Friday, September 4, 2020

Urban Lifestyle Research Essays

Urban Lifestyle Research Essays Urban Lifestyle Research Essay Urban Lifestyle Research Essay Paper Topic: The Bean Eaters Urban culture The way of life of a given gathering of individuals is comprised of a few parts, these incorporate strict practices and convictions, financial exercises, customs, instruction, dietary patterns, government, and dressing. The individuals of this set up are viewed as strict by the presence of strict books, for example, The Bible and the Quran. Religion is broadened since there are Muslims and Christians. Love places are free for the general society anyway if you are foreseeing going to them, it is fitting to put on real clothing and consent to the convictions and customs as requirements be. For example, if you will visit a gathering or place of supplication, dont wear an uncovered shoulders dress and short articles of clothing. You can go into a Moslem mosque as they have visits in the midst of the closures of the week anyway you cannot enter it in the midst of appeal times which is as a general rule after seven pm. It is seen as an insult if you wear shoes or shoes into a Muslim spot o f love so it is fitting to put them off before you do. Do whatever it takes not to attempt to take photos on the off risk that you will visit a Chinese spot of love as it is seen as dishonorable and discourteous lead. Another part of culture is the customs of the individuals for the situation study, these individuals obviously have a convention of tutoring, yet this training framework has conflicted with the previous. A couple of angles are essentially not coordinating. some of which has all the earmarks of being the prior recognized preliminary of capacity in the western institutes of grant, that is, the foundation of two thousand years or a more noteworthy measure of educational examination and the comparably appreciated oral traditions of learning and data as practiced by First Nations. The prior created through various accentuations, that start with the Socratic methodology and proceeds in the Aristotelian basis, Middle Ages masterminds, challenges in the Rebirth of figuring out how to the past orthodoxies, not abandoning the civic establishments of the eighteenth century, from which the arrangement of front line science and the humanities rose (Gonz;lez, 2013). This was essentially affected at various roads by the grants allowed in India, Islam, and China, which were additionally profoundly influenced by western progress. It is fundamentally a reality, substance, and reference driven opposing structure in which keen legitimacy relies overwhelmingly upon the creation of remarkable examination that first passes overview by scholastic partners, and is depended upon, customs, workmanship, administration, monetary exercises, dressing, dietary patterns, social associations, lodging among others. For our situation study, we will utilize the curios examined to attempt to reproduce the way of life and way of life of the tenants of this abode. Current religion With such an assortment of people living in Vancouver, it isn't astonishing to find various spots of strict exercises the proof of strict books, for example, the Bible and the Quran makes this reality valid. Such spots are regular where a blended gathering of individuals is found. Various; to test rhythmic movement speculation or impel another. Another way is methodology progressed by canny individuals to grant social and social information beginning with one time then onto the following without content or composed materials. This transmission may occur as idioms, legends, tunes, services, account verses, numbers or blessed serenades. It deals not with facts but instead with the certainties inherent in legend and fantasy. Its not below average or unmatched contrasted with the past. It is basically one of a kind. The social part of the individuals is likewise clear by the way that they take part in wearing exercises which are a portion of the significant social factors that unite individuals. This is apparent by the utilization of ancient rarities gathered on the site, for example, balls. Innovation gadgets, for example, telephones have additionally created another element of public activity where individuals make companions talk and offer thoughts online through the telephones. Such innovative advances have additionally made the to be a worldwide town where individuals talk and convey without issues regardless of the separation between them. Urban way of life Another perspective and way of life of the individuals being examined can be found from the attire or dressing code, the nourishments they eat. For example, these individuals are meat eaters, they likewise eat fish, future archeologists in their offer to recreate the way of life and culture of these individuals would utilize such antiques. The dressing code additionally shows the way of life of people. The rich dress uniquely in contrast to ordinary citizens. The financial practices can likewise be recreated utilizing the ancient rarities examined. For instance, as we had seen before, the proof of fish implies individuals of this time are anglers. Meat demonstrates that they are ranchers who keep animals and furthermore cultivators since we tested a few grains in the review, natural products additionally mean they are ranchers. Another viewpoint that comes out plainly is the lodging if future somehow managed to lead an investigation on these individuals utilizing the gathered antiques they would presume that these individuals lived in perpetual abodes since the reject from building locales would clarify this. Archeologists dont lead research on a whole site, they test antiques of a given segment of the region under investigation and make general ends for the whole site. This sort of data might be deceiving or one-sided against certain individuals on a similar site. In the investigation we directed, just a small amount of Vancouver was contemplated and this ought not be closed to be the way of life of the considerable number of occupants of the region. For example, in the investigation it was reasoned that these individuals are anglers, ranchers and furthermore like wearing exercises yet from a genuine perspective this may not be valid for all the occupants of Vancouver. It might likewise not be genuine that all occupant manufactured changeless houses as surmised by the investigation. Current society In the event that a similar examination was to be done on similar individuals somewhere in the range of 5,000 years to come, the outcomes would not be the equivalent. This is on the grounds that a portion of the antiques are delicate, some are not lasting and may not bear that long. For instance, antiquities we utilized, for example, the nourishments. Fish, beans, corn, milk, cakes and meat may not endure this significant stretch. Furthermore, accordingly, the way of life of the individuals like their dietary patterns and financial exercises, for example, cultivating and fishing dependent on the relics examined may not be remade at that point, since the curios would not be in presence. We additionally made a deduction that these individuals were taking part in social exercises, for example, brandishing utilizing the examined antiquity, however future history specialists would not have the option to reproduce such data because of absence of curios. The way of life that may stay applicable much after the 5000 years is that of religion, since the books might be put away for long, future researcher may likewise have the option to surmise that the inhabitants of the city had a cash economy by the assistance of the coins tested at the site. Contraptions like telephones, PCs, and TVs may likewise persevere through that long and will assist the researchers with reconstructing a great deal of data about the way of life of the tenants of this arrangement. Devices, for example, diggers, blades and spades additionally dont debase with time thus future archeologists will utilize them to realize that the occupants of Vancouver in the 21st century were ranchers. The reject examined from the development point and the trash from the crumbled structures may likewise persevere through that long and help future archeologists to know the sort of lodging these individuals fabricated and the kinds of materials they utilized in their development. Thi ngs like metal actualizes and iron hardware are a portion of the relics that are known to remain long and will be utilized in the remaking of these people groups culture. In this examination led, there are still a few inquiries that despite everything stay unanswered, because of absence of curios to clarify them and the way to communicate the to persuade the individuals who will peruse the report. Such inquiries incorporate, was there an arrangement of government or any component of administration and if there is which type right? Another inquiry that was not addressed is how do the individuals esteem the marriage foundation? Which sorts of marriage are apparent? How does the general public worth sexual orientation, is there sex equality End As per the examination directed, it very well may be inferred this is a cutting edge society where correspondence has been improved all around by the assistance of innovation, gadgets, for example, telephones and PCs and fundamentally the web is the main correspondence station all inclusive related with the 21st century. Albeit a few parts of life are not unmistakably caught in this exploration yet it draws an away from of a people living in the 21st century. References Gonzlez-Ruibal, A. (2013). Recovering paleohistory: past the tropes of innovation. Routledge. Jones, S., Russell, L. (2012). Paleohistory, memory, and oral convention: A presentation. Universal Journal of Historical Archeology, 16(2), 267-283.

Tuesday, August 25, 2020

Soldier Suicide as Political Statement Essay -- Politics Army War Essa

Officer Suicide as Political Statement At any rate twenty-nine U.S. warriors positioned in Iraq and Kuwait ended it all between March 2003 and March 2004. Indeed, even the Pentagon looks at this as an alarmingly high self destruction rate. It lead the military to commission an assurance survey to be finished by Stars and Stripes (August 2003) and to send in an uncommon psychological wellness warning group to evaluate the circumstance. In April 2004, military authorities announced the group's decision: while the self destruction rate for officers abroad is practically twofold that of the non military personnel populace, isn't viewed as an emergency. (1) Perhaps these suicides reveal to us increasingly about how the usage of majority rule government and opportunity in Iraq is going than we gain from other (government endorsed) reports. What may we gain on the off chance that we considered [suicide], anyway probably, as a sort of an accomplishment, even... as a sort of blessing... not the one we may have wanted, however the one [they give] us when [they do] not have anything to give, composes Peggy Phelan, An increasingly broad thought of self destruction may help make an intercession into the typical story of disgrace, disappointment, and anguish that very every now and again commands the relationship of the living with the individuals who slaughter themselves. (2) Let us tune in to oneself delivered passings of U.S. officers in Iraq as proclamations of obstruction that feature issues with the United States' all volunteer military framework. Numerous warriors (especially individuals from the Reserves and National Guard) are headed to enroll for money related/financial reasons. Confronted with constrained choices, they may have deliberately kept under control any genuine thought of the potential outcomes of battle so they would have the option to sign on. These officer... ...nic measurements of those imbalances. At the point when one thinks about that for some individuals from our volunteer armed force, their choice to enroll was made on the grounds that it was one of their solitary alternatives for security, business, school subsidizing, citizenship... supporting our soldiers takes on various significance. Troopers in Iraq who ended their own lives are shouting to the more extensive network to examine why such a significant number of wind up in a circumstance where passing is their most enabled decision. Works Cited: 1 Statistics accumulated from different news sources recorded in the Media Analysis area that follows. 2 p.6-7, 24, Peggy Phelan, Francesca Woodman's Photography: Death and the Image One More Time, Signs: Journal of Women in Culture and Society , vol. 27, no. 4, The University of Chicago, 2002. 3 Stanley Aronowitz, Check Your Enthusiasm, First of the Month , Winter 2004.

Saturday, August 22, 2020

Implementing Disability Sport in Physical Education Essay

Executing Disability Sport in Physical Education - Essay Example The term inability sports has been really characterized as sports â€Å"designed for, or explicitly rehearsed, by individuals with handicaps. Individuals with incapacities are additionally alluded to as competitors with disabilities† (International Platform on Sport and Development, 2009, p. 8). In like manner, individuals with incapacities are the individuals who are recognized to have â€Å"long term physical, mental, scholarly or tangible impedances, which, in cooperation with different boundaries may block their full and powerful investment in the public arena on an equivalent premise with others† (International Platform on Sport and Development, 2009, p. 8). Game alteration could incorporate utilizing explicitly structured hardware; just as fitting the games and exercises as indicated by the aptitudes sets of understudies, their scholarly levels, and energy for the specific game or physical movement. The advantage of this alternative is that it gives chances to cri ppled understudies to partake, find out additional, and appreciate playing the games through utilizing particularly structured gear, and even standards which could basically be changed or adjusted to their assorted needs. Through partaking, the huge points of interest noted from digging into sports and physical exercises, for example, socialization, sportsmanship, improvement of administration and collaboration abilities, just as empowering the understudies to plan procedures for winning are along these lines figured it out. Incorporating incapacity sports inside the GPE educational program would concentrate on the improvement of differing aptitudes. All things considered, teachers would be fuse planning or in any event, altering the educational program to create integral aptitudes; just as address emotional, psychomotor, and intellectual areas. This would necessiate a survey of different... This paper supports that school heads and policymakers who really think about the decent variety in scholarly prerequisites of understudies from profiting by physical training class would perceive that by consolidating handicap sports, all understudies †regardless of whether impaired or not - would profit simultaneously. As underscored, â€Å"both guardians and educators have consistently yielded that people with incapacities who take an interest in sports exercises are less discouraged, perform better scholastically, are progressively steady in conduct just as in their general social interactions†. Moreover, with respect to the understudies without handicaps, by being given proper training on inability sports, they would be uncovered on the pivotal concerns and issues confronting incapacitated; yet, sports slanted, understudies. This exposition makes an end that the ebb and flow talk has successfully accomplished two-overlay destinations, indeed: to clarify the primary improvements inside the domain of executing incorporating inability sports inside the physical instruction educational program; and supporting the contentions and disputes through investigations and examines composed by other legitimate creators regarding the matter. Generally, incapacity sports ought to be incorported in the GPE educational program to acknowledge huge advantages for all understudies the same: those without handicaps and the individuals who are crippled. The instrumental points of interest of urging understudies to create certifiable eagerness in sports and physical activites would add to their general prosperity and improved wellbeing condition all through their lifetime.

Case Study 3 Example | Topics and Well Written Essays - 250 words - 3

3 - Case Study Example A considerable lot of these airfreight firms are going to specialization, for example moving substantial and oversize load. The pioneer and pioneer of particular airship cargo activities are Volga-Dnepr, a Russian airfreight organization (, 2012). One of the procedures that the organization has utilized to lead in this field is an exhaustive promoting effort on the universal market. They have likewise concocted an arrangement of shipping various merchandise, and this has given the market a one of a kind market item. A portion of the one of a kind items incorporate; eighty-one ton coca-cola packaging gear, substantial synthetic reactors, oil and gas hardware and show hardware for music specialists. The one of a kind open door empowered the organization to acquire numerous universal customers who give Volga-Dnepr 90% of its pay (, 2012). The specialization methodology is the essential factor that has driven the organization to develop. Volga-Dnepr saw an issue and they thought of techniques to illuminate it. They have likewise grasped innovation with the obtaining of new airplanes and adding more to their cargo. These are estimable arrangements and plainly Volga-Dnepr will keep on developing.,. (2012). Innovative Technologies in Aviation Logistics | the European Business Review | Empowering interchanges universally. Recovered 20 April 2015, from

Friday, August 21, 2020

Mother’s Fight with Cancer :: Influential Person Essays

Mother’s Fight with Cancer I am learning, both through perceptions and direct encounters, that there are numerous disasters in life which appear to be unexplainable and out of line, but then have crushing results. Ailment fits into this class. Its outrage doesn't come from the way that it is an uncommon or unprecedented event, since ailment and malady overrun our lives as we hear various accounts of debilitated individuals and come into contact with them every day. Notwithstanding, there is a stamped contrast between perusing in the paper that a well known demigod or sports symbol has tried H.I.V. positive and finding that your own mom has been determined to have disease. Without a doubt, the most powerful individuals throughout my life have been my mom and father. It is to them that I credit a considerable lot of my achieve ments and victories both inside and outside of school. All through my adolescence, my folks have consistently cultivated and energized me in the entirety of my undertakings. At all my games, spelling honey bees, shows, and endless different exercises, they have consistently been first line and focus. My folks, related to twelve years of Catholic preparing, have additionally ingrained in me a sound confidence in a cherishing, caring God, which I have come to solidly accept. It along these lines ought not come as an unexpected that the updates on my moms infection would enormously modify my whole point of view. Where was my God? My mom, actually, had known about her condition in the spring of my lesser year in secondary school. She purposely didn't illuminate my sister or me regarding her sickness since she would not like to divert us from our examinations. Rather, my mom sat tight for the fulfillment of her radiation treatment medicines. As of now, she brought me into her room, sat me down on the equivalent wooden armchair from which she used to peruse me sleep time stories, and started to relate her story. I didn't sob, I didn't wince. Actually, I barely even moved, yet starting there ahead, I pledged that I would do everything without exception to satisfy my mom and make her glad for me. Each ensuing honor won and each respect offered to me has been motivated by the memory of my mother’s situation. I look to her as a main thrust of inspiration. In her I see the firm, suffering characteristics of mental fortitude, quality, trust, and particularly love.

Saturday, August 8, 2020

Jason Segel is the Perfect Choice to Play David Foster Wallace

Jason Segel is the Perfect Choice to Play David Foster Wallace Last week, news broke that Jason Segel would be playing David Foster Wallace in a film adaptation of part of David Lipskys 2010 book Although Of Course You End Up Becoming Yourself: A Road Trip with David Foster Wallace. At first blush, Segel as DFW seems a controversial choice (and, predictably, the internet responded with its usual dose of cynicism). The general consensus: How could a goofy comedic actor portray a man as brilliant and troubled as DFW? But you know what? Jason Segel is the perfect choice to play David Foster Wallace. Heres why: DFW was a normal, self-conscious, self-deprecating, and really funny dude. And nobody plays that better that Segel. One of the main themes of Lipskys book â€" based on four days of conversations while traveling with DFW on his Infinite Jest tour in 1996, just as DFWs fame was exploding â€" is how surprised he is that DFW seems normal. In fact, Lipskys actually skeptical. I think you still feel youre smarter than other people. And youre acting like someone whos about 31 or 32, whos playing in the kids softball game, and is trying to hold back his power hitting, to check his swing at the plate, more or less. DFW cracks: Boy, that would make me a real asshole, wouldnt it? DFW vehemently denies that hes acting, even as hes aware that by trying too hard not to act like a normal guy, he ends up appearing as if he actually is putting on an act. (Isnt that DFW in a nutshell?!) And but so, DFW was anything if not hyper-self-aware, and he addresses his act, or lack thereof, in answer to Lipskys question: Theres a couple times Ive tried to do it a little bit. And it seems like youve caught me every time, and then weve both just laughed. Basically, hes saying, outside of a few times when hes aware of how hed be perceived in what Lipsky wrote, he really had just been being himself. All indications are that even while managing his depression with medication, DFW was truly just an honest, slightly-awkward, joke-cracking, self-deprecating mid-30s dude who just wanted to be liked. (Quote example from Lipsky: I dont think writers are smarter than other people. I think they may be more compelling in their stupidity, or in their confusion.) And, lets be honest, and you know this if youve read him: He really was very, very funny. In Lipskys book, hed complain at times about how it sucked his new fame hadnt gotten him laid. And hed warn Lipsky not to use the bathroom after him because hed just wreaked a little havoc. Comments like that arent exactly aimed at a wine-and-cheese crowd and its not hard at all to envision Segel delivering them to a chuckling movie crowd. If you think about all the roles Segel has played, most of which hes nailed â€" from Marshall Eriksen in HIMYM, to Peter Bretter in Forgetting Sarah Marshall, to Sydney Fife in I Love You, Man â€" and you think about how his characters are readily willing to laugh at themselves and their awkwardness, and if you think about how adept Segel is at delivering one liners with an ironic smirk (I still want to hang out, despite that joke. Youre better than that.), and at how good he seems at being appealingly honestwell, its hard to imagine any other actor but Segel playing DFW! Indeed, since the news broke, Ive been thinking hard about who could do it better, and Ive come up empty. Segel is almost perfect. Hes just gonna have to grow his hair out a bit and practice his bandanna-wearing. Ill certainly concede that its a risky casting decision. Its an unconventional choice, to be sure, and it could fail. But I dont think it will. As one final example, though not part of the movie, think about DFWs essay A Supposedly Fun Thing Id Never Do Again, about his experience on a cruise. Think about about the one actor youd like to see in the scenes in which DFW emerges from his room to beat the shit out of a teenager in ping-pong â€" the only thing he enjoys about the whole cruise. Think about Segel playing that guy. I laugh just typing that. I hope it works. I really do. And I wish Mr. Segel way more than luck. _________________________ Sign up for our newsletter to have the best of Book Riot delivered straight to your inbox every two weeks. No spam. We promise. To keep up with Book Riot on a daily basis, follow us on Twitter, like us on Facebook, , and subscribe to the Book Riot podcast in iTunes or via RSS. So much bookish goodnessall day, every day.

Tuesday, June 23, 2020

Judicial Commentary - Free Essay Example

RECENT JUDGEMENTS ON THE ISSUE OF CORPORATE PERSONALITY PARTICULARLY IN THE GROUP CONTEXT SHOW STRONG AND CONTINUED SUPPORT FOR THE IDEA OF SEPARATE CORPORATE PERSONALITY. DISCUSS One of the consequences of incorporating a limited liability company is that it becomes a separate legal entity. This means that it is has a separate and distinct personality from the members of the company, and so becomes a person in a legal sense.[1] Thus the company bears its own liabilities and debts separate from the shareholders and has rights and duties.[2] The principle of the separate personality of a company was discussed at length in the case of Salomon v. A Salomon,[3] where Lord Macnaghten stated: à ¢Ã¢â€š ¬Ã…“à ¢Ã¢â€š ¬Ã‚ ¦The company is at law a different person altogether from the subscribers to the memorandum; and, though it may be that after incorporation the business is precisely the same as it was before, and the same persons are managers, and the same hands receive the profits, the company is not in law the agent of the subscribers or trustee for them. Nor are the subscribers as members liable, in any shape or form, except to the extent and in the manner provided by the Act.à ¢Ã¢â€š ¬Ã‚ [4] Consequently, the fact that one person owned all or majority of the shares of the company did not make that person the sole owner of the business in the eyes of the law. This was emphasized in the Salomon case when Lord Macnaghten stated: à ¢Ã¢â€š ¬Ã…“I cannot understand how a body corporate thus made capable by statute can lose its individuality by issuing the bulk of its capital to one person, whether he be a subscriber to the memorandum or not.à ¢Ã¢â€š ¬Ã‚ [5] In the case of Lee v Lee Air Farming Ltd,[6] Lord Morris made it clear that it was possible for an individual to enter into a contract with his own company. The judge stated that if the company was accepted to be a separate legal entity, then there was no reason to challenge the validity of any contract between the company and another individual, even if that individual was its majority shareholder. It was the judgeà ¢Ã¢â€š ¬Ã¢â€ž ¢s view that control would in fact remain with the company regardless of whoever the companyà ¢Ã¢â€š ¬Ã¢â€ž ¢s agent was. Therefore, as a separate entity, the company can own property which would belong solely to it and not to its members. Neither a member of the company or a creditor has any interest in that property.[7]The company as a legal personality does not hold the property in trust for the shareholders.[8] They simply have no right to it. The aim of this discussion is to look at the separate leg al personality theory in terms of groups of companies and discover what the attitude of the courts is with regard to the theory and group companies. The first step in this will be identifying the exception to this theory, which is described as lifting the corporate veil, when it can be used and the attitude of the courts to this theory in past case law. Moving forward, the application of the principle and its exception will looked at from an international point of view. Finally, the discussion will focus on groups of companies with the aid of case law and an analysis will be made about the recent stance of the courts regarding the theory. Under certain circumstances, it is possible for the courts to look behind the companyà ¢Ã¢â€š ¬Ã¢â€ž ¢s framework or separate personality to make the members of the company liable for a wrongdoing. This process is referred to as à ¢Ã¢â€š ¬Ã‹Å"lifting the corporate veil.à ¢Ã¢â€š ¬Ã¢â€ž ¢[9] In as much as the corporate veil saves shareholders f rom liability by separating them from the company, it also makes it possible for them to hide behind the corporate veil in order to defraud creditors.[10] It has been suggested that the corporate veil would be lifted by the courts if there was evidence of fraud.[11] In the past, the UK courts have been criticized for showing little reluctance in lifting the corporate veil.[12] An example of this is in the case of Daimler Co Ltd v. Continental Tyre and Rubber Co (Great Britain) Ltd[13] where the Continental Tyre company sued Daimler company for debts owing. The tyre company was incorporated in the UK but all except one of its shareholders were German residents. All the directors of the company also lived in Germany. The issue was whether the company had the right standing in England to sue and recover a debt when there was an ongoing war between Britain and Germany at the time. The tyre company was allowed to sign a summary judgment which was appealed, and Lord Reading, while affi rming the previous decision, emphasized that once a company was formed and registered under the Companies Act, it had a real existence with rights and liabilities as a separate legal entity. It was a different person altogether from the shareholders on the register therefore if the appellants were to succeed then the debt owed would be payable to the shareholders and not to the company. However, a debt due to the company was not a debt due to the shareholders. The House of Lords reversed this decision and Lord Parker stated that while no one could deny the separate legal existence of a company, the character of the members of the company was not irrelevant to the character of the company. As much as a natural person could have enemies, the company as a legal person could also have enemies. He went further to state that the acts of a companyà ¢Ã¢â€š ¬Ã¢â€ž ¢s organs, directors, managers and so forth were the acts of the company and may invest in it enemy character. The differe nce between the approach of the Court of Appeal and the approach of the House of Lords is noticeable in this case. The idea of a company having a separate legal personality is popular in the sense that it retains a personality different from that of its shareholders. Therefore as an artificial creation of law, it also retains the nationality of the place in which it was incorporated.[14] It seems a bit arbitrary that a company is given the characteristics of its shareholders if as a limited liability, it has been separated from them in the first place. A very recent case which shows support for attributing the character of shareholders to the company is the United States case of Burwell v. Hobby Lobby Inc.[15]The United States Supreme Court held that closely held corporation owners could be exempted from a law based on their religious beliefs if there was a less obstructive method of promoting the lawà ¢Ã¢â€š ¬Ã¢â€ž ¢s objective. In this case, the owners of Hobby Lobby Inc. refu sed to provide contraception for their female employees because of their religious beliefs. The basis of this decision was to extend rights to corporations to protect the rights of the people connected with the corporation including its shareholders.[16] In recent times however, the courts have been less willing to lift the corporate veil. In the case of Prest v. Petrodel Resources,[17] Mr Prest owned a network of offshore companies over which he exercised total management control. The business of those companies was originally limited to owning various residential properties, including the matrimonial home he shared with his wife, but later the companies were used in his business. When their marriage failed Mrs Prest made a claim under sections 23 and 24 of the Matrimonial Causes Act 1973 for financial assistance based, in part, on the value of the real estate owned by that network of companies. Mr Prest argued that he was not entitled to those properties and refused to comply w ith orders for full disclosure as to his assets. In giving their judgement, the Supreme Court laid down the appropriate situations in which the corporate veil could be lifted. Lord Sumption found that in the case of piercing the corporate veil, it was only cases which were true exceptions to the separate legal personality rule, where a person who owned and controlled a company could be said in certain circumstances to be identified with it in law by virtue of that ownership and control. He went further to state that in civil law jurisdictions, the juridical basis of lifting the corporate veil is generally the concept of abuse of rights, where the veil could be lifted in cases of misuse, fraud, malfeasance or evasion of legal obligations. The broader principle in English law however, was that the corporate veil may be pierced only to prevent the abuse of the corporate legal personality. The abuse could be the use of a company to evade the law or to frustrate its enforcement. Th e court may then pierce the corporate veil for the purpose, and only for the purpose, of depriving the company or its controller of the advantage that they would otherwise have obtained by the companys separate legal personality. The separate legal personality principle has also been applied internationally. In Rayner v Department of Trade and Industry,[18] the International Tin Council was a United Nations international organisation established by a treaty to regulate the tin market and it had various member states as shareholders. The tin market got into difficulty and the contracts which were made could not be honoured. It was held that that the International Tin Council had a legal personality separate and distinct from its members and that under the common law the members of the Tin Council had no liability for the contracts made. Internationally, fraud seems to be the motivating factor for several countries in applying the principle and its exception. In Germany, lifting the veil is known as breaching the walls of the corporation, [19]and it is applied where a sole shareholder has failed to distinguish between his private assets and the assets of the company and has gained a benefit from that.[20] The principle is however limited to situations where the actions of the shareholder has rendered it impossible for creditors to obtain satisfaction of debts from the companyà ¢Ã¢â€š ¬Ã¢â€ž ¢s assets.[21] There is also the issue of undercapitalization where a shareholder gives a loan to the company and actually receives payment on that debt from the company. Fraud is also present in other Civil Law jurisdictions like France and Argentina, and an example of fraud is in one man companies. This type of company is treated as fictitious on the basis that that a company is treated as a contract, and plurality is an important element of contract law, thus a company which is made up of one man lacks the element of a contract and is therefore fictitious.[22] Al so the concept of fraud in terms of companies is used to solve problems arising from a company being used as a shelter to evade contractual obligations towards third parties.[23] There have been times where the UK courts have ignored the corporate veil completely because of fraud. This usually happens when a company has been set up as a means to defraud creditors or other bodies, and is operating as a faÃÆ' §ade or a sham. The illustration of this principle is in the case of RE Darby, ex parte Brougham.[24] Darby and Gyde, two undischarged bankrupts with convictions for fraud registered a company called City of London Investment Corporation Ltd (LIC) in Guernsey. It had seven shareholders and issued  £11 of its nominal capital of  £100,000. They were the only directors and entitled to all profits. The company then registered another company in England called Welsh Slate Quarries Ltd, for  £30,000. It bought a quarrying licence and plant for  £3500 a nd sold it to the new company for  £18,000. The prospectus invited the public to take debentures in the new company but failed to mention the names of the two incorporators or the fact that they would receive the profit on sale. The new company failed and went into liquidation. The liquidator claimed Darbyà ¢Ã¢â€š ¬Ã¢â€ž ¢s secret profit, which he made as a promoter. Darby objected that the first company had been the promoter of the second and not him. The court held that they had incorporated the company in order to perpetrate a fraud. They acted through the company in order to make a profit, which is why they concealed their identity as the promoters of the new company so they could hid behind the separate personality of the old company.[25] When the principle of a separate legal entity is applied to group companies, every member in a group of companies has a separate identity and in the same vein they are separated completely from their shareholders, whether the shareh older is a private person or a holding company. Thus a holding company cannot control the documents of its subsidiary.[26] The UK Companies Act 2006 defines a group of companies as a parent undertaking and its subsidiary undertakings.[27] Accordingly, one company runs as the head, or holding company and runs a number or legally separate companies which make up the group.[28] However, the application of the separate legal entity principle to cases involving liability in group companies has not always been straight forward. Judges have previously relied on tools like agency[29] or the fact that group companies can be regarded as a separate legal entity in order to lift the corporate veil. In DHN Food Distributers Ltd v. Tower Hamlets London Borough Council,[30] the courts were willing to treat a parent company and its subsidiary as a single economic entity. In giving his judgement, Lord Denning stated that when a parent company owned all the shares of the subsidiaries, it could contro l their every movement. These subsidiaries are then bound hand and foot to the parent company and must do just what the parent company says. A second example is in the case of Re FG (Films) Ltd,[31] where the courts were willing to create an agency relationship between a British subsidiary and its American shareholder in order to lift the corporate veil. By the terms of an agreement between the two companies, the American company had undertaken to finance the making of a film by the British subsidiary. The film was held to be an American film and therefore was not registered as a British one. The basis of this agency relationship used by the courts is that the à ¢Ã¢â€š ¬Ã‹Å"principalà ¢Ã¢â€š ¬Ã¢â€ž ¢ (controlling shareholder or holding company) had induced the à ¢Ã¢â€š ¬Ã‹Å"agentà ¢Ã¢â€š ¬Ã¢â€ž ¢ (the company or subsidiary) into acting according to their directions, and therefore the act of the à ¢Ã¢â€š ¬Ã‹Å"principalà ¢Ã¢â€š ¬Ã¢â€ž ¢ was the act of the company.[32] The introduction of a single economic entity in group companies has actually been met with a negative response.[33] Industrial Equity v. Blackburn[34] has found that the principle works to prevent a holding company from handling a subsidiaryà ¢Ã¢â€š ¬Ã¢â€ž ¢s profits as its own. The Australian High Court went further to state that in the absence of a contract creating some additional right, the creditors of company a subsidiary company within a group, could only look to that company for payment of their debts. They could not look to the holding company, for payment. Also, in Woolfson v. Strathclyde Regional Council,[35] the House of Lords refused to follow the ruling in DHN Food Distributers Ltd v. Tower Hamlets London Borough Council and Keith L.J affirmed that the only reason to pierce the corporate veil would be where a company was operating as a faÃÆ' §ade. He stated that in the DHN Foods case, the company that owned the land was the wholly-owned subsidiary of DHN who was in con trol of anything which might affect the business. In the Woolfson case however, the company had no control over the owners of the land thus Woolfson was not entitled to any compensation. Generally, it seems the courts are leaning towards the application of the separate legal entity principle but with a number of reservations. In Adams v Cape Industries,[36] the Court of Appeal looked at the instances of agency, the group as a single economic entity and the subsidiary company used as a faÃÆ' §ade for the parent company. The court stated that there was no justification for lifting the corporate veil using the tool of agency, Slade LJ stated that there was no presumption of agency, neither was there one that the subsidiary was the parent companys alter ego. On the issue of groups being a single economic unit, the judge stated that there is no general principle that all companies in a group of companies are to be regarded as one. Quite to the contrary, the fundamental principle wa s that each company in a group of companies is a separate legal entity possessed of separate legal rights and liabilities[37] the judge went further to state that the corporate veil could only be lifted in the case where the company was operating as a faÃÆ' §ade or a sham. The effect of this was summed up by Templeman L.J. in the case of Re Southard Co Ltd[38] where he stated: à ¢Ã¢â€š ¬Ã…“A parent company may spawn a number of subsidiary companies, all controlled directly or indirectly by the shareholders of the parent company. If one of the subsidiary companies, to change the metaphor, turns out to be the runt of the litter and declines into insolvency to the dismay of its creditors, the parent company and the subsidiary companies may prosper to the joy of the shareholders without any liability for the debts of the insolvent subsidiary.à ¢Ã¢â€š ¬Ã‚ [39] It would seem that the general position on lifting the veil for group companies is that the courts will not fin d holding companies liable for the acts of their subsidiary, however, the position is still in dispute. In the case of Millam v The Print Factory,[40] the employees of a wholly-owned subsidiary were found to be the employees of the holding company because the activities of the subsidiary company were so integrated with those of the holding company that the two companies were considered as a single entity. Although the companies were separately registered, the holding company paid the wages of the subsidiaryà ¢Ã¢â€š ¬Ã¢â€ž ¢s staff, managed their pension scheme and actually combined some of their meetings. Also in the case of Beckett Investment Management v. Hall,[41] a restrictive trade contract was held to include a holding company and its subsidiaries because Considering, it is submitted that the UK courts have previously taken a very eager view of lifting the corporate veil. It comes from the fact that there should be accountability where corporations are involved. The lim ited liability is in place to protect the shareholder, though, the very same people it protects have also come up with a way to abuse it by hiding behind it whenever it suits them. It should however be stated that creating a way for courts to go poking behind corporate veils has the disadvantage of making the law very uncertain, which seems to be the direction the courts have taken in terms of their recent decisions. It is submitted that the idea of a separate legal personality keeps the image of a corporation intact to enable it to carry on business, and the aim of the courts in lifting or piercing the corporate veil should be to protect the company. Thus in as much as the shareholders or the directors of a corporation might be personally liable for debts owed to creditors, the reach of the court should be to point Basically that doctrine exists in order to preserve the principle of limited liability. It is concerned with the rights of creditors in the context of company law. 1 [1] Salomon v. Salomon [1897] AC 22 [2] Len Sealy Sarah Worthington, Sealys Cases and Materials in Company Law (9th edn, Oxford University Press 2010) pg. 32 [3][1897] AC 22 [4] Lord Macnaghten, Salomon v. Salomon [1897] AC 22 [5] ibid [6][1961] AC 12 [7] Macura v. Northern Assurance Co. [1925] AC 619 HL [8] JJ Harrison (Properties) Ltd v. Harrison [2001] EWCA Civ 1467, [2002] 1 BCLC 162 [9] Len Sealy Sarah Worthington, à ¢Ã¢â€š ¬Ã…“Sealys Cases and Materials in Company Lawà ¢Ã¢â€š ¬Ã‚  (9th ed, Oxford University Press 2010) pg. 53 [10] RE Darby, ex parte Brougham [1911] 1 KB 95 (Kingà ¢Ã¢â€š ¬Ã¢â€ž ¢s Bench Division) [11] Ottolenghi S, à ¢Ã¢â€š ¬Ã‹Å"From Peeping Behind the Corporate veil to Ignoring it Completelyà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1990) 53 MLR 338 pg.338 [12] Cohn EJ and Simitis C, à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã…“Lifting the Veilà ¢Ã¢â€š ¬Ã‚  in the Company Laws of the European Continentà ¢Ã¢â€š ¬Ã¢â€ž ¢ 12 International Comparative Law Quarterly 189 pg.219 [13] [1916] 2 AC 307 [14] Gasque v. IRC [1940] 2 KB 80 (Kingà ¢Ã¢â€š ¬Ã¢â€ž ¢s Bench Division) [15] [2014] 573 U.S__ [16] The Dictionary Act defined persons to include corporations and the Religious Freedom Restoration Act, 1993 extended religious freedoms to all à ¢Ã¢â€š ¬Ã‹Å"persons.à ¢Ã¢â€š ¬Ã¢â€ž ¢ [17] [2013] UKSC 34 [18] [1990] 2 AC 418 [19]Cohn EJ and Simitis C, à ¢Ã¢â€š ¬Ã‹Å"à ¢Ã¢â€š ¬Ã…“Lifting the Veilà ¢Ã¢â€š ¬Ã‚  in the Company Laws of the European Continentà ¢Ã¢â€š ¬Ã¢â€ž ¢ 12 International Comparative Law Quarterly 189 [20] Ibid pg.191 [21] Ibid [22] Ibid pg. 842 [23] Ibid pg. 844 [24] [1911] 1 KB 95 (Kings Bench Division) [25] The legislative basis for the holding in this case can be found in section 213 of the Insolvency Act, 1986 [26] Lonrho v Shell [1980] 1 WLR 627 [27] Section 474, UKà ¢Ã¢â€š ¬Ã¢â€ž ¢s Companies Act, 2006 [28]Collins H, à ¢Ã¢â€š ¬Ã‹Å"Ascription of Legal Responsib ility to Groups in Complex Patterns of Economic Integrationà ¢Ã¢â€š ¬Ã¢â€ž ¢ 53 MLR 731 [29] In the case of Salomon v. Salomon the argument for agency was advanced where the company was said to be the agent of Salomon. [30] [1976] 1 WLR 852 [31][1953] 1 WLR 483 (Chancery Division) [32] In the case of Gramophone and Typewriter Limited [1908] 2KB 89, the court held that a subsidiary could not be held to be the agent of their holding company. [33]Though the corporate veil can be extended o that it encompasses a group of companies. Here the veil is lifted of a company them drawn over the larger group of companies thus the court is dealing with an à ¢Ã¢â€š ¬Ã…“enterprise entity.à ¢Ã¢â€š ¬Ã‚  The Companies Act, 2006 gives credit to this extension under section 399 where, the directors of a parent company, as well as preparing individual accounts for the year, must also prepare group accounts for the year unless the company is exempt from that requirement. Ottolenghi S , à ¢Ã¢â€š ¬Ã‹Å"From Peeping Behind the Corporate veil to Ignoring it Completelyà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1990) 53 MLR 338 pg. 347 [34][1977] 137 CLR 567 [35] [1977] 137 CLR 567 pg.577 [36] [1990] Ch 433 (Court of Appeal) [37] The Albazero [1977] AC 774 at p. 807 per Roskill LJ. [38] [1979] 3 All E R. 556 [39] Re Southard Co Ltd. [1979] 3 All E R. 556 at 565. [40] [2007] EWCA Civ 322 [41] [2007] EWCA Civ 613