structure. The structure archive generally contains the substance that is genuine for plan and a framework of the substance. In this stage, storyboards that are valuable being developed and preparing are then made. The storyboards as a rule utilize illustrations. The designs accessible are helpful in making visuals that are utilized in supplementing the substance of preparing. After conclusion and endorsement by entrepreneurs, the preparation is then propelled. The educational program that is utilized for preparing must be comprehended by the facilitators. The preparation procedure should likewise be seen appropriately. The preparation devices that are valuable incorporate software’s, manuals and books. The assessment stage permits workers been prepared to give inputs on the instructional course. Assessment might be directed by overviews. The overviews should be possible by the utilization of paper media or

Friday, August 21, 2020

Intelligence and Theory for Educational Evaluation and Policy

Question: Examine about theIntelligence and Theory for Educational Evaluation and Policy Analysis. Answer: As indicated by remove from Teachers TV knowledge spins round predominant quality execution in assignments that require intellectual abilities where the individual can inspire an emotional response among mind and substantial developments. Cognizance is required in the execution of knowledge since it causes a person to reason, see and use logiomathmatical abilities while playing out an assignment. The equivalent has been shown in a succinct way with the assistance of well known athlete David Beckham and his remarkable abilities of striking an objective. This is one away from of insight with the most extreme maintenance of subtleties and data at the top of the priority list for the ideal harmonization and implantation of them so as to understand a circumstance. It tends to be in this way never deduced in an oversimplified way that an athlete needn't bother with insight since it requires the most elevated coordinated effort of intellectual abilities so as to settle on choice during a critical second. The psychological and physical equalization that the competitor accomplishes is itself one occasion of having clever operator resources. In the short video, it is well discernable how the competitors are required to settle on immediate arrangements pivotal to winning and losing in an action where there is no extent of following up on sheer drive. One of the other most basic parts of insight is intellectual competence control to accomplish something (Nilan, 2018). Two differentiating school subjects would be Mathematics and History, the previous requires critical thinking aptitudes, language framework, working memory, inhibitory procedures and visual spatial handling with the end goal of data getting a handle on and control, utilization of theoretical information required for maths. The later is about memory, capacity to reiterate realities require the psychological abilities of working memory and sequencing. The youngster and grown-up are both keen since they are both possessing fundamental subjective abilities like consideration, memory, creative mind, mindfulness towards outside occasions and figuring which they can apply in basic critical thinking aptitudes like grown-ups. Anyway if there should arise an occurrence of grown-ups it is especially extraordinary since grown-ups use mind in a more productive way than youngsters. This is evident in the utilization of cerebrum and execution of errand with various degree of mind capability. Grown-ups are increasingly initiated in utilizing the mind areas when contrasted with the kids and along these lines can be named progressively clever when contrasted with kids. They are disparate in verbal IQ, capacity for handling data, picture understanding where the WAIS scale was more steady in grown-ups than in youngsters. Verbal insight perspectives like jargon and understanding are additionally preferable in the grown-ups over found inside the youngsters. Another key region of contrast is kids are at a formative phase of psychological aptitudes while in grown-ups, they are available in a total way. In grown-ups psychological advancement results from a perplexing procedure in numerous extents where will the segments of cerebrum increase full shape bringing about creation the individual intuitive. As indicated by me insight is the aggregate capacity to utilize memory, experience and creative mind so as to tackle issues and gain from the experience. It additionally helps in thinking, thinking conceptually, making analogies and accordingly conquer snags (West et al 2016). I have picked this specific plan since it includes a nearby agreement and coordinated effort of intellectual abilities bringing about endeavor of prudent activity that can be named as knowledge. Reference List: Nilan, M. (2018). PGCE International - Understanding Learning. [online] Nottingham.ac.uk. Accessible at: https://www.nottingham.ac.uk/~ttzelrn/understanding-learning-e/unit2/section2.php [Accessed 22 Apr. 2018]. West, M.R., Kraft, M.A., Finn, A.S., Martin, R.E., Duckworth, A.L., Gabrieli, C.F. furthermore, Gabrieli, J.D., 2016. Guarantee and oddity: Measuring understudies non-psychological abilities and the effect of schooling.Educational Evaluation and Policy Analysis,38(1), pp.148-170.

Saturday, June 6, 2020

Media Term Paper About Technology And Communication - 3025 Words

Media Term Paper About Technology And Communication (Term Paper Sample) Content: Presented by:Institution:Date:IntroductionAccording with Bloom, Garicano,Sadun Van Reenen,2014 to technology have facilitated to changes in the communication both to the individuals and the organization. The noted developments in technology include the uses of computers, new networking, emails and social media platform for dialogue. The use of computers has been widely used in the management of the organizations more so in communication, in net networked systems the organization management can send messages through the email to their members. The computers have been used to store the data necessary for the administration. The secure network enables the organization to operate to vast geographical areas.According with Denney Sammon, 2015 the use of the mobile phones has enhanced quick and reliable communications in the business organizations. Mobile phones are portable and are well networked which facilitate the users to make the call at any time from any place. The coordination of the company has benefited from the new technology. The communication cost has been reduced by the currents use of the technology through which the service providers offer at low prices. The differentiated network services providers have enabled the users to have quality communication to the clients and the customers (McNaughton, Light, 2013).The mobile phones can access to the internet's services which offer alternatives methods of communications.According with Hashim, 2015 social media platforms such as Facebook, twitters, and blogs have facilitated the new communication from business organization, to their potential customers and the active customers. Through the Facebook, the company creates the page where the communications are made and feedbacks obtained. In most cases, the Company uses the facebook page to make advertisements and make urgent messages to the customers. The interested clients can view the information about the Company from the blogs. A large num ber of individuals who uses the facebook pages is potential customers to the Company.According with Eisenberg, Goodall Trethewey, 2013 new organizational structures has played a major role in enhancing communication. The new design and decorations used by the Companies have emerged as successful communication tools in the organization. The use of similar construction design is an indication that the business organization has the same production purpose. The decoration acts as a symbol of uniformity of the organization. The green color has been used by Safaricom which is one of the communication providers. All the related services to the Company have the decorations which are similar to give the customers the same views. It is a clear communication strategy the by the Company (Hashim, 2015).According to Miritello, Moro, Lara, Martnez-Lpez, Belchamber, Roberts, Dunbar, 2013 new industries have elements of communication to the public on the goods and services which are offered by the organization. The merging of the Companies to form a single organization has an image that the two organizations are working together to provide adequate and quality services to the members. The uniformity in the products and services provided in wide geographical regions communicate the widespread of the firm to other countries. The customers learn the ability of the organization to offer the best services to a large group of customers. The uniformity in production is communication by itself (McNaughton, Light,2013).FindingsPersonal experiences on the Safaricom CompanyOver the last ten years, Safaricom has been offering services to its customers across many world nations by providing the communication services to individuals and business organization. Some of the services offered by the Company include networked communication and money transfers services by the name M-pesa. The Company communications have improved gradually through the adaptation of the new technology. The use of the networked computers in all the Company departments has facilitated the organization to offer quality and reliable services to the customers promptly. The machine can store large volumes of customer's data and transitions taking place on dairy services. The full-time operations have been possible through the use of set computer systems which monitors the customer's services. The Company has gained benefits as well as the users of the services. Some of the benefits include huge profits made by the company, increased numbers of the customer worldwide to serve and large market shares which is essential to the Company long life in the market. The customers have benefited from the cost reduction to 80%. The quick transfer of information by use of email, internets and social media services is clear indication of the enhanced communication (Bloom, Garicano,Sadun Van Reenen,2014).The construction design and decorations of the premises have facilitated the communication to a large numbe r of the customers by creating public relations and awareness. Safaricom Company similarity in construction design and coloring has created an image to most people of the services which are offered there, including communication and money transfers services. The color has created publicity where advertisements are free to the general public. The result of design and color is the increased sales up to 85% of the set target. The Company has applied the technology to 90%. The management and organization of Safaricom have been smooth and profitable to the organization. The quality and improved services have been the result of new strategies in communications.InterviewIn an interview where a sample of 2000 customers, 400 agents, and 20 officials was interviewed to provide useful information about the current developments in communication and the extent covered. The interview was conducted for one month over nine countries. The interviewers had two main objectives when conduction the int erview, which are emerging communication strategies and the overall benefits realized. The officials provided the following information related to emerging communication and its effects onto the Company; firstly the Company is intensively using the computers to improve the communications and enhance the storage of the large data from the vast numbers of the customers served. The team also informed the interviewers that the new technology had improved the network to reach many customers and offered quality services. Also, the Safaricom officials explained that technology application has reached to about 85% according to the management's team. The advertising has facilitated 80% of the customer's satisfaction through the use of social media platforms such as facebook and twitter. The team stated that the Company has increased the income and offered the best services to customers from the emerging issues (Miritello, Moro, Lara, Martnez-Lpez, Belchamber, Roberts, Dunbar, 2013).The agen ts provided reliable information on the benefits arrived from the use of the new technology, new organizational structures, and new industries. The cheap and faster transfer of the information has been a key success from the communication strategies. The customer can send up to $700 and below to other clients within a short period. The new organizational structure has offered an adequate number of customers through publicity. The customer has the easy time accessing to the building where such services are offered. It has created high numbers of job opportunities up to 65% of target (Eisenberg, Goodall Trethewey, 2013).The customers who were interviewed provided positive feedback on the services provided by the Safaricom Company. The social media platforms have been facilitated by the quality networks offered by the Firm. The customers said they could interact with other members of the societies without physical movements from one geographical region to another which has saved cost up to 70%. The blogs have the potential customers to gain enough information from the company publications. The customer's satisfaction has been achieved up to 80% of the expectations. It has been possible through the developments in the communication (Ruggiero Vos, 2014).Company publicationsInternet connection with the serves such as Google which provide the wide variety of information has been possible through the use of well network system from Safaricom Company. With Google services, the members can send information through the use of email. It is possible to communicate to more than 100 customers by sending the same mails to them. The immediate feedback from the customers has enabled the Company to improve the services according to the customers' needs. The widespread connection has become a good control tool for management to achieving the set target (Ruggiero Vos, 2014).The increased capital for the Company and high rate of return has been the contribution to the welfare of the shareholders of the Company. The customers can access their bank accounts through the internets provided by the organization. The speed of diffusion of information and the dependability has been a result of good working systems on communication through the use of mobile phones which are portable. The short messages have enhanced the users to leaves a message to the customers who are not accessible at that time. The Company can reach to its customers on dairy services which meat it is 90% of information diffusions.Safaricom is one of the leading Companies which have many branches in the world to enable communication globally. The international market has become the global village where the information is easy exchanges with the customers and service providers up to 70% (Whitmore, Agarwal Da Xu 2015). The Company has a higher market share of 75% whic...

Sunday, May 17, 2020

Importance Of Education Essay - 1578 Words

As Nelson Mandela stated, â€Å"Education is the most powerful weapon which you can use to change the world;† without education the world would be at a halt. On average, American children spend 6.64 hours daily at school for 180 days (National Center for Education Statistics, 2008). This means that an American child spends roughly 1,195.2 hours a year at school. If children are spending this much time in school they must be retaining most of the material being taught, correct? Well, unfortunately that is not the case. Students are spending half their days at school sitting down while receiving tons of information, but what good can come from this if they are not retaining any of it. In order for a student to retain information they must enjoy†¦show more content†¦II. Historical The idea of student engagement is rooted to the philosophy of John Dewey. John Dewey was born in 1859, he was an American psychologist, philosopher, and an educator. He is known as a schoolhouse pioneer because his views changed the fundamental approach to education. His views came from the philosophy of pragmatism. The word pragmatism originated from the Greek word ‘pragma’ which means action. Pragmatism can be simply defined as a logical way of doing things based off certain situations; it is the idea that actions are useful in practice and not just in theory. Dewey strongly believed in progressive education, and his ideas were crucial to the progressive movement in education. He believed that education should be meaningful, and that activity and active participation should be incorporated in learning. Dewey’s (1956) book, The School and Society, expressed his vision of how he believed every school should be an embryonic community life, active with types of occu pations that reflect the life of the larger society and permeated throughout with the spirit of art, history and science. When the school introduces and trains each child of society into membership within such a little community, saturating him with the spirit of service, and providing him with instruments of effective self-direction, we shall have the deepest and best guarantee of a larger society which is worthy, lovely and harmonious. (p. 19-20) HeShow MoreRelatedImportance Of Education Essay1802 Words   |  8 PagesEducation is the necessity of life that lies next food and water in today’s world where people have a vast knowledge of everything and more and more people are getting access to it and is laying the base for developments in different fields and that is exactly what the Astounding American physicist Albert Einstein had said explaining the importance of education in a person’s life even when they are long beyond their school day till the very last day of their life they keep on using that knowledgeRead MoreThe Importance of Education Essay2077 Words   |  9 PagesThe Importance of Education Kandace L. Cottrell Eng 102 11-16-2010 Normand Hays The Importance of Education Why do we say that everyone must obtain an education to be successful in life? This is one of many questions that people ask about education. Some people ask: what does acquiring an education do for someone that just wants to go to work after he or she finishes high school? He or she may think that it is possible just to graduate from high school and start working. Well it is possibleRead MoreThe Importance of Education Essay802 Words   |  4 Pages An education is something that one can keep for a lifetime. Acquiring a good education can affect one’s personal life, one’s community, and one’s entire generation. The only person who truly controls how educated I am, is me. My education feeds my intelligence, and since I want to be an intellectual, I want an exemplary education. In the end, no one can transfer knowledge from one brain to another, like a money transfer from account to account. It is something that I have to achieveRead MoreThe Importance of Education Essay690 Words   |  3 PagesOne’s Education advancements could probably be the most important decision in his or her life. One can safely assume that a person is not in the proper sense until he is properly educated. As said by Nelson Mandela, â€Å"Education is the most powerful weapon which you can use to change the world.† One may take this quote and interpret it as that Education is deadly and needs to be taken advantage of to the highest level. High School and College to common people seem to be the same. One must go to classRead MoreEssay The Importance of Education526 Words   |  3 PagesEducation is imp ortant in any society. Parents, teachers and even political leaders encourage education in our society. Many people do not understand why there is so much emphasis placed upon obtaining a good education. This is why some people do not put in as much effort as they should. It is important that everyone understand the many benefits of education aside from getting a job and earning a salary. This knowledge will help you to develop an attitude that is conducive to learning. You will enjoyRead MoreThe Importance of Education Essay1346 Words   |  6 PagesThe Importance of Education Education and learning is one of the most important processes in today’s society. Today’s youth are tomorrow’s teachers. In the â€Å"banking method† or education by memorization, the student’s are not being taught; they are only expected to memorize the material, which is not actually a learning process. Although there are a lot of misconceptions to the â€Å"Banking method†, I think that there are also a lot of good to this method as well. I think that the teacher’s job isRead More The Importance of Education Essay782 Words   |  4 PagesThe Importance of Education Education has always been a crucial part of society for the past centuries. Some believe that our education is a privilege. Some believe that our education is a right. Some believe that our education is an obligation. The only obligation we might have towards education is to treat it as a privilege as well as a right, but certainly not an obligation to have an education. Education has been the basis for the success we see in our parents, our teachers, and moreRead More The Importance of Education Essay1093 Words   |  5 PagesThe Importance of Education â€Å"Come on sweetie, you can do it!† These words have constantly been spoken to me ever since I was a child, and by my parents enforcing these words towards me they inspired me to achieve all that I am able too. In the Mexican culture there are many of us who yearn to learn new things yet there are many of our people who instead of lending a helping hand they thrust each other downward. With this key fact in mind I push myself to become an educated person withRead MoreThe Importance of Education Essay1427 Words   |  6 PagesMost people will argue that college education in fields like traditional liberal arts and career-oriented subjects such as business, engineering and science is a stepping stone to success, and I agree because it provides one with broad knowledge, increased opportunities and greater potentials to succeed in life. The traditional liberal arts have been the foundation of advanced learning since dateless times. The idea that traditional liberal arts education at college level gives broad knowledgeRead MoreImportance Of Education Essay1643 Words   |  7 PagesA country is only able to grow and prosper through the education of each successive generation. In essence, the quality of the education system defines the potential of future leaders. Without proper teaching each country could revert, fatal mistakes defining the economy, political climate, and general future of a country for decades. The importance of education is clear meaning no country is free of the scrutiny their education system will undergo; although, some countries have far exceeded expectations

Wednesday, May 6, 2020

Critical Analysis of an Article on HIV/AIDS Prevention...

Introduction: This review is about the main points, gaps and critique of the article. The main information provided in this review will help you gain new insight on women HIV/AIDS prevention issues. As a society, we focus on individualist ways of prevention. We try to enforce and educate individuals on HIV/AIDS prevention on an individual level but it’s more complex because women have a lower status compared to men, this disempowerment can lead to violence in relationships with men therefore, negotiating condom use for women can lead to violence. The angle this review will be focusing on is how these gender roles affect women’s HIV sexual risk behaviours and behaviour reduction. Article Structure: The article was organized very well†¦show more content†¦Lastly, we need to understand that HIV/AID affects men and women differently; women are more susceptible physically and emotionally. Men can transmit the virus to females easier then vice versa. Since men usually have higher power than women, they are more likely to decide on condom use. There are still gaps in HIV/AIDS prevention. Firstly, just recently the female condom has been put into place to give women the power in controlling their sexuality but this is not the social norm compared to the male condom, thus creating many problems still. The female condom is not as widely accepted therefore it still creates barriers (e.g. accessibility) for many women using it. Secondly, most researchers did not provide a theoretical framework for understanding gender differences or the social factors that could be important for risk reduction of HIV/AIDS in women. Article critique: The limitations stood out to me about the article. Since most of the models (e.g. The health belief model (HBM) or The theory of reasoned action model (TRA)) are based on the individual and rarely consider the cultural and social context consequently failing to account for behaviour change and risk factor. It’s hard to tie in the theoretical concepts of these models in prevention for women. This makes me question how useful these models are in the context of HIV prevention among women. Also, it is very unfortunate that many sexual encounters are imposed, not voluntary. This puts women at risk forShow MoreRelatedPhiladelphia Movie Review1571 Words   |  7 PagesPhiladelphia Prepare a critical analysis of the movie Philadelphia (1993). 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However, the impacts of these factors are not equally distributed, leading to differences in quality of health and health careRead MoreChild Marriage in India4546 Words   |  19 PagesIndia overall, roughly 47.6 percent of girls are married by the age of eighteen (The implications of early marriage, 2004). Despite international human rights efforts, the eradication of child marriage is greatly hindered by the intertwined social issues that often lead to and are then in turn reinforced by the practice. Various underlying social factors inform why child marriage exists, including: traditional gender norms; the value of virginity and parental concerns surrounding premarital sex;Read MoreThe Development And Implementation Of Social Development Initiatives Essay1931 Words   |  8 Pagesrealization that human trafficking is not just explicitly related to women and the sex trade as is largely publicized, but the growing and largely overlooked forced labor and organ trading. 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The Law on Involuntary Manslaughter

Question: The law on Involuntary Manslaughter highlights key questions about the proper scope of criminal responsibility, including imposing liability for omissions and controversy surrounding the mens rea requirements that are considered appropriate for serious offences in England Wales. Explain the above statement, illustrating your points with examples from case law. Answer: Involuntary manslaughter has to be distinguished from voluntary manslaughter because in the case of former, there is a lack of intention to kill. According to the law, involuntary manslaughter has been divided in three categories which are unlawful act or constructive manslaughter; gross negligence manslaughter or medical manslaughter and the other categories that of reckless manslaughter. In this way, it is clear that a wide range of situations are covered by involuntary manslaughter and it is also echoed in the verdicts that are given by the courts. In case of unlawful act or constructive manslaughter, it is required that the death of the victim should have been caused by an unlawful act which is something more than a civil wrong (R v Franklin, 1883). In such a case it is required that the unlawful act can be considered as dangerous by applying the reasonable person standard. This means that an objective test has to be applied and not a subjective test (R v Church, 1965). According to this test, there should be an act as merely an omission cannot result in creating liability (R v Lowe, 1973). In the same way, it is also required that the unlawful act should have resulted in causing the death as was stated by the court in R v Kennedy (2005). Challenging decisions need to be made in which the death of a person has been caused by injecting a drug. The effect of the decisions given in these cases is that the courts have a reason to scrutinize what can be considered as an unlawful act or constructive manslaughter. At present, it appears that the law provides in this regard that if the drug has been supplied by the defendant but nothing more has been done by the defendant towards administering the drug, generally the court will come to the conclusion that the death has not been caused by the defendant (R v Dalby, 1982). On the other hand, if the person has been helped by the defendant in taking the drug, and such an act has resulted in the death of the person, the defendant can be held guilty of manslaughter (R v Rodgers, 2003). In the same way, if the injection has been prepared by the present but victim took the needle and injected himself or herself with a deadly dose, the defendant can still be considered as guilty of unl awful act manslaughter because in such a case, an unlawful act of administering a noxious substance has been committed by the defendant as provided by section 23, Offenses Against the Person Act, 1861 (R v Kennedy, 2005). Test that can be used in case of unlawful act manslaughter is an objective test however the act can also be related with property. At the same time, it is also required that the risk of harm should be of a physical harm and when they say it is not sufficient if there is a fear or concern even if it has resulted in the victim suffering from a heart attack. However, if the defendant was aware of the weakness of the victim and also the risk that is faced by the victim, in such a case the defendant can be held as liable. However the law requires that they should be evidence to support that the defendant had the mens rea for committing the act, even though it is not necessary that the defendant realized at that time that the act was dangerous or unlawful (DPP v Newbury, 1977). On the other hand, the gross negligence manslaughter or medical manslaughter takes place when a person owes a duty of care and such a duty has been breached which resulted in the death of the victim. In R v Singh (1999), the conviction for manslaughter for gross negligence was upheld by the Court of Appeal for the death of the tenant although his son was left behind to look after the property. In the same way, a large number of immigrants were suffocated while they were under the charge of the driver of the truck that was carrying 60 illegal immigrants from China (R v Wacker, 2003). In such cases, it is required that the actus reus should be so gross that in the opinion of the jury, it appears criminal in nature and at the same time, there should be a threat of death. For example the defendant in R v Adomako (1994), was an anesthetist who failed to see that a tube inserted in patients mouth has become detached while an eye operation was going on. As a result, the patients suffered a cardiac arrest and died. The approach adopted by Lord Mackay in this case was very clear when he stated that the fact that the breach of duty on the part of the defendant amounted to gross negligence relied on the degree of seriousness of the breach on part of the defendant keeping in mind all the conditions under which the defendant was at the time when the incident happened and also to see if, considering the risk of death that was involved in this case, the conduct of the defendant can be considered as so bad under the circumstances that it amounted to a criminal act or omission in the judgment of the jury. It has been mentioned by the courts on several occasions that a duty of care is present between the doctor and the patient similarly as a duty was present in case of the relationship between the ship's owner and the crew of the ship (R. v. Litchfield, 1993). In Adamoko, the concept of gross negligence has been criticized upon which the Court of Appeal has based its judgment by submitting that its formulation involves circularity as the jury was told in effect to convict the defendant of a crime if they thought that a crime had been committed and that accordingly using gross negligence as conceptual basis for the crime of involuntary manslaughter was unsatisfactory and the law should be applied by the courts as provided in R v Seymour [1983] 2 All ER 1058, generally to all the cases in which involuntary manslaughter is involved or at least it should be used as the basis for providing general applicability and acceptability. Another case that needs to be mentioned in this regard is that of R v Stone Dobinson (1977) when a vulnerable sister of the defendant was staying with them. However, when she fell ill, the defendants did not call for a doctor. It was held by the court that a duty of care was present in this case on part of the defendants and as a result, the attitude of indifference adopted by the defendants was sufficient for substantiating the charge of gross negligence manslaughter. On the other hand, reckless manslaughter cannot be defined so easily. Before Adomako (1994), the general view was that manslaughter can be recklessly committed and an objective test has to be used in this regard. However, after this case, it started to be considered that this was not appropriate test that needs to be applied and recklessness can result in the manslaughter of the kind that was found by the court in R v Stone Dobinson (1977). As a result, now it is considered that reckless manslaughter can be present in cases involving motor vehicles which result in manslaughter. An important case in this regard is that of R v Lidar. No. 99/0339/Y4 where there was an argument between the defendant and the victim when the victim was leaning into the car of the defendants. The car was driven by the defendant at that time and as a result, the victim came under cars rear wheel. In this case, the court stated that the defendant was guilty of manslaughter. It was stated by the court of appeal that for holding the defendant liable, it is required that the defendant should have foreseen the risk of serious injury or death taking place and at the same time, it should have been assessed by the defendant that at least it is highly likely to take place (Ashworth, 1989). These days, perhaps reckless manslaughter can be defined with the help of the test that has been provided by the court in this case. It also becomes significant at this point to refer to corporate manslaughter. After the Corporate Manslaughter and Corporate Homicide Act, 2007 was introduced in at the 2008; number of prosecutions has been increasing ever since. The meaning of this legislation is that the corporations and other organisations can also be liable of manslaughter as a result of the failure to perform the duties imposed on them properly. In case of a fatality as a result of the breach of duty of care, and it is found that the company has failed to manage health and safety procedures, the company can be held liable for corporate manslaughter (Thomas, 1978). However the law of corporate manslaughter can be criticized on the ground that in case of big corporations, it is possible that these companies may get away with the offense because there are huge resources available to them as a result, these corporations are in a better position to defend themselves against the charge of corporate manslaughter as com pared to small businesses. Perhaps the subjective definition that has been given to gross negligence manslaughter does not help at present as it suggests that whether the offense has been committed or not depends on the situation and what has happened (Field and Jorg, 1991). As a result even a question can be asked if the offense of gross negligence manslaughter is present at all. Indeed, it can be hard for jury but there are freeware and forceful authorities present regarding gross negligence manslaughter. Similarly, it cannot be supported by a idea that civil law can deal with culpability where this type of negligence has been present for a number of years (Sharpe, 1994). Probably, due to this reason, it was preferred by the Law Commission that the term criminal manslaughter should be used. Of course, the judges have to apply the law so that it can be beneficial for the jury and they may be aware of the verdict that has to be considered during their discussions. As a result, anything done with a view to faci litate jurys work is perhaps good (Smith and Hogan, 1992). Problem may not be faced by the judge regarding a reform that suggests that reckless manslaughter should be abolished which perhaps is present only in cases of motoring manslaughter (Field and Jorg, 1991). However this does not necessarily mean that our concept of second degree murder will be easier for the jury to understand or for that matter, gross negligence manslaughter. It also appears that this term is also full of probable difficulties and it is also likely that the members of the jury could have heard regarding the use of the term in America. It can be argued in this regard that it is more significant to make sure that justice is provided to the victims by devising wide and diverse range of offenses that are capable of covering all the wrongdoers, instead of having any niceties regarding the drafting (Virgo, 1995). However the work done by the Law commission in this regard is also valuable and it should not be disre garded. But in this regard it is also important to note that the Parliament has the responsibility of making sure that it is in step with the requirements of the society and also to ensure that the reforms are made according to the expectations and needs of the people (Glazebrook, 1960). At present, it may be an unwieldy part of the law, however it can be stated in this regard that this is due to the reason that it has to fulfill the requirements of the society which includes the families of the victims. Concerns have been expressed that the offenses related with the death of someone due to dangerous driving, are not capable of showing the loss of life and therefore it is important that significant care is exercised in order to make sure that the reforms regarding unlawful act manslaughter is not treated as diluting of the law and therefore, mixed signals should not be given in this regard. On the basis of the above mentioned the discussion, and considering the circumstances under which a person ought to be held criminally liable for causing death unintentionally, it can be said that this should be the case only where an obvious risk of causing death or serious injury is present, which the person was capable of appreciating. As mentioned above, involuntary manslaughter is a very wide category of offense. It appears to be inappropriate that the types of conduct which hugely vary in terms of fault should all have the same descriptive label. Moreover, as a result of the broad nature of the offense of involuntary manslaughter, problems can be traced by the judges while sentencing because in such a case, the judge is not able to receive the guidance of the jury regarding the matter is that the important for the severity of the penalty deserved, like the foresight of the accused regarding the risk of causing death. Therefore in this regard, it can be recommended that two diff erent offenses of unintentional killing should be created that are based on differing fault elements instead of having one single, broad offense. Although there can be certain disadvantages of having separate offenses but having a single and very wide offense also carries with it much greater dangers that have been discussed in this assignment. References Ashworth, 1989, The Scope of Criminal Liability for Omissions 105 LQR 424. A. Thomas, 1978, Form and Function in Criminal Law, in Peter Glazebrook (ed) Reshaping the Criminal Law p 28. Graham Virgo, 1995 Reconstructing the Law of Manslaughter on Defective Foundations CLJ 14, 16 J C Smith and B Hogan, 1992, Criminal Law (7th ed) p 373 P R Glazebrook, 1960, Criminal Omissions: The Duty Requirement in Offences Aga inst the Person 76 LQR 386 S Field and N Jrg, 1991, Corporate Liability and Manslaughter: should we be going Dutch? Crim LR 156, 158159 Celia Wells, Manslaughter and Corporate Crime (1989) 139 NLJ 931 Sybil Sharpe, 1994 Grossly Negligent Manslaughter after Adomako 158 JP 725 Case Law DPP v Newbury [1977] AC 500 R v Adomako [1994] 3 WLR 288 R v Church [1965] 2 WLR 1220 R v Dalby (1982) 74 Cr App R 348 R v Franklin (1883) 15 Cox CC 163 R v Kennedy [2005] 1 WLR 2159 R v Kennedy [2005] 1 WLR 2159 R v Lowe [1973] QB 702 R v Rodgers [2003] 1 WLR 1374 R v Stone Dobinson [1977] 1 QB 354 R v Wacker [2003] 1 Cr App R 329 v. Litchfield, [1993] 4 S.C.R. 333 Singh, R v [1999] CA