HR Planning for British Airways Essay

Human Resources are one of the most important departments in any organisation. It plays a big role for the company and influences every employee because it is responsible for managing employee costs. However, Human Resources Department also has responsibility for many other tasks including Recruitment and Selection, Training. The most important task that performed by HR Department is Workforce Planning. Basically, Workforce Planning is the process when business needs to make sure that it recruits the right people. The recruitment and selection of best employees might be very hard. First of all, the company has to understand the importance of Human Resources Management and ensure they spend enough capital on each employee. As many companies nowadays failed to do that and can’t survive among its competitors. Human element is the key to potential success and it is what the company should care the most about. If you have the right employees with right skills and they are well motivated then they will perform a good job and will bring the company more profit. British Airways is one of the leading global airlines that I have selected for this assignment. British Airways is aware of the importance of Human Resource Management. Therefore, as the employer they are providing the professional environment for its employees where they can be treated with respect. British Airways also trains and motivates the employees by communicating ethical policies and socially responsible behaviour to them. It makes employees to work more efficiently. There are many external and internal factors that can affect Human Resource Planning and that any organisation should be aware of. The main external factors that affect British airways are political, economic, technological and social. The airline industry is highly affected by political factors. British Airways’ business operation and decisions are influenced by regulations and policies. Regulations can be such as routes that an airline chooses to fly, the business partners the airline works with, the airport slots it uses as well as the fare it sets and the infrastructure costs it pays. Safety and security is another area that is highly regulated by governments. British Airways is engaging with different governing bodies such as European Union and national government to ensure safety and security while causing minimal inconvenience to customers. The airline business is highly sensitive to any economic downturn. There are a number of factors that affected the business of British Airways. For example, prices increases in oil and commodities. Consumer and business confidence on airlines declined because of rising unemployment, uncertainty in the capital markets, the erosion of household budgets and falling house prices. Therefore the customers are likely to cut its costs on holiday and airline tickets which means lower profits for the company. Social factors that affecting HR planning need to be taken in an account by British Airways. Nowadays passengers are choosing trusted airlines, First of all the fall in the economy is also pushing customers to seek for lower prices. With the developing of Internet and other technological advances it is easier for the customers to choose among different airlines and even get personal recommendations online, therefore the customers became less loyal. As every other company nowadays British Airways is also affected by technological factors. Maintaining a corporate website which handles customer queries and reservations is a new requirement for the airlines. British Airways has managed with this task and also the company keeps regularly up to dated with its competitors and technology world. Making customers experience more easier and faster British Airways also uses online self check in and self check in machines at the airports which makes the process much easier for its customers. Like many organizations today, British Airways face several environmental issues such as climate change. Governments and policy makers are now creating regulations and policies that will require airlines to curb emissions growth. All airlines have to meet a comprehensive range of local, national and international environmental regulations As well as there is a number of external factors affecting HR Planning, there are also internal policies and procedures impact HR activities. For example, if the company is committed to promoting from within, HR must ensure employees receive appropriate training and development to be ready for promotion when the time comes. HR should monitor the number of employees eligible for retirement and ensure potential replacements or other staff members are trained to avoid a sudden departure of business

Andres Bonifacio: Story of Life Essay

Bonifacio was the son of Santiago Bonifacio and Catalina de Castro in Tondo, Manila, and was the eldest of five children.[7] His father was a tailor who served as a tenyente mayor of Tondo, Manila, while his mother was a mestiza born of a Spanish father and a Filipino-Chinese mother who worked at a cigarette factory. As was custom, upon baptism he was named for the saint on whose feast he was born, Andrew the Apostle. Bonifacio’s normal schooling was cut short when he dropped out to support his siblings after both their parents died of illness. He sold canes and paper fans he made himself and made posters for business firms. In his late teens, he worked as a mandatory for the British trading firm Fleming and Company, where he rose to become a corregidor of tar, rattant and other goods. He later transferred to Fressell and Company, a German trading firm, where he worked as a bodeguero (storehouse worker). Bonifacio was also a part-time actor who performed in moro-moro plays. Not finishing his normal education, Bonifacio was self-educated. He read books about the French Revolution, biographies of the Presidents of the United States, books about contemporary Philippine penal and civil codes, and novels such as Victor Hugo’s Les Misà ©rables, Eugà ¨ne Sue’s Le Juif errant and Josà © Rizal’s Noli Me Tangere and El Filibusterismo. Aside from Tagalog and Spanish, he could speak a little English, learnt from his working for J.M. Fleming and Co.[8] Bonifacio was married twice, first to a certain Monica who died of leprosy. He then married Gregoria de Jesà ºs of Caloocan in 1893. They had one son named Andrà ©s who died in infancy of smallpox (Chickenpox). In 1892 he joined Rizal’s La Liga Filipina, an organisation which called for political reform in the colonial government of the Philippines. However, La Liga disbanded after only one meeting as Rizal was arrested and deported to Dapitan in Mindanao. Bonifacio, Apolinario Mabini and others revived La Liga in Rizal’s absence and Bonifacio was active at organising local chapters in Manila. La Liga Filipina contributed moral and financial support to Propaganda Movement Filipino reformists in Spain.

Merits and Demerits of Shakespeare

Merits and Demerits of Shakespeare In Preface to Shakespeare, Johnson has shown the merits and demerits of Shakespeare based on the plays he has edited. Here he gives the readers some sound ideas about the virtues and faults of Shakespeare. That Shakespeare's characters have am interaction with nature and that his works have a universal appeal are the major assertions of Johnson in favour of Shakespeare's merits and what he says about the demerit of Shakespeare is that Shakespeare tries more to please his audience than to instruct them which is a serious fault because it is always a writer's duty to make the world morally better.However, what Johnson has seen as the merits and demerits of Shakespeare are given below: Merits of Shakespeare: At first Johnson explicates Shakespeare's virtues after explaining what merit can be determined by the Shakespeare's enduring popularity. He proceeds thence to elevate Shakespeare as the poet of nature. â€Å"Nothing can please many, and please lo ng, but just representations of general nature† (7). He says, â€Å"Shakespeare is above all writers, at least above all modern writers, the poet of nature; the poet that holds up to his readers a faithful mirror of manners and of life†. 8). Again he says that Shakespeare's characters â€Å"are the genuine progeny of common humanity † In the writings of other writers , a character is too often an individual but a character of Shakespeare has a universal appeal, and his characters are the representatives of the common people. Moreover Shakespeare is a prophet figure and from his writings we find the ideas of worldly wisdom and the principles which are of value in society and at home. He says, â€Å"from his works may be collected a system of civil and economical prudence. (9) Again he says that by writings Shakespeare brings out the whole sphere of life. Moreover his heroes are like common human beings. And the qualities that are found in Shakespearean heroes can be found in every human being. As he says , â€Å"Shakespeare has no heroes; his scenes are occupied only by men, who act and speak as the reader thinks that he should himself have spoken or acted on the same occasion† (13) In his characterization and dialogue, Shakespeare â€Å"overlooks the casual distinction of country and condition,† striking at the center of humanity (15).The nature captured by Shakespeare's characters is exhibited in the â€Å"ease and simplicity† of their dialogues (10) Indeed, Johnson points out, the distinctions of character stressed by such critics as Voltaire and Rymer impose only artificial burdens on the natural genius of Shakespeare. He lays an enormous stress on Shakespeare's adherence to general nature. He states: â€Å"Shakespeare always makes nature predominate over accident; and if he preserves the essential character, is not very careful of distinctions superinduced and adventitious.His story requires Romans or kings, but h e thinks only on men. â€Å"(15) Johnson goes further in his defense of the Bard's merit, extending his argument from the characters within his plays to the genre of the plays themselves. In the strictest, classical sense of the terms, Johnson admits, Shakespeare's works cannot be fairly called comedies or tragedies. For this too, his plays earned harsh criticism from Johnson's contemporaries. Johnson, though, sees in the mixture of sorrow and joy a style which â€Å"approaches nearer than either to the appearance of life† (20).Demerits of Shakespeare: His praise for Shakespeare, which centers on the Bard's sublunary approach to character, dialogue, and plot, does not blind him to the poet of nature's weaknesses. Johnson airs Shakespeare's imperfections without hesitance. In doing so, though, he does not weaken his arguments; he simply establishes his credentials as a critic. As Edward Tomarken points out, â€Å"for Johnson, criticism requires, not intrusive sententiae, but evaluative interpretations, decisions about how literature applies to the human dilemma† (Tomarken 2).Johnson is not hesitant to admit Shakespeare's faults: his earlier praise serves to keep those flaws in perspective. Even without that perspective, however, Johnson's censure of Shakespeare is not particularly harsh. For the most part, Johnson highlights surface- level defects in the Bard's works: his â€Å"loosely formed† plots, his â€Å"commonly gross† jests, and- most ironically-his â€Å"disproportionate pomp of diction and a wearisome train of circumlocution† (Johnson 34, 35). The most egregious fault Johnson finds in Shakespeare, though, is thematic.Unsurprisingly, Johnson exhibits emphatic distaste for Shakespeare's lack of moral purpose. Johnson argues that he † He sacrifices virtue to convenience, and is so much more careful to please than to instruct, that he seems to write without any moral purpose † (33). In leading â€Å"his per sons indifferently through right and wrong† and leaving â€Å"their examples to operate by chance,† Shakespeare has abandoned his duty as an author as the righteous Johnson would have that duty defined (33). This is, in his eyes, Shakespeare's greatest flaw, though it does not supercede his other merits.Shakespeare's plots, he says, are often very loosely formed and carelessly pursued. He neglects opportunities of giving instruction or pleasure which the development of the plot provides to him. He says, â€Å"The plots are often so loosely formed, that a very slight consideration may improve them, and so carelessly pursued, that he seems not always fully to comprehend his own design. † (34). Again he says that in many of his plays, the latter part does not receive much of his attention. This charge is certainly true.The play of Julius Caesar clearly shows a decline of dramatic interest in its second half. He says, â€Å"It may be observed, that in many of his pl ays the latter part is evidently neglected. When he found himself near the end of his work, and, in view of his reward, he shortened the labour, to snatch the profit. â€Å"(35) Next, Johnson considers Shakespeare's style and expression. According to him there are many passages in the tragedies over which Shakespeare seems to have laboured hard, only to ruin his own performance.The moment Shakespeare strains his faculties, or strains his inventive powers unnecessarily, the result is tediousness and obscurity. However, Johnson adopts purely a neo-classical point of view which emphasizes the didactic purpose of literature as much as its pleasing quality. In this respect we can't agree with Johnson's condemnation of Shakespeare. Because all that we can expect from an artist is that he should give us a picture of life as he sees it.

Why Marijuana Should Be Legalized Essay Example | Topics and Well Written Essays - 500 words

Why Marijuana Should Be Legalized - Essay Example The essay "Why Marijuana Should Be Legalized" discusses the legalization of marijuana. Marijuana is a type of medicine which is used in several nations from ancient periods. From the viewpoint of prescription, marijuana is illegal in the USA because it is used as a drug, and has been traditionally associated with harmful narcotics. Presently, marijuana is considered as an unlawful element at the national level and is registered in the U.S. â€Å"Controlled Substances Act†, but marijuana can be effectively used for health benefits. Several surgeons and medical investigation specialists conveyed that marijuana can be used as remedies for certain health related problems. Marijuana can rouse hunger and is useful for biliousness. Besides, marijuana is also useful for cure of glaucoma. By any extent of the rational investigation, marijuana can carefully be used under an administered routine of medical care. Legalizing marijuana can also decrease the offense linked with the drug busi ness. The main reason is that unlike other drug markets, the market for marijuana produces a comparatively lesser number of criminal offenses. In comparison with other drug affected criminals, the marijuana affected criminals represent offensive activities below 10% for infringement of drug law. If marijuana is utilized as a drug, then legalization of it might decrease the crime related to alcohol. Besides, through marijuana legalization, there is a possibility that police officers will be able to focus more on the other crimes.

Chemistry of hazardous materials Essay Example | Topics and Well Written Essays - 500 words

Chemistry of hazardous materials - Essay Example High Explosives Accident, 2004). The chemicals involved in this particular explosive accident include TNT or trinitrotoluene in the first room where the initial explosion took place and where the workers were dealing with boosters, which were in fact made up of TNT. The other chemical was PETN or pentaerythritol tetranitrate, which was present in the neighboring rooms and was actually the main chemical component of the drying explosives (Sierra Chemical Co. High Explosives Accident, 2004). The interaction of chemicals involved mainly the solidification of the base material for boosters – namely TNT and other high explosives, and their ensuing explosion that caused the explosion of the PETN in the neighboring room. Based on the reconstruction of evidence conducted by the U. S. Chemical Safety and Hazard Investigation Board, apparently one worker left in the booster room around 50 to 100 pounds of base material made up of TNT and other high explosives in a pot. As no other worker or operator utilized the base material, it solidified due to the extremely low temperature on the outside. The next day, while assuming that the base material in the pot had been used, he may have turned on the motor to the agitator blades right away without checking whether the pot was empty or not. This triggered the first explosion. The reason for this is that â€Å"the heavy mixer blade had probably become embedded in the hardened explosive† (Sierra Chemical Co. High Explosives Accident, 2004). The ensuing explosion must then have caused heavy debris to rain down on the PETN drying explosives which was 220 feet away from the building, thus causing the secondary explosion (Sierra Chemical Co. High Explosives Accident, 2004). Before the incident, the U. S. Occupational Safety and Health Administration or OSHA had required that certain safety systems for hazardous chemical operations should be

Rhetorical Analysis of Academic Communities of Writing and Discourse Essay

Rhetorical Analysis of Academic Communities of Writing and Discourse in the Technical Fields - Essay Example Notably, each journal has its own purpose and has defined academic traits and levels of academic integrity that authors and contributors should have. This paper will present a rhetorical analysis of five journals using an article from each of the journals as an example, and highlighting the differences and similarities in the purpose, content, use of tone and language. This journal contains both English and French articles and invites peers to review articles in different publications. The purpose of the journal is publishing articles related to fundamental studies of the transfer processes on thermal aspects as well as related applications. It has a defined scope of the articles it publishes which must be related to thermal processes in physics. The reason why this journal publishes in both English and French in an effort to increase the readers considering these languages are the most widely used international languages. One of the articles selected from this journal titled â€Å"thermal conductivity measurement of amorphous si/ sige multilayer films by three omega method,† it becomes evident that the journal places emphasis on the use of an academic tone while presenting the research finding (Shen et al 20). The structure of presentation of the research findings should be very elaborate as revealed in this article. Moreover, the authors contributing articles to this journal must back up their finding with graphical representations, diagrams, and illustrations as required by the physics field. Since the journal targets readers who are either students specializing in the field or other professional with advanced knowledge in the field, the tone and language level reflect an advanced academic level (Shen et al 22). This journal targets to cover articles that discuss any of the scientific and technological processes related to fatigue. In this case, the

Independent evaluation of agile methods Literature review

Independent evaluation of agile methods - Literature review Example Teams looking for an appropriate way of monitoring scope and at the same time enhance project implementation timelines look to agile project management. This method assists firms attain a healthy balance between waste reduction, cost cutting and quality preservation (Patel, Seyfi, Taghavi, Wills, Liu, Latih, & Misra, 2012). While conveying value to the buyer in a cost efficient way, agile project administration sustains the intricacies of the projects in a way that the conventional systems would not have in any way. Agile methods can help teams dispense products more swiftly while making them acclimatize to vicissitudes more easily than when they would have used the traditional methods (Maarit, Outi, & Pekka, 2010). The other benefits of agile methods of project management are that it cuts the time spent on information gathering while also enhancing implementation timelines. Agile project management simplifies teamwork and group effort enhancing overhead costs involved in project implementation. Agile project management is an adaptive approach that stresses on collaborative work or in other words revolutionary driven work done which demands team work in its execution and a continuing involvement of interested parties in the project cycles. The response of the interested parties is crucial during the execution process of the project when the end consequence is indefinite in some extent. In such an environment, the collaborations are inducted in every stage. This is important because it permits to reexamine the project on the basis of the interested parties’ feedback and reallocate work in the project accordingly. Working progressively gives room for the teams to stay on track and also for the consumers to attain what they need without the risk of profligacy (Qureshi, 2012). The Agile method of project management encompasses a number of factors making it conceivable for agile management teams to

Immigration, civil rights, terrorism Thesis Example | Topics and Well Written Essays - 250 words

Immigration, civil rights, terrorism - Thesis Example ally occurs through illegal crossing of border, immigration on false visas from other countries, overstaying after expiry of Visa or Border Crossing Card, drug smuggling and identity theft. USA has been critical about its immigration policy since beginning, however, the efforts became quite strong and serious with the World Trade Centre attack by Alkhaida on 11th September, 2001. In 1990 the US Congress appointed the Commission on Immigration Reform for reviewing its national policies and laws and to suggest necessary changes. In 2001, USA modified its immigration law for enhancing the ability of federal authorities to prevent foreign terrorists from entering USA and to detain foreign terrorist suspects (Charles Doyle, 2001). This led to a conflict of personal freedom and dignity enjoyed by the immigrants in USA. The person’s freedom may be severely affected by over interference of the Police as in case of Lawrence v Texas (2003). However, the social security of the nation is highly important and law on immigration has to be very transparent and efficient for controlling the element of terrorism and hence affirmative action on controlling terrorism is highly essential in USA but at the same time all possible efforts must be taken to protect the civil rights, promote racial harmony and avoid the undue interference in personal freedom of foreign nationals living inside the

The Cut Flower Cluster in Kenya Essay Example | Topics and Well Written Essays - 1000 words - 1

The Cut Flower Cluster in Kenya - Essay Example These include the overall economic performance and its subsequent effects upon the local and the international consumers. Similarly, there is the aspect of macro performance that entails several things. For instance, in terms of the national Gross Domestic Product (GDP), cut flower has been very influential. It contributes about 8% in terms of total export revenues. On the other hand, there is the contribution of productivity has been high accompanied by profitability margins. This has been facilitated by the inadequate competitiveness that guides the innovation and productivity of cut flower in Kenya (Zeng 2008, p. 153). In other words, there has been tremendous improvement on the transaction costs that work towards the boosting of productivity and overall efficiency. The productivity has also been able to received sustenance from the export growth that has not decreased making productivity a fundamental choice of macro performance. However, there has also been the effect of the cut flower grown in Kenya in the context of inflation in the outlook of the country’s economy. For example, transporters of the cut flower have experienced the instances of high inflation costs especially with the fall of the dollar in the local and global market. This is because it affects the prices of the local production that is paramount in the boosting the average productivity. Alternatively, there is also the revenue generated from exports that are also affected by the high inflation of the new dollar economy. Therefore, it may be added that the fall of inflation has also helped in the cut of about 14% of the cut flower prices in the global market (Webber & Labaster 2010, p.66). This suggests that one-third of total supplies are current being sold in Europe to accrue export revenues and an increase in productivity. Cut flower also has an adverse effect on the currency of the nation in the context of the effects on the

Ethical Issues of companies Essay Example | Topics and Well Written Essays - 1500 words

Ethical Issues of companies - Essay Example In simple words, there is more harm than gain from whistle-blowing in the current setting. As a result, this action is wrong under the utilitarianism framework. This framework states that only those actions should be taken which gives greater good to the society than the costs. In this case, there are more costs associated with the action than the benefits and hence I should be passive and let how things move on until I decide to whistle blow, which is not an option at the moment. If we look at the risks associated with whistle blowing, they are loss of jobs for employees, company's reputation at stake, my job in jeopardy and the chance that the company may lose market share against the major competitor. The gains from the action will be people would be aware about Delectable's nonexistent quality control and this can lead them into making a better choice. However, weighing the two options, one feels that there are greater risks than gains and hence I should not whistle blow. A2) the attitude of workers is purely materialistic at the moment. They are paid on piece rate and hence they want to produce as much goods as possible while ignoring the quality of what they manufacture. The policy of quality control won't be effective in the current company's culture as workers are just trying to make more goods as they are paid on the basis of how much they produce and because quality control may hinder the speed of their work, the policy won't be as effective as it will be in other settings. There are a lot of issues that the management needs to readdress looking at the attitudes of workers and supervisors on the factory floor. First of all, the management needs to incorporate in people that the workers should respect the people from higher level of hierarchy instead of blocking their work. This can be done by the management by showing them their authority and by firing those people who do not cooperate with the top brass. The main pressure is that the workers a re not willing to cooperate and the situation can only improve if either the authority is delegated to the quality control department or the management itself fires or threaten people who are hindering the efforts of the quality control department. PART B B1) The government and state faced a major challenge in the form of underfunding to deal with the health and safety issue. There is hardly any possibility that the current staff of 60 can see 16000 food businesses in Georgia. Similarly, Delectable employs thousands of people and government will be threatened to take any action against the company as it would mean loss of jobs and unemployment. However, government can counter the problem by staffing more people in order to keep check and balance on most of the businesses in the state. The government should try to encourage people and organizations to fund FDA by telling them it would improve the general condition of the food businesses in the country and ensure that their offerings are hygienic and comply with quality and control standards. Government can also encourage the businesses to act in a socially responsible way. This can be done by giving tax holidays to company where there is no quality cases recorded reported against the compa ny. The government can also levy stricter rules on food businesses which could levy harsh penalties on these business and can ask them disclose the quality and contr

American and Finnish Work Teams Essay Example | Topics and Well Written Essays - 750 words

American and Finnish Work Teams - Essay Example Working together calls for the team members to understand their role and cultivate trustworthiness for the benefit of the group. There are emotional difficulties, which helps the team members to build trust and work closely with both American and Finnish teams. Teamwork is demonstrated by hard work and effort put by each in the team to ensure that they achieve the team's goal. A divided team cannot meet their target in this competing world where everyone struggles to produce the quality product to remain relevant. Whether the work teams involves employees in corporations, students in learning institutions or members of clubs and societies teamwork must be a very important thing for success. The differences include the Finland teams have a very positive attitude towards what they do and participate in especially Sauna. It is interesting to find even small apartment fixed with little Saunas demonstrating their importance in the Finish culture and was not for business purposes. American teams engage in matters relating to business including the football teams, whose players are heavily rewarded unlike Sauna, which is meant for the very scenario. American work teams focus on the individualism especially in situations where individual members in football teams are praised. Losing teams in America are normally forgotten I they do nothing to improve performance and other lose their members. Recognition is common for team members of the winning teams and become famous for their work even in big corporations.

Importance of Peer Review Essay Example for Free

Importance of Peer Review Essay A student in a graduate program must conduct research during the course of study. The purpose of this assignment is to discuss how one can determine which references are credible and which are not. Importance of Peer Review As a scholar-practitioner it is of utmost importance to know that information is obtained from a source which is peer reviewed. When a journal or article has been designated as peer reviewed this means that the information has been submitted to several of the authors peers for content review. The reviewers must agree that the information has been gathered through the use of proper research methods, and that it is accurate and original. Knowing that Articles Retrieved are from Peer-Reviewed Journals The articles I downloaded for this week’s application are peer reviewed. The Walden University library has a search feature which allows one to find only peer reviewed articles quickly and easily. This is the procedure I followed when obtaining my articles. If an article is obtained from a source other than the Walden library, verification of peer review can be done through Ulrich’s Periodicals Directory. Importance of Peer Reviewed Articles My area of interest is nursing education. It is important that the information I share with students has been peer reviewed. I want to make sure it is accurate and credible. Summary In summary, it is essential for students in a graduate program to always make sure resources utilized for research are peer reviewed. The information obtained for assignments must be reliable and accurate. References Cornell University. (April 5, 2011). Cornell University Library. Retrieved from http://olinuris.library.cornell.edu/ref/research/skill20.html Walden University. (2011). Walden University Library. Retrieved from http://library.waldenu.edu/689.htm

Factors Affecting Consumers

Factors Affecting Consumers The topic of this study, namely factors affecting consumers purchasing decision on hybrid cars in Malaysia. Hybrid cars are developed to reduce the level of gas emissions into the air and increase fuel economy. As fuel prices rise to the point where many consumers can no longer afford to drive as much as they once have, automobile manufacturers have been faced with many new challenges. Hybrid car are very similar to the gasoline powered automobile most people drive today, the difference is the hybrid cars on the road right now are gasoline-electric hybrids. Many gas powered hybrids are and will be in the available in market today and some that will be coming to Malaysia, that include Honda Civic Hybrid, Honda Insight, Toyota Prius, Hyundai Sonata Hybrid and etc. However, there are very few hybrid cars is to be seen in Malaysia. Only 327 hybrid cars were sold in 2010 (Ahmad, 2011) and 297 total units sold in the whole 2009 (Mahalingam, 2011). BACKGROUND OF STUDY To investigate the relation between independent variables which are price, design, excise duty, fuel economy, consumers environmental consciousness and dependent variable which is consumers purchasing behavior in purchasing a hybrid car. This research study is to examine the association of the independent variables that impulse buying behavior of consumers on purchasing a hybrid car in Malaysia. RESEARCH PROBLEM The innovation of the fuel efficient and environmental friendly hybrid vehicles is becoming popular nowadays. Today, many consumers include Malaysians are becoming more sensitive to rising oil prices and becoming more environmentally friendly, Malaysians are considering the option to buying hybrid vehicles which that can saves them money and make a positive impact on our environment. A research is conducted to find out the consumer behavior of Malaysians and to investigate the factors affecting the consumers purchasing decision of hybrid cars. The questions arise are: Will customers consider hybrid cars are actually worth the money they spend? Will the rising of oil prices leads them to pay more attention to a cars fuel economy? Does the design of the hybrid cars affect their purchasing decision? Does the removal of excise duty for hybrid cars affect their purchasing decision? Or will their environmental consciousness suggest the purchasing of a hybrid car. RESEARCH OBJECTIVE The main objective is to find out the factors that affect consumers purchasing decision of hybrid cars in Malaysia. Through the application of many new and innovative technologies, the hybrid is an extremely efficient vehicle that also significantly reduces emissions. As a result, hybrid vehicles have been gaining in popularity because they are cheaper and consumer enjoys numerous incentives for purchasing a hybrid vehicle. However, the prices of hybrid vehicles in Malaysia are far more expensive compared to the prices in other foreign countries. RESEARCH QUESTION This study is only going to focus on the determinants of consumers purchasing decision of hybrid car in Malaysia. How price of the hybrid cars influence consumers purchasing decisions? What is the relationship between the design of the car and the influence it posses to consumers during decision making to purchase? Does excise duty on hybrid cars affects consumers purchasing decision? How a cars fuel economy will influence the purchasing decisions of consumers? Will a consumers environmental consciousness plays a role in their decision making to purchase a hybrid car? 1.6 SIGNIFICANCE OF STUDY Our study focused on the factors that affect consumers purchasing decision of hybrid cars. This study will determine whether price, design, excise duty, fuel economy, and environmental consciousness will affect consumers decision to purchase hybrid cars. It is important to find out how a consumer is willing to pay for a hybrid car and to know will the design; fuel efficiency and the removal of excise duty on hybrid car influence their purchase decision. There are consumer who will buy a hybrid car because it can save fuel and money, but there are consumers who are not willing to pay a high price for the hybrid car as well. It is crucial to determine the perspective of consumers since they are the end users of products and services. Hence, this study is important to analyse the various factors that influences consumers idea on purchasing, so that it is easy for manufacturers to take vital decisions to fulfill the demand of the consumers. 1.7 SCOPE OF STUDY This study will be focusing on the factors affecting consumers purchasing decision on hybrid cars in Malaysia. The study also focuses mainly on the automobile manufacturers such as Toyota and Honda. Nowadays, vehicles serve as a very important role in our current society where everyone needed transportation to continue their daily lives. Acquiring a car nowadays is considered a necessity, compared to the past where it was considered a luxury (CorpeduCar, 2010). At present time, a car has become our need for easier and faster transportation and to be on time with our daily activities (Harvey, 2011). Surveys have been done by individuals as it is always a best and direct way to obtain opinions from the consumers. This research will be focusing on generation X and Y. Survey questions to understand more about consumers behavior on purchasing a hybrid car will be distributed to consumers from generation X and Y. Generation X and Y were born between the years in 1960 till around 2000 according to Mark Winburn (2010) (as cited in White, 2010, p.4). This study carries out for respondents who are living in Peninsular Malaysia. Consumers from generation X and Y, being the largest generational demography is more concern about the looks and price of the vehicles. Full of gleaming sports cars and eco-friendly vehicles aimed at consumers from generation X and Y. (White, 2010) 1.8 ORGANISATION OF REPORT Chapter 1 This chapter shows the definition of the topic which is about hybrid cars. The factors affecting consumers purchasing decision of hybrid car is examined by using the independent variable that are price, design, excise duty, fuel economy and environmental consciousness. We tend to understand the problems before we conduct our research. After understanding the research problem, we conduct 5 objectives to study on. Chapter 2 We focus on literature review for this chapter. We define the terms of our research variables and also describe further about how and why is these variables related to this research. Chapter 3 For this chapter we are focusing on research methodology. Operational definition of research variable is done in this chapter. Besides that, we did some hypothesis in this research and also the description of the sources use in the research data. After that we describe about the sampling design of our research and also defining the instrument and measurement used in the research. Lastly is to explain how data is analyzed. Chapter 4 This chapter shows the results of the research. In this chapter we include descriptive analysis or demographic analysis and mean analysis. After that we did the normative test to every research variable. Then, we test hypothesis we did earlier end finally, we end up by doing the regression analysis. Chapter 5 This chapter shows some discussion and conclusion of the research. Besides that it shows the suggestion for future, limitation of study and etc. 1.9 SUMMARY In this introduction, a brief overview is given about hybrid cars. This chapter has also identified the research problem and research objectives for this study. The independent variables and research questions are stated for this study. The next chapter gives a more detailed explanation and a literature review for the topic. Chapter 2 Literature Review 2.1 INTRODUCTION This study finds out factors that influence consumers purchasing decision on hybrid cars. Through this research, there are five variables that influence consumers purchasing decision on hybrid cars which are pricing, design, excise duty, fuel economy, and environmental consciousness. The purpose of this study is to determine the factors that affect consumers purchasing decision on hybrid cars. In this chapter, literatures from past researchers are cited to support and explain the given variables in this study. 2.2 OVERVIEW OF LITERATURE This chapter will provide a description of the literature relevant to this study. This research seeks to examine the influence of price, design, excise duty, fuel economy, and environmental consciousness on consumers purchasing decisions. A theoretical framework will show the independent variables and dependent variables that is explained through this chapter as well as giving an overview of what has been reviewed by past researchers. 2.3 THEORETICAL FRAMEWORK Figure 2.1 Factors that affects consumers purchasing decision on hybrid cars Independent Variable Dependent Variable Price Purchasing Decision H1 Design H2 Excise Duty H3 Fuel Economy H4 Environmental Consciousness H5 Source: Adapted for this study 2.4 INDEPENDENT VARIABLES Price Price is one of the variables in this research. Product price are demonstrated to be the variables affecting consumers decisions. According to Chang (2009), price plays several roles in consumers purchasing decision making. For example, price can be an indicator of the degree of perceived sacrifice needed to purchase a product and an indicator of the level of quality. A higher perceived price leads to higher perceived quality and consequently to a greater willingness to buy. At the same time, the higher perceived price represents a monetary measure of what must be sacrificed to purchase the product, leading to a reduced willingness to buy. Consumers purchase decision are affected by price, a particular product may seem too expensive at its regular price, but a good value when it is discounted. Similarly, consumers will be motivated to shift to another brand or use a product less with an increase in price (Litman, 2004). Consumers make their choice, based on the information regarding all the products available on the market and price is an important factor of decision making (KazaKevitch, Torlina Hendricks, 2005). Price is always an important attribute in the decision-making process (Hermann et al., 2007; Lalwani Monroe, 2005; Chang, 2009; Webb, 2011). Playing a more complex role than often attributed to it, price has been a determining factor in consumer choice (Monroe, 1990; Chang, 2009). Consumers remembered information on past and present price and are able to acquire complete information on the attributes of products being considered as options, the objectives of which are to minimize the price paid (Chang, 2009). Progressive Insurance and NADA conducted a poll shows 46% respondents stated that price is still number one concern in their most important new-car attributes ranking (Bryant, 2006). In an interview showed that car buyers indeed consider price an important factor in their purchase decisions (Herrmann, Xia, Monroe Huber, 2007, p.51). In an analy sis of consumers willingness to buy a hybrid car, the purchase price would influence the willingness to buy according to (Tanaka et al.) as cited in (Kishi Satoh, 2005). A study published in UK found as many as 71% of customer said that price was the most important factor that influences car purchase (Bikash, Pravat Sreekumar, 2010, p.51). In a survey of 1,524 adults by the Japanese motoring organization JAF, 61% said it was important that the car was economical (JAF, as cited in Okamura Cairns, 2003). Consumers in Generation Y are concerned with price and getting a good value (Wolf, Carpenter Petrela, 2005). Most of the interviewees in the study conducted by Webb (2011) are very price conscious and that price is an extremely important factor and is the bottom-line when purchasing a product. The biggest concerning factor for purchasing a product was determined to be price (Webb, 2011). Hence, it is reasonable to suggest that price is one important component in influencing consum ers purchasing decisions taken by all age groups, including young adults on hybrid cars. By referencing the existing literature on price, it is hypothesised that: H0: There is no relationship between the price of hybrid car and consumers purchasing decision. H1: There is a relationship between the price of hybrid car and consumers purchasing decision. Design Design is one of the variables in this research. Consumers have expectations when buying a product. Through what consumers have acquired from their cultural environment, consumers motivation to buy and even to pay a high price is based on a value judgment, like and dislikes of a sociological and psychological nature. In Webb (2011) studies, majority of respondent in strongly agree (UK-31%, US-39%, Other-38%) and agree (UK-48%, US-46%, Other-46%) that the design of the product is a considering factor when buying. According to Jung et al. (2010), it is known from consumer surveys that the design of cars greatly influences on consumers affection and therefore leads to their purchasing decisions. Additionally, Jung et al. (2010) study provides a basis of understanding underlying consumers affection in terms of user-centered design. In order to improve consumers affection and influencing their purchase decisions as consumer spends more and more time in cars, manufactures are developing in terior design requirements to achieve positive results (Cho, 2005; Jung et al., 2010). There are hundreds of designs available on the market and it is difficult for consumers to choose one that catches their interest. Therefore, a cars body design plays a very influential factor (Hagemann, 2011). Dull and ugly cars do not sell, consumers will not be attracted to design that just does not look particularly good at all (Cato, 2009). Designs have a certain positive causal relationship with purchase intention indirectly and are important factors affecting purchase decision. Therefore, automobile manufacturers should consider designing heterogeneously and individually for vehicles to satisfy consumers fashion and individual needs on the basis of the quality assurance (Wang Li, 2010). In Nielsen (2010) online survey, the Nielsen Company looked at the factors most important to consumers when choosing new cars in the current economy. Surprisingly, 85% will consider buying if the new car we re available now and met the key requirements such as design, dependability and durability. 12% of the respondents will consider buying the hybrid car if it had a unique design that set apart from existing car models. Design adds value to the product, giving it distinction to attract consumers who are more focused on the design and brand name. By far, price is a big indicating factor within any demographic group for buying products, alongside with the design of the product itself (Webb, 2011). Marketers should design the brand or product to match the way consumers understand, utilise, and emotionally connect themselves to a product. Hence, it is reasonable to suggest that design is one of the important factors in influencing consumers purchasing decisions. By referencing the existing literature on design, it is hypothesised that: H0: There is no relationship between the design of a hybrid car and consumers purchasing decision. H2: There is a relationship between the design of a hybrid car and consumers purchasing decision. Excise Duty Excise duty is a tax or sometimes called duty in its simplest form and it is defined as levy and collection of duty on manufacture of goods (Kanak, 2002). Excise is imposed on consumption that is discouraged by the government such as alcohol and cigarettes, the production or sale of certain goods, normally luxury items as well as on gasoline and other fuels. On the other hand, excise is considered an indirect tax, meaning that the producer or seller who pays the tax to the government try to recover the tax by raising the price paid by the buyer. The Websters New International Dictionary, as mentioned in Kanak (2002), excise duty is any duty, toll, tax or an inland duty or impost levied upon the manufacture or sale or consumption of commodities within the country or tax upon pursuit of certain sports, trades, or occupations usually taking this in the form of fees or licenses. In Malaysia, excise duty is imposed on automobiles. Cost is a major barrier to adoption. For example, a Toyota Prius is priced slightly under RM 180,000 before excise duty exemption. As cars are more of a necessity these days, overpriced cars are inhibitive for consumers. Before the exemption of excise duty, hybrid cars are considered expensive. Although they dont cost as much as a sports car but they are by no means cheap for consumers. In Malaysia, existing taxes on cars, particularly excise duties are high. Excise duties should be exempted by the government for all hybrid cars if they are serious about encouraging hybrids (Yeoh, 2010). The government decision to grant full excise duty exemptions on hybrid vehicles below 2,000cc until year end that had been announced during the tabling of Budget 2011 in October 2010 had lower the prices of hybrid cars. Public awareness of the benefits of hybrid cars has picked up considerably with lower price after excise duty waiver, and with that, sales of such cars has increased (Mahalingam, 2011). Toyota Prius is priced at RM 139,900 in Peninsular Mal aysia after full exemption of excise duty which lasts till the end of 2011, makes it an attractive proposition for Malaysian drivers (Standing a hybrid apart, 2011). Excise duty exemption on hybrid cars is like a shot in the arm to this vehicle segment (Mahalingam, 2011). The spike in demand for hybrids has been fuelled primarily by the Governments decision under Budget 2011 to grant full excise duty exemptions on hybrid cars below 2,000cc unti Dec 31, 2011. Representative from UMW Toyota stated that the company had received over 470 bookings for Toyota Prius and 946 bookings for the Honda Insight since the Governments budget announcement (Mahalingam, 2011). Since the Government announced the exemption of excise duties (at Budget 2011) last year, demand for hybrid cars have shot up, said MAA President Datuk Aishah Ahmad in Mahalingam (2011) news article. The sales of hybrid cars had risen and consumers in Malaysia are more aware of the benefits of hybrid cars since the exemption of excise duty. Hence, it is reasonable to suggest that exemption of excise duty on hybrid cars is one of the important factors in influencing consumers purchasing decision on hybrid cars. By referencing the existing literature on excise duty, it is hypothesised that: H0: There is no relationship between excise duty and consumers purchasing decision on hybrid cars. H3: There is a relationship between excise duty and consumers purchasing decision on hybrid cars. Fuel Economy Fuel economy refers to the fuel efficiency relationship between distance travelled by an automobile and the amount of fuel consumed. Fuel economy indicates how far a vehicle travels on a unit of fuel. Fuel economy is one of the variables in this study. When it comes to making their final decision about which vehicle to buy, fuel economy is one of the factors that consumers focus on. Fuel economy is the number one factor driving consumer decisions about green vehicles (named by 57% of respondents) and more respondents in China and the U.S. pointed to fuel economy (Dixit et al., 2009). According to the 2008 Advanced Automotive Features Study, it is reveals that some 38% respondents indicate that they would sacrifice vehicle performance for better fuel economy (Fuel economy, 2008). Eighty percent of consumers surveyed by the latest research from ExchangeandMart.com.uk in Fuel efficiency (2011) article said that a cars fuel efficiency directly affects their purchasing decision. Consumer Reports, 2009 in Jeffrey Gonder (2011) article found that prospective vehicle buyers listed fuel economy as a top factor of interest. Power Asia Pacific, (2010) found improved customer satisfaction with auto dealers in cases where those dealers provided advice for maximizing fuel economy when driving (Jeffrey Gonder, 2011). This further supports the thesis that consumers have some interest in fuel economy with the right encouragement. Increasing fuel economy standards encourages greater automobile use by reducing the cost per kilometre travelled (Thorpe, 1997; Agostini, 2010). Due to fuel price increases, consumers purchase more fuel efficient vehicles (Litman, 2004). A report comes from Market Intelligence research performed by the online arm of Kelley Blue Book reports that fuel economy has become a much more important part of the criteria buyers use to select their next vehicle (Bain, 2011). In the midst of escalating concerns about the dangers of greenhouse gas emissions, enviro nmentalists hailed the superior fuel economy and wide range of the hybrid-electric engine as a critical breakthrough that could help save the environment without inconveniencing consumers (Thatchenkery, 2008). According to a survey by the Consumer Federation of America, fuel economy ranks near the top in consumer priorities in general (Zhuang, 2009). The survey found that 76% of customers intend to buy a vehicle with fuel economy averaging five miles per gallon greater than the mileage of their current vehicle. Hence, it is reasonable to suggest that fuel economy is one of the important factors in influencing consumers purchasing decision on hybrid cars. By referencing the existing literature on excise duty, it is hypothesised that: H0: There is no relationship between fuel economy and consumers purchasing decision on hybrid cars. H4: There is a relationship between fuel economy and consumers purchasing decision on hybrid cars. Environmental Consciousness Environmental conscious can be known as affective traits that can signify an individuals likings, dislikes, worries and consideration about the environment (Yeung, 2004; Sinappan Rahman, 2011). The consumers spending pattern and preference has been growing and changing over time. People nowadays are more aware of the environmental issues. Generally, consumers tend to have a positive attitude towards green purchasing when they are aware of the environmental issues (Sinappan and Rahman, 2011). According to Soonthonsmais study in (Sinappan Rahman, 2011), a green consumer is defined as consumers who are conscious of and interested in ecological issues. All products and services that have environmental impact are put into their considerations and these consumers initiative is to reduce them to the minimum. As mentioned in Sinappan Rahman (2011), few studies were done on environmental consciouness (Barr et al., 2003; Milfont and Duckitt, 2004). The study done by Lee as cited in (Sinappa n Rahman, 2011) among Hong Kongs young consumers revealed that environmental consciousness is the 2nd top predictor of green purchasing behaviour. This result is consistent with Sinappan Rahman (2011) study where environmental consciousness is the 3rd top predictor of green purchasing behaviour. Consumers who have high concern on the environment often consider on how the quality of the environment can be improved and they would definitely engage themselves in buying environmentally friendly products, such as a hybrid car. According to KÃ ¶szeghy, (2004), a study performed in the United States levels of consumers environmental consciousness was identified. There are the true-blue greens who are firmly environmentally conscious persons, exhibiting this in their actions. They crisply refuse products of firms having doubtful environmental performance and give preference to environment friendly products. Greenback greens are the youngest and best educated people who support environmen talism with money rather than with any action or their time. These are wealthy people, ready to pay extra cost for environment friendly products. Demand for environment friendly products appears among environmental conscious consumers. The quality of the environment is important, which is taken into considerations in their purchase decision. Firms should take segments formed by the level of consumers environmental consciousness into account in their decision making process (KÃ ¶szeghy, 2004). Business today had changed, they are acknowledging that being environmentally conscious is being competitive and green products provide competitive advantage (Introduction to Environmental, 2006). Hence, it is reasonable to suggest that environmental consciousness is one of the important factors in influencing consumers purchasing decision on hybrid cars. By referencing the existing literature on environmental consciousness, it is hypothesised that: H0: There is no relationship between environmental consciousness and consumers purchasing decision on hybrid cars. H5: There is a relationship between environmental consciousness and consumers purchasing decision on hybrid cars. 2.5 DEPENDENT VARIABLES Purchasing Decision The purchasing decision process is a stage that a buyer passes through in making decisions about which product or service to buy. Every day consumers are faced with purchasing decision. A better understanding of how consumers decide what to purchase is critical to the success of a product. Purchase decision occurs when the consumer actually makes the purchase. It includes the product, method of payment, package, location of purchase and all other factors that are associated with purchasing the product (Wolf, n.d). It is insufficient to understand how consumers arrive at their purchase decision because there are personal, psychological and social factors that influence the purchase decision. Understanding of these factors is essential to effectively market products. In this study, we focused on five variables, which are price, design, excise duty, fuel economy, and environmental consciousness as the factors that affect consumers purchasing decision on hybrid cars. As mentioned in the literature review, these five factors are reviewed and explained on how they affect consumers purchasing decision. This is important to marketers and they need to understand clearly about their consumer to be able to market their product with a good understanding of these purchasing decision processes. 2.6 ITEMS OF MEASUREMENTS 2.6.1 Price 2.6 SUMMARY OF LITERATURE Table 2.1 Summary of literature Dimension Authors Price Chang, 2009; Litman,2004; KazaKevitch, Torlina Hendricks, 2005; Hermann et al., 2007; Lalwani and Monroe, 2005; Webb, 2011; Monroe, 1990; Bryant, 2006; Herrmann, Xia, Monroe Huber, 2007; Kishi Satoh, 2005; Bikash, Pravat Sreekumar, 2010; Okamura Cairns, 2003; Wolf, Carpenter Petrela, 2005 Design Webb, 2011; Jung et al., 2010; Hagemann, 2011; Cato, 2009; Wang Li, 2010; Nielsen, 2010 Excise Duty Kanak, 2002; Yeoh, 2010; Mahalingam, 2011; Ahmad, 2011 Fuel Economy Dixit et al., 2009; Jeffrey Gonder, 2011; Agostini, 2010; Litman, 2004; Bain, 2011; Thatchenkery, 2008; Zhuang, 2009 Environmental consciousness Yeung, 2004; Sinappan and Rahman, 2011; Barr et al., 2003; Milfont and Duckitt, 2004; KÃ ¶szeghy, 2004; Lee, 2008 Source: Adapted for this study 2.7 SUMMARY The five variables, which are, price, design, excise duty, fuel economy, and environmental consciousness plays an important role in consumers purchase decision. This study explored the five variables, which are, price, design, excise duty, fuel economy, and environmental consciousness by referencing the existing literature on how they affect consumers purchasing decision on hybrid cars. On the previous research, price plays an important role in purchasing an automobile. Price is always an important attribute in the decision-making process. Designs have a certain positive causal relationship with purchase intention indirectly and are important factors affecting purchase decision. It is known from consumer surveys that the design of cars greatly influences on consumers affection and therefore leads to their purchasing decisions. With a lower price after excise duty waiver, public awareness of the benefits of hybrid cars has picked up considerably and leads to more sales. Fuel economy h as become a much more important part of the criteria buyers use to select their next vehicle. In business today, environmentally conscious is being competitive and it provides competitive advantage. The quality of the environment is important, which is taken into considerations in consumers purchasing decision. Chapter 3 Methodology 3.1 INTRODUCTION The main objective of this research was to determine the factors affecting consumers purchasing decision on hybrid cars in Malaysia. In this chapter, various topics was discussed includes hypotheses development, research design, sampling technique, sources of data, scales and measurement, questionnaire design, data collection method, and statistical data analysis. After identifying the various independent variables, a hypothesis to test the validity of the relationship with dependent variable was developed. Next, the research design and sources of data were also elaborated. As this study was using the survey method of questionnaires, therefore the sampling technique, questionnaire design and measurement was in explained detailed. Finally, data collection method and statistical data analysis was also explained. 3.2 RESEARCH DESIGN AND PROCEDURE 3.2.1 Type of study This study will take place in urban areas in Malaysia where transportation is a necessity for consumers to travel around from place to place. Consumers like working adults who need vehicle to go to work and travelling in the urban area are more concern about the vehicles they drive. 3.2.2 Nature of study This study found that design was positively correlated with price. Consumers have expectations when buying a product. Consumers motivation to buy and even to pay a high price for a product is based on value judgment. Value can and has been added in several different ways. For example, through recognizable mark or signature of the designer that can add value to the product. Another way to adding value is through symbolic capital, which refers to the enhancement or the power that emanates from the designers name, which in turn evolves into a signature, mark or brand of the designer or manufacturer. Design adds value to the product, give it distinction. As a result, consumers are willing to pay a premium for the product. Independent variables in this study which are price, design, excise duty, fuel economy, and environmental consciousness are all positively correlated to the dependent variable, which is purchasing decision. Consumers concern of the price and whether the product is worth what they paid for. This brings a positive relation that influenced consumers p

The Representation Of Gender In Disneys Films Film Studies Essay

The Representation Of Gender In Disneys Films Film Studies Essay In the golden age of animation, 1928 1960s, Walt Disney was one of the famous animators in the industry who founded The Walt Disney Corporation. He was an American film director, producer, screenwriter, entertainer and entrepreneur. The book, From Mouse to Mermaid, described that Disney ethos both reflects and promotes particular elements of the dominant ideology of United State culture (Murphy, p.127). Most of Disneys work represents characters that embody racial, ethnic, and gender stereotypes. As well as middle-class perspective and royalist ideology while focusing on themes like innocence, friendship, magic and fairytale. The old Disney works such as Bambi (1942), Snow White (1937), Cinderella (1950), and Sleeping Beauty (1959) are misleading in the image that they portray to young children whose mind is still impressionable. Disney also created subtle messages of stereotypical of social construct of men and women. Snow White and the Seven Dwarfs released in 1937, it was well-known as the first to use Technicolor cel animation, about 250,000 celluloid frames for each animated film. Each frame is repeated from frame to frame, as layers upon layers of retelling, and in particular, a retelling of womans body. They also used live-action models for the characters and cinematic conventions of representing women. Each individual cel of film was hand-painted by women who created indelible images of the feminine. Elizabeth Bells said in her essay the women in these films are not bifurcated into good and bad, but represent a continuum of cultural representations of womens power and performance (Bell, p. 121). Eventhough I agree with her that Disneys work represents steriotypical role of female in our society, but I do not agree with her at this point because in Snow White and Cinderrella, we can see a clear distinction between a good characters and a bad characters that womens. A good characters fullfill a typical role of the ideal woman. The ideological woman is supposed to be skinny, beautiful, acquiescent, and perform duties of a housewife. She will not disobey direct orders and does not hold a job on her own. Whereas the bad woman is independent, strong willed and does not perform duties of a house care taker. During that time, the standards of contemporary beauty in Hollywood were young, pretty, white, graceful and slender. Disneys heroine character moved along with these standards except for the old Femmes Fatales. According to Middle-aged women represented as femme fatales are dark, independent, and treacherous; they are dressed on extravagant costumes. The example of this can be seen in Snow White, with the Evil Stepmother. As Bell rightly point out Disney transforms the vain, active and wicked woman of folktales into the Femme Fatale, the deadly woman od silent film and of Hollywood classic film. They usually played the roles of an evil stepmother who envied the younger heroine for her looks and ended up being defeated or killed. The old crone from Snow White represents the old female character which is depicted as gray and wrinkled, clumsy, and frumpily dressed. Disneys representation of women is the treatments of the feminine life-cycle in hegemonic social disclose and stereotypes a bout womens bodies. Another notable film technique is use by Disney film Bambi. Released during World War II, the film still used Technicolor cel animation but the goal was to obtain a highly realistic look than the previous productions. Bambi is a story about the birth and maturation of a young male; the son of the stag who rules the forest and his mother who was killed by man. Walt Disney attempted to achieve realistic detail by lecture the animators, so they could study movement of animals. Los Angeles Zoo was shipped a pair of fawns to showed animators, therefore the artist could draw nature look and realistic movement of Bambi and Faline. Each individual shows detail of nature; for instance, in the open scene we saw the shadow of sunlight which represents the morning hours. But because of the realism that they tried to created, multiples of cel made color of the film faded. Bambi used Anthropomorphism to represent gender of male and female stereotypes by using non-human characteristics to display an object or abstract concepts. Even though the film does not ascribe to the typical view of physical appearance but it still portray ideological of gender through Anthropomorphism. Anthropomorphism ascribes human motivation, characteristics or behavior to things not human, such as inanimate objects, animals or natural phenomena. Bambi also represent royalist ideology because the title character is a son of the Great Prince of the Forest and he became the Prince of the forest. The male stereotypes are represented through Bambi, Ronno and Bambis father, while female stereotypes are represented through Bambis mother and Faline. Beginning with male stereotypes, the father is labeled as the Great Prince of the Forest during the film, which represents his authority amongst the forest community which shows that only a male can lead the society and be a protector of f amily or community because males are perceived to be smarter that females. In the scene, Bambis father told everyone in the forest to escape from the hunter it shows how he tried to protect everyone in the forest because he would stay back to ensure that everyone is safe. The mother is represented as the natural stereotype of typical mom who always loves and cares about the children. One of the scenes that showed the way that mothers would do everything for their children is when they ran away from hunter, she preferred to give up her life in order to save her childs life. Another stereotype of young men represent in Bambi and Ronno, when they fight for Faline because young males always fight for a women. We also see the stereotype of young female Disney character in Faline which describe as young, pretty and slender stereotype that depends on a male. She was falling in love with the prince and ended up with the happy ending. The ideology of fairy tales is showed in a female character in Disneys film  which is the inherent expectation to falling in love and getting married to the prince so they can have happiness in life.  An example of this is in Snow White character that allows girls to have fairy-tales to dream of and hope for. As Murphy point out in his essay the Disney ethos both reflects and promotes particular elements of the dominant ideology of United States culture (p. 127), where the young girls are waiting for prince charming and dreaming of being princesses. They set the standards and ideology for girls on how to grow up. Contemporary society believes that women need to be more independent through the film because it has a huge impact on young audience on how they see the world. They want Disney to show that women can take care of themselves, more independent, be leaders, have jobs and do not rely on men. They also want Disney to transform into equality of gender because most of their films show a male dominated outlook. Feminists concerned about perception of the world and values about the point of view on young children especially girls to watch for unhealthy look of the physical attributes along with the values supporting male dominance. Disney production films showed the ideals of nature conflict through their female protagonists where women are fully dependent on men and female characters are often shown as happy housewives. This is due to the personal belief and attitude Walt Disney has towards how the family life is shaped and wha t roles women should play in society. The narratives of media associated between genders offer patterns of proper and improper behavior, messages, and ideological conditioning with pleasurable of popular entertainment being show on television. Even though there have been changes over years, we can see appropriate societal roles for men and women. By analyzing and interpreting animation films through history, one is able to understand the representation of gender which entails the inequalities that rest amongst sex, gender, nature, and ethnicity.

Harold Pinter Essay -- Biography Biographies Harold Pinter Essays

Harold Pinter Harold Pinter is one of the greatest British dramatists of our time. Pinter has written a number of absurd masterpieces including The Birthday Party, The Caretaker, The Homecoming, Betrayal, Old Times, and Ashes to Ashes. He has also composed a number of radio plays and several volumes of poetry. His screenplays include The French Lieutenant's Woman, The Last Tycoon, and The Handmaid's Tale. He has received numerous awards including the Berlin Film Festival Silver Bear, BAFTA awards, the Hamburg Shakespeare Prize, the Cannes Film Festival Palme d'Or and the Commonwealth Award. Harold Pinter was born on October 10, 1930 in Hackney, East London. He was the sole child of Jack Pinter and Frances Franklin. His father was a ladies’ tailor whose family was among Jewish immigrants that reached the East End of London. Both sides of Harold’s family were Jewish, but they had different personalities and characteristics. His paternal side was Orthodox Jewish and they had an artistic background, whereas his maternal side was more secular and skeptical about strict rules of religion and were known for their entrepreneurial background. Although the Pinter’s were relaxed and music-loving, they got along well at family gatherings with the noisy and clamorous Franklins. Since Harold was an only child, he would imagine a life with brothers and sisters and would create imaginary friends and play out adventures and scenes in the backyard of his home. This isolated world created a place where Harold felt warmth and security. However, this childhood was interrupted by the outbreak of war in 1939. Harold had to leave his home in Hackney as part of a nationwide evacuation, and along with twenty four other children, Harold was sent to John Nash, a fabricated castle, from the elementary school. This was a traumatic and disturbing experience for all of the boys who were isolated from their homes and families, especially for nine-year old Harold. Some boys took advantage of this experience and were happy to be exposed to rural life. â€Å"For Harold, the disturbing experience blended with a magical eye opening encounter of rural life and his tendency to introspect blossomed† (Top Biography). At the same time, his awareness to sounds and images developed, and these permeated his later life and work. This encounter left a mark in Harol... ...lways isolated from something, whether it be from the lack of feeling of love from non-existing siblings and creating imaginary friends in his backyard, or being isolated from his parents during his evacuation throughout the war. Pinter’s life was filled with significant events, but he claims that his life is and was confusing and has had no influence through his works. In this case, his plays, like his life, are just a series of events that happen in real life, but are not supposed to mean a certain thing or express a certain thought. His most recognizable plays mostly take place in just a room filled with people dealing with a certain issue, but they mean so much more; or do they? These situations can be so awkward and silly at times that they are absurd enough to see humor in them and laugh at. This is the way Pinter wanted his plays to be looked at. He was never trying to get a message across and his plays are meant to show a situation at hand and how people deal with it. It is so easy to try and come up with a reason for his menace which causes critics to over-analyze his work. This is what makes Harold Pinter one of the greatest British dramatists of our day.

The Growth of Democracy :: European Europe History

The Growth of Democracy In 1850, Britain was an undemocratic country. At this time the electoral system divided Boroughs and Counties. Voting qualifications were different in boroughs and constituencies. The vote was only given to men over the age of 21 providing their property was valued at  £10 or more, or land was more than  £2 per year in rent. Seats were distributed unequally and traditional ruling families usually formed the Cabinet. Furthermore, bribery and corruption were widespread and only the minority of the population were entitled to vote. At this time there was no form of a basic education for the population masses and there was still a lot of power lying within the House Of Lords and not with elected officials. A certain degree of money was necessary to stand for election because this was not a paying job, which, as a result stopped vast numbers of people standing for election because the did not have the finances to support themselves. Nor were they able to afford to stand for election a s due to bribery and corruption, the poor stood no chance of winning as they did not have the money to provide voters with what they wanted in return for their support. For democracy, there needed to be regular elections and although at this time elections were every seven years, this was not often enough. However between 1850 and 1918, progress was made towards Britain becoming a democracy. Now there was better communication and education increasing political interest and this influenced people in trade, industry and finance. Economic changes made people better off and left them wanting to take part in politics, and be represented in parliament. This general desire for the widening of the franchise led to pressure groups forming in 1864. The Extension of the Franchise was helped by the Second Reform Bill passed in 1867. In this act, all householders who paid rates with 12 months residence and all  £10 a year lodgers with one years residence in the Boroughs were given the Franchise. In the Counties, the Franchise was given to those  £5 property owners and all those who occupied property with a rateable value of  £12 or in Scotland,  £14. This act changed the views of The Liberals and The Tories as they now saw that many people backed the idea of a widening of the franchise. Party opinions changed in order to woo voters in the towns, but these changed opinions alone helped in bringing Britain towards democracy as now these political parties wanted to give the people what they wanted and were, agreeing with the populations views on this issue.

What Is The Role Of Engineers Environmental Sciences Essay

Through the last few decennaries the physical growing of population has become one of the universe ‘s highest environmental menaces. This growing has created singular demands for land, transit, energy, H2O, sanitation, etc. , and marked the different countries or Fieldss where applied scientists are working. As a consequence, todays ‘ applied scientists in both developed and developing states must to follow a new holistic attack toward natural and societal systems ( Amadei 2004 ) . Which means exchange the controlling nature attack for collaborating nature attack ; through sustainable development in pattern. Engineers, people that design professional solutions for societal issues, are playing a critical function in the building of modern societies, although the ways as they overcome and approach these depend mostly on the socioeconomic conditions which vary significantly. This essay will discourse the function of applied scientists in developing states and analyse H2O sup ply & A ; sanitation and energy as two of the most important countries affected by their decision-making.Role of technologyGeneral PerspectiveThe function of technology has suffered many alterations over the last few decennaries, although its construct which is based on test and mistake has remained an indispensable component of the scientific-technological method ; where societal, environmental and human factors define the most suited solution to pull off a peculiar issue. Therefore, applied scientist ‘s function is go oning reshaped harmonizing to the new challenges and necessities implicated by specialised subjects on peculiar countries of engineering ( civil, chemical, agricultural, etc. ) . ( UNESCO 2010, p. 24 )Contemporary Perspective and sustainable developmentUnlike the twentieth century where the technology epoch seemed to hold limitless natural beginnings, todays ‘ century is confronting serious jobs that are seting tremendous force per unit area on the enviro nment ( Azapagic, Perdan & A ; Clift 2004, pp. 3-5 ) . Therefore, todays ‘ applied scientists besides the basic proficient and scientific cognition of the technology subject, they besides have to lend and advance sustainable development that meets todays ‘ necessities without impacting adversely the capableness of approaching coevalss to run into up their ain necessitates. This new function of technology, demands new patterns based on social-environmental factors instead than merely concern ends.Impact of technology on societyThe history shows legion illustrations in which applied scientists ‘ public presentation has widely influenced among communities. Quality of life, economic wealth and good substructure for case, are one of the most relevant and common indexs of their weight on society. As ( UNESCO 2010, p. 40 ) have stated, by 2025, the universe ‘s population will hold increased from 1.5 billion to 6.6 billion about and the per centum of migration to urb an countries will lift from 40 per cent to 60 per cent. This information shows that urbanisation rates will hike dramatically. Subsequently applied scientists have the duty to do effectual and sustainable solutions as an incorporate attack without generate negative impacts, which is known as technology societal duty.Ethical side of technologyIn general footings, technology ‘s moralss is straight related with technology duties regulated by criterions codifications which act harmonizing to several state of affairss. The aim of the ethical factor in technology instead than merely fixed up regulations, is pulling solutions with reflection of peculiar state of affairss fixed into anterior rules. On this footing, at the clip of doing determinations, applied scientists should take into history the undermentioned points: sustainable development, protection of the public-environment, faithful agent of stakeholders – related with objectiveness, competence-knowledge, equity and ju stness, unity in the workplace ( dedication and service ) , and professional accountability- leading. ( UNESCO 2010, p. 190 )Engineers in Developing StatesAs in developed states, applied scientists must work within the societal, economic and environmental context in order to vouch existent sustainable development for the whole universe ( Parsons 1996, p. 170 ) . Social duties such as H2O supply, sanitation, nutrient, energy and environmental protection are the same in developing states. The difference resides on the socio-economic factors which are straight influenced by people ‘s behavior, authoritiess places and development precedences.Engineering accomplishments and moralss in Developing statesAs is described in the subdivision A.1 and A.3, competencies and rules of applied scientists in developing states remain the same as standardised features. The great challenge for them is in fact, to develop realistic undertakings on clip to peculiar communities and engineering availa ble ( Parsons 1996, p. 170 ) . In fact, environmental issues, frequently take less importance because there are others which have more â€Å" relevant societal impact † , oil geographic expeditions for case.Successful and failed undertakingsThe successful and failed undertakings in developing states depends much on the capableness of applied scientists to set about undertakings with a clear apprehension of the aims, dependable appraisal of resources ‘ handiness, concern, and proficient demands and effectual communicating among stakeholders. The ability to implement accurately these facts will convey up utile and applicable options to turn to existent issues. By contrast, deficiency of attending to the social-economic context, moralss codifications, unrealistic outlooks, underestimated clip, quality and cost will convey hapless results. ( Parsons 1996, pp. 171,172 )Relationship between engineering and socioeconomic factorThe usage of high-technology does non vouch a succ essful undertaking or accurate solutions. In order to accomplish good consequences, applied scientists must be able to do a balance between usage of engineering and socioeconomic properties. Parsons ( 1996 ) points out that the appropriated choice of engineering will find non merely undertaking ‘s success besides its viability. As a consequence, there are four points to take appropriated engineering harmonizing to socioeconomic factors: it must be conceptual and physically compatible with operators, trim parts and equipment must be available in the influenced country, undertaking support must be commensurate with its budget, and the engineering must be compatible with the physical environment where it will be used. This theoretical account leads to reason that the relationship between engineering and socieconomic factor is really narrow, it must suit users and demands every bit good as must be designed to better quality life.Engineering AreasEnvironmental tendencies that are d etermining new applied scientistsBrief reference of of import events that encourage environmental position on technologyWorld population, followed by clime alteration are considered the two chief factors that are determining new applied scientists with environmental attack. During the last half of the 21th century ; universe population increased from 2.5 billion to 6 billion particularly in less economically developed states, this tendency is expected to top out at 9.3 billion by 2050 ( United Nations 2012 ) . In add-on, overpopulation besides has been linked with higher demands of natural resources ( H2O, cropland, wood ) , shanty colonies, transportation-infrastructure shortages etc. Another of import event that is doing an environmental attack is the fact that the current planetary economic is based on productiveness, which has brought several impacts associated with nursery gases, waste merchandise of fossil fuels and air pollution. Climate alteration is surely the consequence o f all these elements at an unnatural rate. Therefore, the universe has changed its development attack to sustainable development ( Brown, Rener & A ; Halweil 2000 ) . Hence, most of professional corporations have incorporated sustainable development into their purpose statements and codifications.New theoretical account of acquisition and patternTo face the planetary challenges that the Earth are confronting today, technology instruction has incorporated the construct of sustainability into all technology Fieldss. This means, that professional are expected to do dependable determinations that improve quality of life every bit good as cut downing negative impacts on environment and degrees of ingestion, and be aftering their actions harmonizing to socio-economic factors and engineering available. Consequently, the procedure of acquisition and pattern has been adjusted by a theoretical account of instruction more realistic-practical. Where pupils throughout workshops are larning and e difice cognition in existent state of affairss, every bit good as has created in them greater environmental duty. ( Amadei 2004 ) .Sustainability and transmutationAs explain Azapagic, Perdan & A ; Clift ( 2004 ) , there are surely three constrains that built the construct of sustainability. Techno-centric concerns, which represent human expertness, inventiveness and economic systems, Eco-centric concerns related with natural resources and ecological capableness and socio-centric concern based on human and societal outlooks. The Techno-centric concerns, has been traditionally used in the procedure of instruction in technology, the duty of today ‘s applied scientists is to include in equal proportion or balance all three restraints to accomplish a sustainable development. Which finally is seeking for human well-being, in other words fulfilling human demands, bettering quality of life in an eco-friendly manner.Water Supply and SanitationDeveloping States backgroundUNESCO ( 2010 ) states that H2O supply is one of the most serious jobs confronting by developing states, in India for case, 85 % of the urban population has entree to imbibing H2O, but merely 20 % of the of this meets the health-quality criterions set by World Health Organization. Additionally, the day-to-day rate of H2O supply frequently is really low and depends on economic factors and location. The state of affairs on sanitation is even worse ; frequently sanitation has lower precedence than H2O supply. It has estimated that 2.6 billion people do non hold decently or bing sanitation system in developing states. Another issue related with sanitation is in fact that effluent and solid waste aggregation services ; and stormwater drainage are unequal. Littering straight to open countries for case, has created environmental impacts on surface and land H2O resources being more dramatic in countries such as shanty towns.Engineering Challenges Engineers attackThe traditionally intervention of H2O suppl y and sanitation direction is considered now as a standard process. Which has several interventions harmonizing to the H2O physicochemical features, engineering available and environmental ordinances. Although, it is by no agencies certain that this process has been the best. Indeed, 95 % of the effluent in the universe has been discharged to the environment without intervention ( Montgomery & A ; Elimelech 2007 ) . Hence, Beside new ordinances and codifications, todays ‘ applied scientists instead that retroflex solutions from developed states to developing states, they will hold to run into basic demands of all communities for H2O and sanitation and work as facilitators of sustainability attack within context institutional, societal, political, economic, environmental and technological. Thereby, the issue of H2O and sanitation in developing states will be overcame or at least decreased. For illustration, cleaner production can be â€Å" an expensive solution † , never theless it is truly depends on legion conditions linked with the population objet, such as natural resources, demands and societal category.EnergyDeveloping States backgroundIn the following few decennaries, the force per unit area on energy services will increase well in developing states. It is predicted that energy ingestion worldwide will increase approximately 30 % from 2007 to 2030 and most of that growing will be came from developing states. As a consequence, the intergovernmental panel clime alteration ( 2007 ) point out that these energy issues will be addressed through cost-efficient energy plans based on the decrease of dodo fuel usage ; executions of ecofriendly engineerings and renewable energy in lodging, transit and industrial sectors and eventually the decrease of life-cycle cost, this related with all disbursals in the design, building, operation and care of a peculiar undertaking. ( Liu, Meyer & A ; Hogan 2010, pp. 35,36 ) . Today ‘s modern development demand s serious energetic plans that fix up both economic development and sustainable development based on the rational usage of natural resources.Engineering Challenges and attack in developing Nations.Worldwide experiences have showed that the replacing of non-renewable to renewable energy seems to be more expensive and furthermore, information about renewable engineerings is unequal or unapproachable. For that ground, the common committedness for applied scientists on energy solutions is provide better options in footings of sustainability and development. Adoption and design of new engineerings, ordinances, technology supervising within national schemes, continues updating, provide advice of energy demands, etc. , will be the common countries where applied scientists ‘ function will be important for environmental energy development in the less economically developed states. ( UNESCO 2010, p. 288 ) .Decisions

Early Humans Essay

What animals did the early humans hunt for food? Early humans found meat from animals that were back in the day, the meat was not so common because before they had animals they had other types of food like for example, fruits from trees, nuts and sometimes even honey and the y also got berries form the burry bushes like raspberries, strawberries, blueberries and so on, but the animal that they always use to eat in the ancient times was the buffalo which was one of the most common animals in there specific villages and mostly when they would get the animals they would open them up with sharp things and then they would eat the meat and by the time they figured out fire they used fire to cook the food like we do know. How the early Human nut and got their food? Well the simple answer is that they used weapon to hunt the animals but we always thought that the early humans are stupid but the truth is that they are actually very smart because of the weapons they used for hunting and another thing they did to hunt food was that back in the early days there was a group of people called hunter gatherers and what hunter gatherers are is that basically a group of people for example from villages (mostly man) would go out to hunt for food mostly everyday and then when any of them would get food they will bring it to the group of people that they are and then the would most probably share the food with the people. And mostly the weapons would be made out of stones and wood. Also an example of the weapons they used wear spears and bows made out wood and stones. The most common food eaten nowadyaus are seeds. Also very populare is vegetables and fruits.

Criminal Law 9 Offences Against Property

Theft – The Theft offence is defined under S1 of the ‘Theft act 1968’. Where it provides that if ‘A person dishonestly appropriates property belonging to another, with the intention of permanently depriving the other of it,’ will be guilty of the offence. For this charge to be upheld, both the actus Reus and the mens rea have to be established. Actus Reus – Beginning with the physical element of the crime, the actus Reus it is made up of 3 elements – ‘appropriates, property, belonging to another. ’ Appropriation is defined in S3, ‘Any assumption by a person of the rights of an owner amounts to appropriation. This includes coming across the property innocently or not without stealing it and treating the property how the owner would. Examples of this would be using, eating, selling, destroying, lending/hiring the property. The case examples are: ? ‘Pitman v Hehl (1977)’ – ‘defendant sold propert y belonging to another. Offer of sale is an assumption of right. It didn’t matter whether the property was removed or not. ? ‘Morris, (1983)’ – At least one assumption of all the rights Switched price labels in shop. ? ‘Lawrence (1971)’ – With consent An Italian student paying for taxi ride, ? 6 instead of 50p. ‘Gomez’- Lied about cheques so friend could take supplied goods. Dishonestly appropriating goods, induced through fraud, deception or a false representation to consent. ? ‘Hinks’ – Consent without deception, got naive friend to put money in account. Said where gifts however also results to appropriation. Property has been defined under S4; this includes money, real property (buildings and land, personal property, things in action (bank accounts) and other intangible assets. (e. g. Patent) ? Kelly and Lindsay (1998) – Taken body parts from the royal college of surgeons to make casts.Normally dead bodies are not property however; belonged to the royal college. ? A-G of Hong Kong v Chan Nai-Keung- Stolen quota ? Oxford v Moss – Not intangible property , – knowledge of the questions on a exam paper ? Wild mushrooms and plants cannot be property unless it is taken for reward or commercial purposes. Not theft if creatures are wild, but theft if they are in captivity or owned. Belonging to another is defined under S5, ‘property shall be regarded as belonging to any person having possession or control over it, or having in it any proprietary right or interest. Therefore prosecution do not have to prove who the legal owner is. ‘Turner (no. 2) (1971)’ Stealing own car Garage was in control of the property as he left it with them to make repairs and pay thereafter. Guilty, when property may not belong to another. (1) Trust property, where trustee steals it (2) Property received under obligation – ‘Hall, (1972)’ – Travel agent, deposits for client tickets. Klineberg and Marsden,’ Obligation to make deposits in a certain way. Timeshare apartments. ‘Davidge V Bunnett’ Money for bill but didn’t. 3)Property received by another’s mistake – ‘A-G Reference (No 1 of 1983) (1985) – Salary overpaid through bank transfer, had an obligation to repay. Mens Rea – Within the offence of the theft the mental element of the crime the mens rea is the ‘dishonest intention’. Dishonesty, it has to be proved that they defendant appropriated dishonestly, there is no definition under S2 however it states that it is irrelevant whether it was made with a view of gain or own benefit. Therefore meaning if the other entire elements are present the defendant’s motive is not relevant.S2 provides 3 situations in which the defendant’s behaviour is not dishonest. If a genuine belief in one of the three below not guilty. A) He has in law the right to deprive the other of it, on behalf of himself of a third person. b) He would have the consent if the other knew of the appropriation and the circumstance of it. c) The person who the property belongs to cannot be discovered by taking reasonable steps. Willing to pay – it doesn’t prevent dishonest conduct. ‘A person’s appropriation of property belonging to another may be dishonest notwithstanding that he is willing to pay for the property. The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital, He claimed fees for operations he had not carried out. COA decided dishonestly has both objective and subjective element. 1. Was the action dishonest according to the ordinary standards of reasonable & honest people? Objective 2. Did the defendant realise that what he was doing was dishonest by those standards? Subjective Here the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted.Intention to permanently deprive this is the final element, which is defined in S6. ‘Velumyl’ – Company manager took ? 1050 from safe. He said owed money to a friend and would replace later. COA upheld conviction as he has intention of permanently depriving company of banknotes. Permanent e. g. destroys property ‘DPP v Lavender (1994) – took doors from council property at time of repair and used to replace damage door in girlfriend council flat. Borrowing is not theft unless it is for a period and in circumstances making it equivalent to taking it or disposal Lloyd’ – Not theft, film taken copied and brought back undamaged. ‘Easom’ – The defendant picked up a handbag in a cinema, rummaged through its contents and then put it back without having taken anything, condition intention, not guilty. Robbery is an offence defined under S8 o f the ‘Theft act 1968’, it provides’ A person is guilty of robbery if he steals, and immediately before or at the time of doing so, and in order to do so, he uses force on any person or puts or seeks to put any person in fear of being then and there subjected to force,’ will be convicted of robbery.This is basically aggravated theft, by the use or/and threat of force. For robbery, theft must be completed for robbery to be committed, all the elements of theft need to be present, and therefore if there is no theft, there is no robbery. The elements which have to be proved for the actus Reus of robbery are:- 1. Theft 2. Force or putting or seeking to put any person in fear of force. ( immediately before or at time of theft and must be in order to steal) Completed Theft – Where force is used to steal, the moment that theft is complete, there is a robbery.A case example is Corcoran v Anderton (1980) – Defendant hit woman in back and then tugged at her bag. She let go of the bag, however the defendants ran off without it, as the lady was screaming. It was held that theft occurred, therefore guilty of robbery, (temporary Appropriation). If she had not let go of the bag, theft would not be completed, but could be charged with attempted robbery, (s9 (2) Theft Act 1968). Force or threat of force – The prosecution must prove that there was a force or threat of force present. This is determined by the jury. It has been said the amount of force use can be small. In ‘R v Dawson’, one the defendant nudged the victim causing loss of balance so the other could take his wallet. Jury to decide if the force was present; charged with robbery †¢ In R v ‘Clouden’, the defendant had wrenched on the victim’s handbag from her hands. COA held that whilst taking of property without resistance from the owner, should not amount to robbery, the question of force ‘on any person’ should be left to the jury. The force must be immediately before or at the time of the theft. – It is decided by the jury the length of theft, but it has been held that theft is a continuing act. When theft is completed. ‘Hale (1979)’, the two defendants forced their way in. One defendant put his hand over her mouth to stop her screaming while the other went upstairs and took a jewellery box and then tied up her up before leaving. COA, force of hand over mouth and theft ongoing. †¢ ‘R v Lockley’, the defendant The defendant, with two others, was caught shoplifting cans of beer from an off-licence and used force on the shopkeeper who was trying to stop them escaping   The defendant appealed on the basis that the theft was complete when he used the force, but the Court of Appeal followed Hale and dismissed his appeal. On any person – This force or threat of force can be put on any; it does not have to be the person from whom the threat occurs. An exampl e situation is bank robbery and force on customers. – Force in order to steal – If force is not used in order to steal it is not robbery, example being fight between defendant and victim and then theft. The defendant charged with OAPA and also theft. For the mens rea of robbery it must be proved that the defendant had the:- 1. Intention for theft 2. Intended to use force to steal. Burglary offence is under S9 of ‘Theft act 1968. It defines 2 different ways to commit burglary. Common elements of both, (a) entry (b) of building or part of building, (c) as trespasser. Under S9(1)(a)‘A person is guilty of burglary if he enters any building or part of a building as a trespasser , with intent to steal, rape, do unlawful damage and inflict gbh. Under S9(1)(b)‘ A person is guilty of burglary if he enters any building or part of a building as a trespasser, he steals or attempts to steal anything in the building or inflicts or attempts to inflict gbh on any per son in the building. Actus ReusNot defined in ‘Theft act 1968’, but there are several cases of the meaning. ‘Collins’ – COA, Jury satisfied that D made ‘effective and substantial entry’ ‘R v Brown’ – ‘Effective entry’. D was outside shop window leaning in, looking through goods. ‘Ryan (1996)’ – D entered, trapped in window of a house at 2:30am, half body inside. The theft act gives extended meaning for the word building, but a basic definition is not given, however never really a problem with this. It includes houses, flats, offices, factories†¦ It also includes outbuilding and sheds.Large storage containers – ‘B and S v Leathley (1979) A freezer container had been in a farmyard and been used for storage. It had be held to be a building Part of building. This is where a defendant has permission to be one area of the building however not another. ‘Walkington (197 9) – D went to the counter of the shop and open the till. S (9) (1) (a). Defendant to be committed of burglary he must enter as a trespasser. If have permission – not a trespasser. ‘Collins’ – Drunken defendant wanted sex, he saw an open window and climbed a ladder to look. A naked girl was asleep in†¦ Entered the room.She thought he was her boyfriend †¦ they had sex. Charged under S9 (1) (a), Enter, trespasser with intent to rape. On appeal, conviction quashed as he was not a trespasser. A defendant can become a trespasser even if he has a permission to enter. This is when the defendant goes beyond the given permission. ‘Smith and Jones (1976)’ – Smith and friend went to smiths fathers house and took two television sets without his father’s knowledge/ permission. His father stated that his son is not a trespasser, (general permission to enter). However COA, guilty of Burglary, S9 (1) (b), ‘entering in acce ss of the permission given to him’.In line with ‘Barker v R (1983)’ Neighbour to look after property, told defendant that there is a key hidden if needed, but however entered property to steal. Mens Rea – 2 parts Both, S9 (1) (a) and S9 (1) (b), must intend or be subjectively reckless to enter as a trespasser. With S9 (1) (a) the defendant will also need the intention of committing at least one of the four offences stated when entering. He needs intention to steal or condition intention. For S9 (1) (b) the defendant must also have the mens rea for theft or gbh when committing or attempting to commit the actus Reus of burglary.Deception Offences (Fraud) and Making off without payment. Deception Offences ? Obtaining property by deception (s15 Theft Act 1968); ? Obtaining services by deception (s1 Theft Act 1978); ? Evading liability by deception (s2 (1) Theft Act 1978). Common Elements – (1) Deception (2) obtaining/evading (3) Dishonesty [pic]Basic de finition is stated in S15 (4) Theft Act 1968. ‘Any deception (whether deliberate or reckless) by words or conduct as to the fact or as to law, including a deception as to the present intentions of the person using the deception or any other person’.It applies to all 3 offences. It makes clear the deception can be words, silence, conduct†¦ Deception definition – ‘DPP v Ray (1973)’ – Lord Reid. ‘Deceive is to induce a man to believe that a thing is true which is false, and which the person practising deceit knows or believe it to be false’ Deception can be deliberate or reckless. Spoken or written words -‘Silverman- (1987)’ D gave excessive quotation to 2 elderly sisters, after building a good relationship from past. COA said it is deception. Quashed because jury. – Conduct (e. g. alse cards, uniform) – ‘Barnard- (1837)’ went in to shop in oxford worn student clothes, and stated that he w as a student, so could get sold products on credit. False pretent Silence– Can be implied in certain situations, ‘DPP v Ray’ – (1973). Went to restaurant with friends, he didn’t have enough money but friend agreed to pay, however they all decided not to pay and then ran out of restaurant. Circumstances Also when circumstances have changed – ‘Rai – (2000)’ – Applied for grant for downstairs bathroom for elderly mother. It approved but she died, did not tell council. Firth 1990)’ – Doctor who failed to inform the NHS hospital, that some patients were private, he avoided paying charged to the hospital. Use of cheques When a person writes a cheque, it implies that they have the bank account and money in this, to pay for the cheque, representations of fact. ‘Gilmartin (1983)’ D paid for supplies with a post dates cheque which he knew would not be met. Use of cheque guarantee cards – It i s issued by the bank on current accounts, which has a limit of ? 50- ? 100. The bank guarantees that a cheque up to a specific amount will be met by bank. ‘Charles (1976)’. D bank account had overdraft of up to ? 00. Has cheque guarantee card for up to ? 30. Not meant to use more than 1 a do. Wrote 25 of ? 30, also knew he no sufficient funds. HOL, false representation S16, Theft act 1968 (Obtaining a pecuniary advantage by deception. Credit cards. Representations, user of card is the name on card and has the authority of Card Company to use it. ‘Lambie (1981)’ D had a Barclaycard credit card which had a limit of ? 200; she exceeded limit and bank asked for card to be returned. HOL reinstated it. Deception as to fact, law intention. False statement about the law can be deception and also deception about the facts. King and Stockwell (1987)’ The falsely represented to woman that they were reputable firm of tree surgeon, and made false claims to make h er agree to pay for work. Attempting to obtain property by deception. [pic]As well as proving deception, it must be shown that a person was deceived and property/service/ evade liability as a result of deception. Common in all deception offences. Deception is not relevant to the person to whom it is made. ‘Laverty’. D changed number plates and chassis of car and sold to plaintiff. Not deception as plaintiff thought he was owner and no prove of deception. Etim v Hatfield’ D produced false declaration to PO clerk that he was entitled to supplementary benefits. Clerk gave him ? 10. 60. Without deception no payment would be given. Machines, not possible for deception to happen, however it may be charged as theft. Deception after obtaining is not deception. ‘Collis-Smith’ D filled car up with petrol and claimed that his company would pay for his petrol. Ownership of petrol passed to him. Led to new law of the theft act 1978 under, S2. [pic] It must be pro ved in all deception offences. The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital.He claimed fees for operations he had not carried out. COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? Objective †¢ Did the defendant realise that what he was doing was dishonest by those standards? Subjective Here the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. – Intention to permanently deprive, S15 (3) states that S6 shall apply to this offence, the word ‘‘appropriation’ is changed to ‘obtaining. – Makes the deception deliberately or to be reckless as to whether they are deceiving others Obtaining Property by Deception is defined in S15 of the Theft act 1968 it states that any deception made to dishonestly obtain property belonging to another, with the intention of permanently depriving the other of it. It is similar to theft however property must be obtained through deception. Most offences of obtaining by deception could also be charged with theft, since the case of Gomez which overlapped these laws. Actus Reus. Obtain – S15 (2), states that obtain means ‘obtaining ownership, possession or control of it.Any one is sufficient; makes clear that obtaining can be for another person or to enable another person or to keep it. Property – It has the same meaning as it theft. It includes money and all other property, real or personal, including things in action (bank accounts) and other intangible assets (e. g. Patents). The only difference being that it has no restrictions on obtaining land (limited situations) Belonging to another has the same meaning as in theft, therefore it means ‘any person having possession or con trol over it, or having in it any proprietary right or interest. ’Obtaining because of deception – As well as proving deception, it must be shown that a person was deceived and property obtained as a result of deception. Deception is not relevant to the person to whom it is made. ’ Laverty’. D changed number plates and chassis of car and sold to plaintiff. Not deception as plaintiff thought that defendant was owner, no proof of deception. ‘Etim v Hatfield’ D produced false declaration to PO clerk that he was entitled to benefits. Clerk gave him ? 10. 60. Without deception no payment would be given. Deception after obtaining is not deception. Collis-Smith’ D filled car up with petrol and claimed that his company would pay for his petrol. Ownership passed to him. Led to S2 theft act 1978 Mens rea – Dishonest – The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital. He cla imed fees for operations he had not carried out. COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? O †¢ Did the defendant realise that what he was doing was dishonest by those standards? SHere the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. – Intention to permanently deprive, S15 (3) states that S6 shall apply to this offence, the word ‘‘appropriation’ is changed to ‘obtaining. ‘ – Makes the deception deliberately or to be reckless as to whether they are deceiving others Obtaining Services by Deception is a offence under S1 of Theft act 1978, which states, ‘S1 (1) A person who by any deception dishonestly obtains services from another shall be guilty of an offence.S1 (2) It is an obtaining o f services where the other is induced to confer a benefit by doing some act, or causing or permitting some act to be done, on the understanding that the benefit has been or will be paid for. The defendant make the other person induce to confer a benefit by: AR Doing some act Causing some act to be done Permitting some act to be done This part of the actus Reus covers a wide range of situations of the ways that the offence can be committed. The act must cause a benefit to the defendant and must be proved that the benefit ‘has been or will be paid for. If the benefit is free there is no offence even if the defendant was dishonest. The victim doesn’t have to suffer any loss. Service – E. g. haircut, hotel stay, entertainment activity, film, repair of goods, cleaning and decoration etc. ‘Widdowson’ obtaining of hire purchases in order to buy a car was a service. ‘Halai’ Mortgage advantage not a service. But S1 (3) inserted into S1 by the the ft, (amendment) act 1996. Now contained in S1 theft 1978. ‘Sofroniou’ – Obtaining loans through a bank account or by way of overdraft was now, with the amending addition of S1 within the meaning of services.COA held that opening bank account and obtaining credit card is also a service. Understanding that the benefit has been or will be paid for. For there to be an offence they have to be shown that they were a benefit which had been or would be paid for. ‘Sofroniou’. D opened 2 bank accounts under false names, and then arranged for loans in both accounts causing account to become overdrawn. He then applied for store credit and exceeded limit. Convicted of S1 theft act 1978. Understanding of the payment Mens rea – Dishonesty, deception was made intentionally or recklessly – Dishonest – The Ghosh Test (1982) – Leading case on dishonesty.Ghosh a doctor, (a locum consultant) at hospital. He claimed fees for operations he had n ot carried out. COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? O †¢ Did the defendant realise that what he was doing was dishonest by those standards? S Here the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. – Makes the deception deliberately or to be reckless as to whether they are deceiving othersEvasion of Liability is under S2 if the Theft act 1978, it creates a number ways that evasion of liability can be committed2(1) (a) dishonestly secures the remission of the whole or part of any existing liability to make a payment, whether his own liability or another's; or 2(1) (b) with intent to make permanent default in whole or in part on any existing liability to make a payment, or with intent to let another do so, dishonestly induces the creditor or any person claiming payment on behalf of the creditor to wait for payment (whether or not the due date for payment is deferred) or to forgo payment; or 2(1) (c) dishonestly obtains any exemption from or abatement of liability to make a payment; shall be guilty of an offence. The liability is limited to legally enforceable liability Securing remissions of a liability – E. g. persuades creditor to let him off repaying all or part of debt, through untrue stories and deception. Jackson’ D paid for petrol using a stolen credit card, it was decided that he had an existing liability to pay for it by deception through the stolen credit card Inducing a creditor to wait or forgo payment, with (a) There must be an existing liability, but for (b) this offence it is enough if the defendant induces the creditor to wait for payment or forgo payment, the defendant must intend to make a permanent default. ‘Holt and lee’ – Two defendants had a meal i n a pizza restaurant, after they finished they made a plan to tell their waitress they had already made payment to another member of staff, so they could leave without paying. This was heard by an off duty police officer and they were arrested for attempting to induce a creditor to forgo payment. Turner’ (1974) – Defendant owed money for some work done, but the defendant said he had no ready cash and persuaded creditor to accept a cheque which he knew would not be met. Intent Obtaining an exemption from or an abatement of liability – Covers many everyday situations. E. g. People use invalid tickets or claim discounts that they are not entitled to. Leading case’ Sibartie’(1983) Defendant was a law student, bought two season tickets for daily journey, one ticket covering the beginning of his journey and the other ticket covering the end of his journey on; in between were 14 stations including an interchange station which had no valid ticked.At the in terchange station passing a ticket inspector, the appellant flashed ticked so fast so that she could not see what was on it. He with evasion of a liability by deception, contrary to section 2(1) (c) of the Theft Act 1978. ‘Firth 1990)’ – Doctor who failed to inform the NHS hospital, that some patients were private, he avoided paying charged to the hospital. Mens rea [pic]As well as proving deception, it must be shown that a person was deceived evaded liability as a result of deception. Common in all deception offences. Deception is not relevant to the person to whom it is made. ‘Laverty’. D changed number plates and chassis of car and sold to plaintiff. Not deception as plaintiff thought he was owner and no proof of deception. Etim v Hatfield’ D produced false declaration to PO clerk that he was entitled to supplementary benefits. Clerk gave him ? 10. 60. Without deception no payment would be given. Machines, not possible for deception to happ en, however it may be charged as theft. Deception after obtaining is not deception. ‘Collis-Smith’ D filled car up with petrol and claimed that his company would pay for his petrol. Ownership of petrol passed to him. Led to new law of the theft act 1978 under, S2. [pic] It must be proved in all deception offences. The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital. He claimed fees for operations he had not carried out.COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? Objective †¢ Did the defendant realise that what he was doing was dishonest by those standards? Subjective Here the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. – Intention to permanently deprive, S15 (3 ) states that S6 shall apply to this offence, the word ‘‘appropriation’ is changed to ‘obtaining. ‘ – Makes the deception deliberately or to be reckless as to whether they are deceiving othersMaking off without payment, is defined under S3 (1) of the Theft Act 1978, it provides ‘a person who, knowing that payment on the spot for any goods supplied or service done is required or expected from him, dishonestly makes off without having paid as required or expected and with intent to avoid payment of the amount due shall be guilty of an offence. ’ The goods supplied or service must be lawful, if not there is no offence. This offence was created as the Theft act 1968 had many loop holes which meant many defendants were getting off not guilty even if defendants conduct seen by many as ‘criminal’. One gap was seen in the case ‘Greenburg’ (1972) – D filled car up at garage and driven off without paying, not guilty as moment petrol was appropriated it belonged to him. Payment on the spot’ includes payment at the time of collecting goods on which work has been done or in respect of which service has been provided. Needs to be proved that POTS was required or expected. ‘Vincent’ (2001) – D stayed at two hotels and left without fully paying his bills, having persuaded both hotel owners, by deception, to postpone payment, so POTS was not required. The COA quashed his conviction under S3, because the hoteliers had agreed to postpone payment, which meant that the actus Reus had not been committed. Makes off – The defendant must make off for the spot that payment is required ‘McDavitt’- D refused to pay a bill after an argument with the manager. D walked towards the door but was told the police were called. D went to the toilet and remained there.Directed jury to acquit the defendant, as he had not made off without payment. ‘Brooks & Brooksà ¢â‚¬â„¢, D1 ran out of a rear door and D2 was caught having walked out of a restaurant. ‘The spot’ was treated as being cash register ‘the spot where payment is required. ’ Mens Rea – Dishonesty (Same as theft) -The Ghosh Test (1982) – Leading case on dishonesty. Ghosh a doctor, (a locum consultant) at hospital. He claimed fees for operations he had not carried out. COA decided dishonestly has both objective and subjective element. †¢ Was the action dishonest according to the ordinary standards of reasonable & honest people? Objective †¢ Did the defendant realise that what he was doing was dishonest by those standards? SubjectiveHere the jury would start was the objective test, if it was proved to be dishonest it was carried to the subjective test, however if it was not dishonest he would be acquitted. Knowledge that payment on the spot is required. It must be established that the defendant knew payment was required or expected of hi m. Examples are restaurants where bill paid before leaving. Intention to avoid payment ‘with intent to avoid payment for the amount due ‘Allen (1985)’ HOL stated there must be an intent permanently to avoid payment. D left hotel without payment of ? 1,286, leaving behind his belongings. He phoned later to say he would pay as soon as he received sufficient money and arranged to collect his belongings and leave his passport as security.Basic criminal damage is set out in S1 (1) of the criminal damage act 1971 where it provides that ‘A person who without lawful excuse destroys or damages any property belonging to another intending to destroy or damage any such property or being reckless as to whether any such property would be destroyed or damaged shall be guilty of an offence. ’ Actus Reus – This phrase is not defined in the act, however old cases have stated that slight damage was sufficient to prove damage. ‘Gayford v Chouler’- Tra mpling down grass, no longer binding but a persuasive precedent. ? ‘Roe v Kingerlee’ – Smearing excrement on walls of a police cell; it cost ? 6 to clean up. ‘Matter of fact and degree,’ damage even if not permanent. ‘Hardman’ – Painting on pavements, removed with jets. None permanent ? ‘Blake v DPP’ – Biblical quotation on a concrete pillar, cost to clean, so held as damage ? ‘Samuel v Stubbs’ – Denting a policeman’s hat, causing a â€Å"temporary functional derangement† ? ‘A v R’ – D spat on policeman shirt, minimal effort to remove, therefore no damage. ? ‘Morphitis v Solmon’ – Scratch on scaffolding pole, doesn’t affect its usefulness or integrity. Defined in S10 (1) of criminal damage act 1971, ‘property’ means pr of a tangible nature, whether real or personal, including money and land; tamed wild creatures (or th eir carcasses); but not including wild mushrooms, fruit or foliage. Not intangibleBelonging to another is defined in S10 (2), provides that property belongs to any person having: custody or control of it; any proprietary right or interest; or a charge on it. Cannot be guilty of damaging or destroying own property. ? ‘Smith 1974’, D removed some electrical wiring . Not guilty, lacked mens rea. Mens Reus – ‘Pembliton (1874) – D threw stone at men who were fighting, missed and broke window. No intention even if he had intent to throw stone. No charge. – ‘Smith 1974’, Believed he was damaging own property. ‘Honest belief, negatives the mens rea. ’ ‘Stephenson (1979) D was tramp sheltering in a hay stack, lit a fire †¦ costs in damages.Would have been guilty if he was not schizophrenic, he didn’t realise the risk. Caldwell (1981), the HOL changed the law. Reckless – created an obvious risk to prope rty†¦.. It was used up to 2003. Gemmell and Richards reinstated the subjected test for recklessness. The two young defendants went camping without their parents' permission. During the night they entered the back yard of a shop and set fire to some bundles of they found and threw some it under a large plastic wheelie-bin and left. The fire spread and caused approximately ? 1m worth of damage. The defendants stated they thought it would extinguish itself because of the concrete, could not be charged as they didn’t realise the risk. 5 (2) (a) – D believed that the owner had consented or would have consented to destruction or damage. S5(2)(b) – D did it to protect some other property which he believed was in immediate need of protection and the means of protection were reasonable having regard to all the circumstances. (a) ‘Denton’, Thought employer had encouraged him to set fire to mill to make insurance claim. (B)’Hunt’ helped wife in duty as deputy warden in block of flats. Set fire to bedding to show alarms didn’t work. Conviction upheld as not for protection. (b)Conviction upheld – Baker and Williams, only for immediate danger. (Endangering Life) Aggravated criminal Damage is under S1 (2) of Criminal damage act (1971). A person who without lawful excuse destroys or damages any property, whether belonging to himself or another – (a) intending to destroy or damage any property or being reckless as to whether any property would be destroyed or damaged; and (b) intending by the destruction or damage to endanger the life of another or being reckless as to whether the life of another would be thereby endangered; shall be guilty of an offence. ’. Much more serious than basic, carries life sentence. The danger must come from the destruction/damage. ’ Steer (1987) – D fired 3 shots at the window of ex business partner, causing damage. Not guilty danger from shots. ‘We bster – D pushed large stone from bridge on to train, caused damage & showered passengers with debris, based on Recklessness. ‘Warwick’ – D rammed s police car and threw brick at it, causing damage and showered the officer with broken glass.Aggravated criminal damage the life doesn’t have to be endangered. ‘Sangha’ D set fire to mattress & 2 chairs in neighbours flat, however flat was empty and no one was at risk. Realised risk he would be guilty even if no actual risk. ‘Merrick’ – Employed to removed cables, life live wire out for 6 minutes, no one was hurt, but charged, if it was owner he would also be guilty. Mens Rea Intention or Recklessness as to destroying or damaging any property; and Intention or reckless as to whether the life is endangered by the destruction or damage. (Same meaning as basic offence). The prosecution must prove that the defendant was both aware of risk and danger.R( Stephen Malcolm) d was 15 years old, with friends thrown milk bottles filled with petrol at the outside of neighbour flat. This caused sheets of flame across window, thus endangering the lives of occupants, guilty. Arson – Under s1 (3) of the criminal damage act 1971, ‘an offence committed under this section by destroying or damaging property by fire shall be charged as arson. ’ the maximum penalty if life imprisonment. The basic offence of criminal damage must contain destruction through fire, thus the rest is the same. Aggravated Arson – Prosecution must prove that the defendant intended or was reckless as to whether life was endangered by the damage or destruction by fire. ‘Miller’ HOL held that arson can be committed through omission.