Wednesday, September 2, 2020

Grand Isle vs the Awakening free essay sample

The Awakening, is viewed as one of the principal messages tending to the worries of the women's activist development. The story rotates around a little gathering of companions from New Orleansâ who excursion together on Grand Isle each late spring, the principle character being Edna Pontellier. Then again, there’s a movie entitled Grand Isle, which is an immediate interpretation of Chopins epic. Both The Awakening and Grand Isleâ make utilization of setting, images, and characters to uncover a definitive subject of the work: that no one is liberated from society. Amazing Isleâ is a total adjustment of The Awakening and with just a couple minor subtleties changed, the film takes Chopins epic and totally makes an interpretation of it into an alternate medium, regularly citing the novel precisely in character discourse. Dismissing its sources and impacts, as a show-stopper on its own, Grand Isleâ is very much shot with an agreeable cast and depicts its principle topics totally. We will compose a custom paper test on Fantastic Isle versus the Awakening or on the other hand any comparable point explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page The tale and the film vigorously depend on setting, both to organize the occasions of the story and as a technique for imagery. The setting of the novel is truly exact. Numerous families living in New Orleans and comparative urban communities would withdraw to little beach front islands for the late spring to get away from the warmth of the city. On a more significant level, the two principle components of the setting, the city and the island, or development and the wild, fill in as images. The city, or human advancement, represents persecution by cultural requests, while the island, or wild, represents opportunity from societys watch. When Edna is dwelling in the city, she is overloaded by societys desires for her. She should be home on certain calling days, she should be compliant to her significant other, she should put her kids before all else, and she should be the individual that adjusted society urges her to be. Then again, when she is on the island for the late spring, Edna is liberated from a significant number of her obligations. Her better half is regularly away with business, her youngsters go through the days playing at the sea shore, different occupants live so close as to make calling out of date, and Edna is left with a feeling of opportunity from all which holds her down in the city. Another significant viewpoint in The Awakening and Grand Isle is images. Most clearly, water is constantly differentiated against land as a wellspring of opportunity. As is run of the mill in a lot of writing, the water fills in as an image of through and through freedom and absence of restrictions. Similarly as the sea can't be compelled to move in any controlled manner and isn't encased by such a compartment, Edna feels that, while in the water, she has total self-governance over her life. Ashore, be that as it may, this freedom is lost, as she should by and by comply with the shows of society. Ednas self destruction by suffocating in the sea speaks to her accomplishment of extreme discharge from society, for social limitations can't block the dead. Flying creatures fill in as another theme all through the novel and the film, likewise an image of opportunity. As flying creatures are not bound to two elements of development, similar to people and all land abiding creatures, they are viewed as unchained starting from the earliest stage, to move about voluntarily in the extensive and apparently boundless sky. Like a winged animal, Edna feels that she ought to likewise have the option to move and act at impulse, yet like a considerable lot of the feathered creatures in the novel and the film, she is confined and secured by the imperatives of society. Toward the finish of the novel, in spite of the fact that this detail is absent from the film adjustment, an ocean flying creature with a messed up wing is seen hovering over the sea. The winged animal, however still free, still to some degree ready to fly, doesn't have the total, perfect opportunity of different flying creatures. This winged creature speaks to Edna, as she can't have perfect opportunity, for society will consistently be a choking factor, so she should, similar to the harmed fledgling, decide to be free in a blemished way, or remain totally limited and secured. Characters, particularly Edna and her two foils, are significant components of both the novel and the film. As a lady in an exceptionally customary social position, Adele Ratignolle is an outrageous inverse of Edna. Adeles whole life spins around her significant other and kids, and she exists totally inside, and without scrutinizing the imperatives set up by society. This is the sort of lady that Edna feels so unequivocally that she ought not be. On the other extraordinary is Mademoiselle Reisz, who isn't hitched and is depicted as completely free; she has pushed off the most conventional jobs of ladies by staying unmarried and childless, and she frequently laughs at numerous different parts of society and the individuals who continue those perspectives. This is the kind of lady that Edna gazes upward to and tries to imitate. Each of the three of these characters are images for various times of ladies. Chopin utilizes Adele to speak to the conventional lady, content with her absence of opportunity since she knows nothing else. Edna typifies the women's activist development, speaking to change and development towards autonomy. Mademoiselle Reisz is the future lady, the lady that the women's activist development would like to discharge. She is the crucial objective of the women's activist transformation. Generally, while The Awakening and Grand Isleâ are totally the equivalent, the two of them depict one womans arousing to the acknowledgment that society is keeping, and her conviction that she should follow her freshly discovered mindfulness or hazard being held down until the end of time.

Saturday, August 22, 2020

Auto Industry in the United Kingdom Essay Example | Topics and Well Written Essays - 1500 words

Vehicle Industry in the United Kingdom - Essay Example Bristol Motors began is as yet situated in the UK and Mercedes Benz is an agent of the market of the automobile business in the UK too. The vehicle business is principal and is critical in the UK all things considered to the economies everywhere throughout the world. As per Auto Industry the car producing area contributes around 8.4bn increased the value of the economy, and records for 1.1% of GDP, 5.8% of assembling esteem included and 9.5% of all out UK fares of products. Somewhere in the range of 237,000 individuals are utilized in the structure and assembling of vehicles and parts. The West Midlands remains the core of the business in the UK with around 30% of the business being situated in the district. The UK is home to the world's best motorsport industry just as a scope of littler makers serving expert markets, for example, sports and extravagance vehicles, and London taxis. 17 of the top level one providers and around 20 driving autonomous car configuration firms additionall y have a base in the UK. (2005) The car business is a basic component of the UK producing segment. ... Moreover, the car producers that are situated in the UK have a worldwide impact. The UK has a universally select quality improvement activity that is worked and worked by the Society of Motor Manufacturers and Traders' Industry Forum. The reason for these kinds of projects advantage the car producers in a few different ways. A case of these advantages incorporates expanding h the intensity of the organizations, which at last outcome in more benefits for them. Car Industry reports, commonplace upgrades have been in the district of 30% decrease in costs and relating enhancements in quality and conveyance. (2005) Just as the above talked about there are in excess of a thousand car part providers that make their items in the UK. These organizations incorporate Visteon, Federal-Mogul, TRW Bosch and Delphi. d TRW. UK-possessed part producers like GKN, Unipart and Pilkington are among the most famous on the planet. Top Japanese providers, including Ikeda, Yutaka Giken, Denso and Calsonic have been pulled in to the nation, for the most part following in the wake of the Japanese-claimed Vehicle Makers. (Auto Industry 2005) mulling over what has been talked about with respect to the vehicle business in the UK; three agent auto organizations will be examined. The organizations Bristol, Ford and Mercedes Benz will be utilized as a conversation as agent organizations of the car business in the UK. Bristol Cars: ' Bristol Cars is a producer of extravagance cars that is situated in the UK. Bristol produces hand-construct cards and they are situated in Filton, which is close to Bristol England, subsequently the

Friday, August 21, 2020

Three Wars That Led To The Defeat free essay sample

Of Napoleon Essay, Research Paper Three wars that prompted the licking of Napoleon Paper put together by Unknown Napoleon Bonaparte was one of the most impressive work powers ever to walk the substance of the Earth. Many trust him to be the principal hostile to christ, just as Nostradamus anticipated. To the military faculties he told, he was known as the # 8220 ; inviting little substantial # 8221 ; , and to the sovereigns and male rulers that he ousted, he was the # 8220 ; Corsican Ogre # 8221 ; ( # 8221 ; Napoleon Bonaparte # 8221 ; ) . Some idea him to be an incredible reformist. Others imagined that he was a beast. In any case, companion and adversary in like manner could both hang on one thing ; Napoleon I, Head of France and pioneer of a large portion of Europe for 16 mature ages, was one of the most noteworthy and boldest military driving forces of all clasp ( # 8221 ; Napoleon Bonaparte # 8221 ; ) . In any case, as each extraordinary pioneer, Napoleon unreasonably had his ruin. Napoleon took an interest in three wars that prompted his ruin: # 8220 ; The Attack on Russia # 8221 ; , # 8220 ; The War of Nations # 8221 ; , and # 8220 ; Waterloo # 8221 ; . Napoleon was one time cited as expressing, # 8220 ; A contention is an emotional activity which has a start, a middle, and a terminal. The request for strife which the two ground forcess take, the primary movements to come to blows-this is the elucidating ; the counter- movement of the ground powers under invasion signifier the intricacy, which requires personalities and furthermore, welcomes on emergency from which springs the outcome or Denouement ( Gray 6 ) # 8221 ; . Napoleon believed himself to be brilliant and God-like. He felt that he had a destiny to be one of the best military pioneers to ever populate. The grown-up male idea that he could non be murdered on the contention field, he was correct. He went from an officer to the Emperor of France in just ten short mature ages ; he fell in under three. Napoleon drove a ground powers of 600,000 work powers into Russia ( Reihn 159 ) . Bonaparte was ever truly worried about his troopers and ensured that they were acceptable taken consideration of ( Segur 58 ) . Napoleon assaulted Russia from the Neims River on June 24, 1812. Similarly in a matter of seconds as they crossed the Neims, a Cossack amazed them and addressed them. They said they were Gallic and that they had come to do war with Russia. Some of the warriors pursued the Cossack into the wood and terminated at him ( Segur 68 ) . This made Napoleon extremely furious. They rested on the bank of the Neims with their arms in manus. Napoleon other than gave a fire denial with the goal that they would be undetected by their adversary. There was an extraordinary thunder-tempest and they took cover. From that point he made a trip to Kovno. From Kovno they drove the Russians further into Russia. They kept on the Russians trail for a month ( Segur 74 ) . The Russians continued pulling back go into the state, terminating all provisions that Napoleon could use, be! do the Russians realized that Napoleon # 8217 ; s supplies would non keep going truly long ( Reihn 159 ) . After about a month they saw the foe and in a flash began terminating their guns at the adversary. The Gallic won the main clash at Ostrovna. Napoleon # 8217 ; s brother by marriage Murat drove the staying Russians into the backwoods. The Russians took new places. The Russians came out of the timberlands yelling and screech. The Gallic round them down, and the Russians withdrew again into the backwoods. Napoleon requested the battle to end so he could contemplate the land and be after the accompanying clash ( Segur 89 ) . By mid-summer the officers started to gain exhausted and the provisions separated. The dairy cattle and Equus caballuss kicked the bucket and the fighters needed to swamp through the boggy soil. The Russians continued pulling back and after a piece one-hundred and fifty-thousand Gallic warriors had kicked the bucket. He assaulted a walled city called Smolensk, trusting to force the Russians to battle at that place, yet his ground powers was pounded. Napoleon had issue kiping also, he attempted to create a program to improve of the Russians. The Russians lost a tierce of their work powers. At the point when Napoleon in the end arrived at Moscow, it was ablaze. All provisions and haven were gone and he had no pick yet to return back spot with his remaining 100,000 work powers ( Reihn 229 ) . The attack on Russia had fizzled. When Napoleon realized that he had lost in Russia he returned to France to raise another ground powers. He showed up before Christmas in 1812. He realized that Alexander would look to abuse him ( Corley 117 ) . Alexander needed to settle the imprint with France. In the spring of 1813 the battle started. Napoleon and the Tsar arrived at an outside breath point leting both to develop up their ground forcess. Napoleon # 8217 ; s ground powers developed to 400 fifty-thousand. He said he wou ld lead as General, non an Emperor. Malady managed an incredible exchange of damage to Napoleon is ground powers, Ninty thousand French officers were out at once because of affliction. # 8220 ; The Skirmish of Nations # 8221 ; started at Leipzig with 190,000 Gallic warriors against 300,000 Alliess. On the third twenty-four hours, Napoleon began a retreat. Sixty thousand Gallic warriors fell or were caught in the retreat. The entirety of his ground forcess separated, and he came back to Paris in any expectations of procuring more work powers and financess, however the Gallic had given their all ( Corley 124 ) . The Tsar by and by acknowledged the acquiescence of France. The comprehension said that the old administration of male rulers would return. Napoleon figured he could toss out the foe from Paris be that as it may, his heroes requested him to deny. He was ousted to a little island called Elba where he would be permitted to keep up the rubric of Emperor. Napoleon gulped a contemptible of toxicant so as to turn out his interminability. His natural structure did non ingest it, and the toxicant had no outcome. He was bound to battle in one more clash ( Corley 127 ) . Very much settled in Elba, Napoleon had acknowledged the change in his karma until visitants begun coming, expressing him how troubled France was under Louis the fifteenth # 8217 ; s sibling. Napoleon was extremely entertaining about what occurred at the Congress of Vienna, the meeting at which the Allies were puting Europe to rights after all the bothers in the course of the last 25 mature ages. Napoleon cruised back to France in a brig repainted like a British war vessel. A possibility had come ; the Allied official that had been put on Elba to regulate Napoleon needed to go to the territory for a twenty-four hours or two. After Napoleon set canvas, he was in acceptable mixers. He taught non one shooting ought to be terminated in light of the fact that he needed to repossess his Crown without carnage. As he went inland, the nation people started to distinguish that their incredible Emperor was one time again in their thick, and they surged in to invite his arrival. Napoleon moved toward a legion of illustrious military work forces. They were requested to fire at him, then again they hollered and cheered him and joined his ground powers ( Becke 174 ) . A considerable lot of his old officials hurried to his side. Anyway in Vienna the Allies chose to do the Duke of Wellington the Supreme Officer, and Napoleon was named a criminal then again of a delegated head. As a result, Bonaparte concluded he would attack Wellington with fast impudence. Wellington accepted that Napoleon would repeat a similar game that he played last twelvemonth in the run of 1814. The Gallic advancement monitors assaulted the Allies a little internal of the outskirts, however Wellington was as yet timid of Napoleon # 8217 ; s programs. Wellington concluded that he would fall in with the Prussians ( Becke 213-227 ) . It was pouring actually unequivocally. Wellington # 8217 ; s ground powers alongside the Prussians met Napoleon at morning. Napoleon flaunted he would pass on a sound licking. It was early afternoon before Napoleon # 8217 ; s guns started shooting. The Allies were being squeezed hard by the Gallic, yet by the evening the Prussians were all the while coming ( Becke 2: 20-43 ) . Napoleon sent in the supreme gatekeeper as a finishing up endeavor to nail the united cutting edge. At the point when they were 20 paces off, Napoleon requested them to open fire. The Duke of Wellington requested the line to counter-assault the worn out Gallic ground powers. Vanquished, Napoleon rode toward the outskirts ( Becke2: 70-97 ) . He intended to compose another ground powers and get down another run, yet Napoleon was gotten by the British ground powers at Waterloo. He attempted to convey them to permit him travel to America ( Becke 2: 132-189 ) . Bonaparte said he would revoke just if his kid were declared Napoleon II Emperor of the Gallic. This idea was forgotten about by the British, yet Napoleon gave up in any case. He had earned everlasting status and superstar, yet he could non experience that to his kid ( Thompson 214 ) . Napoleon was ousted to a little island called St. Helena. Bonaparte had this to state about Waterloo: # 8220 ; The program of the contention will non, according to historiographers, mirror any acknowledgment on Lord Wellington as a general. The glorification of such a triumph is a incredible thing ; yet in the oculus of the historiographer his notoriety will infer nil by it ( Gray 100 ) . # 8221 ; Napoleon passed on the island of St. Helena in the organization of a couple of his companions with his secretary close by. The unfading general had been brought to his expire on May 5, 1821 ( Chevalier 201 ) in a little manor. Napoleon had picked up everlasting status and big name ( Thompson 214 ) . He passed on a saint. In spite of his disappointments, he will ever be viewed as one

Friday, May 29, 2020

They say/I say (or the point of Critical Reading)

If you look in the Official College Board Guide, 2nd edition (aka the Blue Book), youll see that the sample essays in the front of the book are written in response to a prompt that asks whether there is always a however (i.e. are there always two sides to every argument?) It recently occurred to me that the College Boards choice of that particular prompt for inclusion in the Official Guide was not an accident; on the contrary, its a sort of clue to the test, an inside joke if you will. And in classic College Board style, its laid bare, in plain sight, for everyone to see, thereby virtually guaranteeing that almost everyone will overlook it completely. Let me back up a bit. When I took the SAT in high school, one of the Critical Reading strategies I devised for myself was, whenever necessary, to write a quick summary of the argument of that the author of a passage was both for and against. So if, for example, a question asked how a particular author would be likely to view the advocates of a particular idea (lets say string theory, just for grins), I would write something like this: Author: ST = AMAZING! (string theory is amazing) Advocates: ST = WRONG! (string theory is wrong) Therefore, author disagrees w/advocates, answer = smthg bad It never struck as anything but utterly logical to keep track of the various arguments that way. As a matter of fact, I took the process of identifying and summarizing various points of view so much for granted that it never really occurred to me that keeping track of all those different points of view was actually was more of less the point of the test. Of course I knew it at some level, but not in a way that led me to address it quite so explicitly as a tutor. I assumed that it was sufficient to tell my students that they needed to keep track of the various points of view; not until about a year ago did it truly dawn on me that my students couldnt keep track of those points of view. They were having trouble with things like main point because they couldnt distinguish between authors opinion and other peoples opinions, and therefore I needed to explain some very basic things upfront: 1) Many SAT passages contain more than one point of view. 2) The fact that an author discusses an idea does not necessarily mean that the author agrees with that idea. 3) Passages contain more than one point of view because authors who write for adults often spend a lot of time conversing with people sometimes imaginary people who hold opposing opinions. Authors are essentially writing in response to those other people. 4) There are specific words and phrases that a reader can use to identify when an author is talking about his or her own ideas vs. someone elses ideas. 5) The fact that authors discuss other peoples ideas does not make them ambivalent or mean that they do not have ideas of their own. 6) It is also possible for authors to agree with part of someone elses idea and disagree with other parts. Again, this does not mean that the author is ambivalent. In other words, theres always a however, and if the author of Passage 1 doesnt give it to you, the author of Passage 2 almost certainly will. Not surprisingly, I have Catherine Johnson to thank for this realization. A while back, she posted an excerpt from Gerald Graff and Cathy Birkensteins book, They Say/I Say: The Moves that Matter in Academic Writing on her blog, and reading it was a revelation for me. Id already touched on they say/I say model in a very old post (SAT Passages and Deep Structure), but Graff and Birkensteins book explained the concept in a far more direct, detailed, and explicit manner. It also took absolutely nothing about students knowledge for granted. Id already written a first draft of The Critical Reader at that point, but when I read that excerpt, something clicked and I thought, thats it thats actually the point of Critical Reading. THATS what the College Board is trying to get at. To be sure, Critical Reading tests a number of other things, but I think that this is one of the most if not the most important. If you understand the strategies that authors use to suggest agreement and disagreement with arguments, you can sometimes understand almost everything about a passage its content, its structure, its themes just from reading a few key lines. They Say/I Say provided me with the thread that bound the book together. It also provided the very important link between reading on the SAT and reading in the real world (or at least in college) a link that some critics of the SAT (!) insist rather stridently does not exist. Then, in a colossal duh moment a couple of days ago, it occurred to me that the point of the quote before the essay prompt is to provide students with the option of using the they say/I say format in their essays (if they so wish) its just that the students have so little experience with that format (if they even know it exists) that it never even occurs to them to use it! Just how little experience students have with it became clear, incidentally, when I was working with students on the synthesis essay for the AP French exam. As is the case for AP Comp, students are given three sources and expected to compose a thesis-driven essay, integrating the sources into their writing. Theres no way to earn a high score without using all of the sources, and since the sources cover all sides of the argument (pro, contra, neutral), at least one source will contradict the students position. So basically, the point of the exercise is to force them to integrate opposing viewpoints into their writing. As I discussed the essay with my students, however, I made two intriguing discoveries: 1) They did not really understand that the essay was thesis-driven and that it was ok for them to express their own opinions. They equated having to include multiple side of an argument with not having an opinion. They were stunned and relieved to discover that it was ok for them to actually write what they thought instead of simply summarizing what all the various sources said. Incidentally, their teacher had told them that more than once, but I think the concept was too foreign for them to fully grasp. 2) They did not know how to integrate other peoples words and ideas into their own arguments in anything resembling a fluid manner. Instead of writing things like As Sorbonne Professor Jean-Pierre Fourrier convincingly argued in a May 2009 article that appeared in Le Monde, the encroachment of English into the French language is nothing new, they would write something like this: Jean-Pierre Fourrier, a professor at the Sorbonne, says the encroachment of English into the French language is nothing new (Source 1). When I showed one of students (a very smart girl and a strong writer) how to do the former, she was thrown off guard. Oh, she said. I didnt know that. Of course you didnt know that, I said matter-of-factly. No one taught you how to do it. So Im teaching you now. That was another lightbulb moment for me. The thought had drifted across my consciousness before, but it hadnt quite pushed its way to the surface. Reading and writing are two sides of the same coin. Students who havent been taught how to make use of certain strategies explicitly in their own writing are therefore unlikely to recognize those strategies in other peoples writing. Ergo, when an author interweaves his or her opinions with someone elses opinions in the same passage or paragraph, sometimes even in the same sentence, students have limited means of distinguishing between the two points of view. I think that this is something that should be covered very explicitly and thoroughly in AP Comp class, but something tells me that it isnt. I certainly didnt learn it in high school; instead, I picked it up in college by reading lots of academic articles and simply copying what professional scholars did. So whats the solution? It is in part, I think, They Say/I Say or something like it (note the very subtle plug for The Critical Reder here;). Ive said it before, and Ive said it again: the only way to prepare for a college-level test is to read things meant for college students, which They Say/I Say certainly is. So if youre taking the SAT next Saturday and are reading this in the hopes of picking up some last-minute miracle tips for Critical Reading, heres my advice: read Cathy Birkenstein and Gerald Graffs introduction to They Say/I Say. It wont give you any SAT-specific tricks, but it will explain to you clearly and bluntly, just what it is that most of the writing youll encounter on the SAT is trying to accomplish. Even if it doesnt  solve all your problems, but it might demystify the test a bit and make Critical Reading seem a little less weird.

Saturday, May 16, 2020

Multicultural Team Creates Frustrating Management Situation

1.Main purpose of the article: Multicultural team often creates frustrating management situation. To solve conflicts caused by cultural differences in a multicultural team, identifying cultural problems and having different strategies for solution is important. 2.Most important information in this article: There are many conflicts that is caused by different culture in our workplace. For example: 1. An American manager was leading a project in Japan, when she pointed out the problem directly to her boss in an email without discussing them first with her Japanese colleagues, even though her boss was happy of the direct warnings, her Japanese colleagues was embarrassed by her direct style of communication. Subsequently, her Japanese colleague isolated her from overseeing project progress. 2. A Latin American member of multicultural consulting team felt that because of the language difference, although her skill level is subpar with his American colleague and has a good question for the interview, her American colleague tend to lead the interview with the client. During an interview of a U.S-Japanese team for the potential of expansion of U.S retail chain into Japan, her American colleague tend to underestimate the feedback from the Japanese consultants because they are not fluent in English and considered them not intelligent enough. He disregards the aspects that Japanese know Japan’s business situation better than him. 3. In Mexican culture, even though managers understandShow MoreRelatedMulticulturism1524 Words   |  7 Pagesarticle â€Å"Managing Multicultural Teams† (henceforth referred as core article) are of the opinion that cultural differences are sometimes capable of exacerbating challenges associated with effective team work. 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April 15, 2015 Contents Introduction 3 My Five Strengths 3 Achiever 3 Harmony 4 Futuristic 5 Restorative 6 Responsibility 6 How do your Strengths Finder talents support the primary planning, organizing, leading, and controlling activities of a manager? 7 Which Strengths Finder talents would you focus personal development activities on if you would pursue a management position or improve in your management current positionRead MoreNegotiating For Your Employer?1644 Words   |  7 Pagestactics that are very different can be quite frustrating. However, becoming aware of how certain countries respond or react will make business transactions run smoother. These two countries negotiate differently. However, it does not make one cultural superior to the next. Knowing this information about the culture ahead of time brings incite on who needs to sit in on what meetings. It also says who needs to be the negotiator depending on the situation and the need for the business. Knowing certainRead MoreCross- Cultural Communication2005 Words   |  9 Pagestwo factors that have raised the importance of Cross-Cultural Communication can be stated as follows- †¢ Improvements in communication and transportation technology have made it possible for previously stable cultures to meet in unstructured situations, e.g. the internet opens lines of communication without mediation, while budget airlines transplant ordinary citizens into unfamiliar milieux(the social and cultural environment in which a person or thing exists). Experience proves that merely crossingRead MoreNational Basketball Association Is Not A Diverse Sport Essay2001 Words   |  9 Pagesthe NBA for the 2014/2015 season was 5.18 billion dollars, this is due to the organizational diversity of the NBA. The National Basketball Association consists of 30 teams. Each team has a head coach. A team can have 15 players on a team, 13 of the 15 can be active. In the 2014-2015 season there were 446 players playing on times 30 teams. Of those 446 players, the percent of players who were classified as African-American or Black in the league was 74.4 percent (332), White players made up 23.3 percentRead MorePrinciples and Practices of Management2971 Words   |  12 Pagesnot only train and develop employees but create relationships and boost morale within the organization as well. A customer service representative may benefit most by podcasting and classroom. Podcasting would allow the workers to go through scenario based lessons on a computer. Being able to see the different ways to properly handle a situation on the computer can increase their problem solving skills. A classroom discussion on handling certain situations may also greatly benefit workers as wellRead MoreThe Nature of Communic ation10702 Words   |  43 Pageswhom you want to do with business with and add to your network. The success of any encounter begins the moment someone lays eyes on you. One of the first things they notice about you is your aura, that distinctive atmosphere that surrounds you. You create it, and you are responsible for what it says about you and whom it attracts. Your aura enters with you and starts speaking long before your open your mouth. Since body language conveys more than half of any message in any face-to-face encounter, howRead MoreCase Study on Ibm7721 Words   |  31 PagesSTraTEGIc Hr ManaGEMEnT case study–PaRt a IBM’s Global Talent Management Strategy: The Vision of the Globally Integrated Enterprise By John W. Boudreau, Ph.D. Project team Author: SHRM project contributor: External contributors: John W. Boudreau, Ph.D. Nancy A. Woolever, SPHR Randy MacDonald Richard Calo Michelle Rzepnicki Katya Scanlan Jihee Lombardi Copy editing: Design:  © 2010 Society for Human Resource Management. John W. Boudreau, Ph.D. Development of this case was made possible by a grant

Wednesday, May 6, 2020

Office Policy Regarding Prevention And Detection Of...

The purpose of this antifraud statement is to communicate municipal policy regarding prevention and detection of suspected fraudulent behavior and dishonesty by employees and others, and to provide explicit instructions to follow in case of violations. The development of this antifraud policy is to emphasize a zero-fraud tolerance from public employees; it also sends out a clear message to public managers and taxpayers that their City will not tolerate fraudulent conduct. The City is committed to preventing fraud and corruption from occurring and developing an antifraud environment. City officials and employees must always observe all the applicable rules and regulations pertaining to fraud prevention. The City will not tolerate the†¦show more content†¦Skimming- Stolen cash from the City before it has been recorded on the City’s financial records. Cash Larceny- Stolen cash from the City after it has been recorded on the City’s financial records. ïÆ'Ëœ Inventory and other assets Misuse – Inappropriate use, misapplication, destruction, removal of City’s inventory or assets for personal use. (i.e., using City’s vehicles for personal errands) Larceny – Stolen inventory or other assets from the City. Corruption – Unlawful use of influence in a business transaction in order to obtain some benefit from another person. ïÆ'Ëœ Conflict of interest – An undisclosed economic or personal interest in a transaction that negatively affects the City. ïÆ'Ëœ Bribery - The giving, offering, receiving or asking of anything of value to influence and official action. ïÆ'Ëœ Illegal Gratuities – Someone that benefits from a business decision in giving of a gift to a person who make the decision. This fraud does not need proof of intent to influence. ïÆ'Ëœ Economic Extortion – Employee demands payment from a vendor/contractor to influence an official’s business decision. Fraudulent Statements – Misrepresentation of the City’s financial statements. ïÆ'Ëœ Inappropriate reports of revenues and expenses to intentionally misrepresent the financial position of the City. Fraud Awareness and Prevention AllShow MoreRelatedAnti Fraud Professions3098 Words   |  13 Pagesthe professional can work in the private sector similar to the private funded hospital like St. Jude, and St. Francis. The anti-fraud professional can also work in the public sector such as a government funded hospital, nursing home, and welfare office. This paper focuses on the anti-fraud professional and the background of fraud and the importance of being a certified fraud examiner. Table of Contents 1. Introduction a. What is Fraud? b. How does Fraud Occur? c. PreventingRead MoreOrganizational Fraud9733 Words   |  39 Pages1. Structural red flags 11 3.6.2. Personnel red flags 12 3.6.3. Operational red flags 12 3.6.4. Accounting system red flags 12 3.6.5. Financial performance red flags 12 4. ESSENTIALS OF ORGANIZATIONAL FRAUD 12 4.1 Detection 13 5. SATYAM SCANDAL 14 5.1 Lessons for HR Professionals 14 5.2 Lessons for India Companies 15 6. ORGANISATIONAL EMPOWERMENT 16 7. RISK OF FRAUD IS LESSENED IN EMPOWERED ORGANIZATION 16 8. IMPACT OF FRAUD 16 8.1 MacroviewRead MoreComprehensive Review in Accounting19880 Words   |  80 Pagesinformation in the financial statements. 2. In relation to auditing, which of the following is a correct phrase? a. Auditing communicates results to management. b. Auditing involves obtaining evidence regarding action and events. c. Auditing evaluates assertions regarding evidence. d. Auditing subjectively obtains and evaluates evidence. 3. Which of the following is not an output of an independent audit engagement? a. Management letter. b. Audit report. c. EngagementRead MoreCorruption Is Barrier to Development in Pakistan9592 Words   |  39 PagesAdministrative Corruption 3. Causes of Corruption in society 4. Genesis of Corruption 5. Consequences of Corruption II. Corruption in Pakistan and barrier to its development. 1. Factors encouraging corruption in Pakistan A. Poor government policies B. Arrival of foreign remittance C. Afghan War 2. A barrier to development in Pakistan A. A crime against prosperity B. A barrier to justice C. A barrier to democracy D. A crime against the environment E. A barrier to health F. A barrier to educationRead MoreManaging Information Technology (7th Edition)239873 Words   |  960 PagesData Resource The Data Model and Metadata Data Modeling 98 Database Programming 100 97 97 Contents Managerial Issues in Managing Data Principles in Managing Data 101 101 The Data Management Process 106 Data Management Policies 110 Review Questions 114 †¢ Discussion Questions 114 †¢ Bibliography 114 ̈ CASE STUDY I-1 IMT Custom Machine Company, Inc.: Selection of an Information Technology Platform 116 ̈ CASE STUDY I-2 VoIP2.biz, Inc.: Deciding on the Next Steps for a

Tuesday, May 5, 2020

Australian Administrative Law-Free-Samples-Myassignmenthelp.com

Question: Administrative Law mechanisms are largely ineffective and don't provide real avenues for review. To obtain justice, a person should call upon the power of the Courts and ignore the Administrative law framework altogether Do you agree or disagree? Answer: Australian administrative law sets out the degree of responsibility and powers provided to the Australian administrative agencies. It is fundamentally a common law system which has enhancing legislative overlay which have transferred its emphasis towards extensive jurisdiction tribunals and fixed system of judicial review. The rule of law had been established since the Magna Carta of 1215 It has been followed thoroughly in the jurisprudence after the re-drafting of the concept in the late 13th century. Section 75 of the Australian constitution states that original jurisdiction is vested in the high court in the matters where the person being sued or suing is the commonwealth, or on behalf of the commonwealth and in matters where the writ of prohibition or mandamus is claimed against any person related to the commonwealth. Such jurisdiction cannot be altered as it has been provided by the constitution itself and is only possible through amendment by national referendum. The fundamenta l idea in relation to the rule of law is that the application of law has to be made equal to the persons who rule and those who are ruled. The purpose of this paper is to find out whether the mechanisms of administrative law are ineffective largely and do not allow appropriate revenue for the purpose of review and in order to attain justice, people should take the help of the courts and do not consider the framework of administrative law at all. The paper throws a light on the rule of law on which both the frameworks are based. The paper than discusses judicial review in relation to administrative law. The paper discusses the advantages and disadvantages of administrative law and compares it to the court system to analyze the effectiveness of administrative law. The relationship between the people and the government is established by the rule of law. According to Douglas, Roger and head (2014) the stage at where law ends, tyranny is initiated[1]. In addition the concept of the rule of law states that the law in sense is applicable on the behavior and conduct of both public and private officials. The significant sub principles of the rule of law states that no person in the land is bigger than the law, no person on land is inferior to another for law, legal redress is available through courts and the law is always applied. However the concept of the rule is not very simple and can be explained in the best way through the collection of many sub-principles. A comprehensive survey is conducted by the Administrative Review Council in relation to the federal review for the purpose of Administrative Action regularly to analyze the effectiveness of administrative law. As described by Don (2013) the rule of law is a noble lie which is present in the British constitution[2]. As mentioned above then purpose of the rule of law is to make sure that no person can be bigger than the law. The implication of this principle is that all persons are bound to the law. Law is not only applicable to the members of the society but also on the ministers and other administrative officials.[3] Administrative law is the organ of law through which the activities of the administrative agencies made by the government are governed. Actions which are allowed by administrative law to the government agencies include adjudication, rulemaking or enforcing a particular regulatory agenda. Administrative law is a part of public law. As administrative law is a part of public law it is concerned with decision-making related to the administrative units of the government such as commissions, boards and tribunals which are an organ of national regulatory schemes in domain such as international trade, police law, broadcasting, environment taxation and transport. The expansion of administrative law had been triggered significantly in the twentieth century as during this time various government authorities had been created by legislative bodies around the world in order to govern economic, political a social sectors of human interaction.[4] Countries which are governed by civil law have their own special administrative courts which review the decisions of the agencies. On the other hand most of the countries which abide by the principles of common law have enacted a procedure of judicial review which restricts the capacity to be reviewed in relation to the decisions which are made by the administrative bodies[5]. The process is often added with statues and other common law principles which provide a standard rule making process. The review of decisions made by semi-public bodies like disciplinary boards, non-profit corporation and other bodies of decision making which have an effect on the rights of the members of an entity or particular group is also facilitated through administrative law.[6] The judicial review in relation to the decisions of administrative bodies is not as same as the process of administrative appeal. While making a review of the decisions made by the administrative bodies the process in which the decision had been made will only be considered by the court and in case of an administrative appeal the correctness of the decision is verified by a higher body in the hierarchy. The significance of this system is very much in order to appreciate administrative law in the common wealth countries.[7] Parties who are not satisfied with the decision of an agency or minister can take the support of the external review system where the appropriateness of the original decision is determined. The Administrative law in the Australia is a part of the public law which is related to the procedures, powers, duties, liabilities and rights of public bodies through which public policies are administered. The common principle of administrative law states that the administrator or a government officials must be fair and reasonable and in accordance to law while discharging their duties. This concept is the essence of administrative law and the rest is all machinery.[8] The history of administrative law review in the Australia can be traced from the since 1960s which resulted out of the problems from bureaucratic decisions[9]. As a result a committee of selected people had been established in the year 1970 and the recommendations of the company set the foundations for administrative law in Austra lia. The most significant of these recommendations were in relation to the Kerr report which provided for the establishment of the administrative tribunal which had the authority to review administrative decisions on codification, merit and procedural reforms in relation to the judicial review system and the initiation of the ombudsman office. The proposals had been brought into practical use through the passing of the number of federal legislations like the Ombudsman Act 1976, the Administrative Appeals Tribunal Act 1975, the Freedom of Information Act 1982 and the Administrative Decisions (Judicial Review) Act 1977. The process of administrative law initiates from the doctrine of delegated legislation. The law which is not passed through the act of the parliament is known as delegated legislation. Instead a powering act provides the authority to the bodies, person or minister to make delegated legislations. Compared to only a few acts of parliament thousands of delegated legislations are enacted every year by the local bodies. The use of delegated legislation can be in relation to a broad scope of purposes such as technical and narrow matters like setting fees level for a public service to filling details about how a legislation setting out wide principles would in practice be implemented. Delegated legislation in form of administrative law has several advantages and disadvantages. Firstly the enactment of delegated legislation does not is done without the utilization of a lot of time as the various processes which are involved in relation to the cats of a parliament does not have to be observed [10]. It does not take up the precious time of the parliament in relation to deciding small matters such as traffic signs, details of pension schemes thus giving the time to the parliament to focus on significantly broad policies and principles. Secondly, the system ensures that the rules and regulations related to technical matters are designed by those who are experts in such area. Thirdly, the flexibility which is provided through delegated legislations ensures that changing circumstances are dealt which speedily such as increasing service costs, scientific scheme development and minor changes required by policies.[11] On the other hand the process of delegated legislation is often criticized for not been subjected to adequate scrutiny of the parliament as compared to parliament legislations and thus could be used by the bodies in such way which have not been intended or power for which has not been conferred by the parliament to the bodies. In addition a few matters which are ve ry significant and controversial to the public are taken away from the control of the parliament and put in the hands of the government. Another problem with administrative delegated legislation is the number of laws which are passed by the bodies. The number is so large that the public does not get the chance to be aware of the changes. Judicial review is a procedure through which the courts regulate the exercise of power by a public body. If an exercise of power seems unlawful, one may apply to the Administrative Court which is a division of the High Court, for the judicial review of a decision. If the court finds the decision to be violate of any law, it may quash the decision, or award monetary compensation or even may impose an injunction upon the public body[12]. In the case of Council of Civil Service Unions v Minister for the Civil Service [1985] AC 374, as summarized by Lord Diplock, the grounds of judicial review that can revert an administrative decision are Illegality, Procedural impropriety, Irrationality, Legitimate expectation. According to Diplock, the proper and correct understanding of the law, by the decision-maker, that regulates the decision-making power to the decision-maker, is required and it should be effected in the same sense, as obtained from the intent of the law. In the case Bromley Council v Greater London Council (1983), the local council, acted outside the purview of its authority. It was held that the ground of illegality as a ground of judicial review applies to this case. In Australia independent merit reviews of the decisions provided by administrative id done by the Administrative Appeals Tribunal according to the rules of the commonwealth. AAT has been provided the authority to review decisions made by the commonwealth departments, agencies and ministers. The decisions which are made by the non-government bodies and the state governments can also be reviewed by the AAT in specific circumstances. The AAT has been imposed with the duty of making correct and preferred decisions in every case which is brought before it. The establishment was AAT was under the Administrative Appeals Tribunal Act1975as a body between administrative agencies and courts. It is based on the principles of being informal quick economic and fair. The most significant change which has been introduced in Australian through AAT is the right of reviewing a decision based on its merits along with the right to gain information about the reasons behind the decisions[13]. The failure by the decision-maker to observe procedural rules that are provided in the legislation expressly, that confers it it's jurisdiction, faltering to observe rules of natural justice, not acting in accordance with procedural fairness etc. are all included within the purview of procedural impropriety. The Aylesbury Mushroom Case (1972) bears example of such procedural impropriety. A legitimate expectation is said to arise when a person or an association of persons, has been made to understand, by a policy, promise or representation of a public body that, certain steps will be followed in reaching a decision. For instance when an individual or a group has been made to think that certain steps will apply, when an individual or a group relies on a policy or rules by which an area of past executive action is governed. In the case of R v Liverpool Corporation, ex parte Liverpool Taxi Fleet Operators (1972), this has been considered. The court may emphasize that a public body would follow certain procedures ("procedural" expectations), on an expectation of some substantive benefits and not only on a legitimate expectation. The court may emphasize that a public body would follow certain procedures ("procedural" expectations), on an expectation of some substantive benefits and not only on a legitimate expectation. Speaking technically, the judicial function and powers are the primary the work of the courts The High Court is the highest appellate court in the Australia. The principles related to judicial review are provided through Administrative Decisions (Judicial Review) Act 1977(Cth) in Australia. Due to the concept of parliamentary sovereignty followed in the Australia, the High Court is much more restricted in its powers of judicial review in comparison to that of the Constitution or Supreme Courts of some other countries. It is incapable of changing entirely, any primary legislation made by Parliament. However, if any secondary legislation is found to be out of the scope of the powers in primary legislation, the Supreme Court can revert such legislation.[14] Under provisions of Administrative Decisions (Judicial Review) Act 1977(Cth), the High Court, may make a declaration of incompatibility, that is, the legislation subject to the declaration is incompatible with one of the rights in the Australian Constitution. Such a declaration can apply to legislation, irrespective of it being primary or secondary legislation. Traditionally a plaintiff is required to show standing under common law before a right is provided to them to take an action as provided by Australian Conservati on Foundation v Commonwealth[1979] HCA[15]. In case the proceedings are brought under Administrative Decisions (Judicial Review) Act 1977(Cth) the claimant can be any person who has suffered by a decision which is reviewable[16]. A provided by the doctrine of separation of powers in Australia the powers of the courts are only limited to challenge the validity of the decisions made by the executives and not the nature of the decision. The context had been made clear by the High Court in the case of Minister for Aboriginal Affairs v Peko-Wallsend Ltd[1986] HCA 40[17]. However it is not easy to make a distinction between legality and merit matters. In Australia unlike the US or the UK no doctrine exists which prevents the courts from reviewing political questions. Under ordinary circumstances, the courts cannot invalidate legislation and no Parliament can pass laws which the future Parliaments cannot absolutely change[18]. The doctrine of Parliamentary sovereignty does not leave much scope for the judicial review of the Acts of Parliament. The judicial review is thus limited to the decisions of officials and public bodies, and secondary legislation or delegated legislation in Australia .However, ordinary common law remedies, special prerogative orders, etc. are available in certain circumstances against these, where judicial review is not available[19]. The doctrine of ultra vires, dominates the constitutional theory of judicial review. According to the doctrine, the decision of a public authority that exceeds the powers given to it by Parliament can be reviewed. The enforcement of will of Parliament", in accordance with the doctrine of Parliamentary sovereignty, was seen to be the aim of the courts. However, the interpretation of the doctrine has been allowed to be expanded to include errors of law and of fact. The courts have also declared that the rulings under the Royal Prerogative, are subject to judicial review. Therefore, the need to obstruct the abuse of power by the executive along with the need to protect rights of the individuals, determine the contemporary constitutional position of the judicial review[20]. In the case of Batemans Bay Local Aboriginal Land Council v Aboriginal Community Benefit Fund Pty Ltd[1998] HCA 49 it was provided by the High Court of Australia that it is not within the scope of judicial review to review matter which are politically sensitive and related to National security[21]y. In addition with respect to prerogative decisions justifiability cannot initiated through administrative decisions (Judicial Review) Act 1977(Cth) because the Act is only limited to decision which are provided under an legislation of the commonwealth. The system is comparatively young in form of an organized system of rules which are focused upon the rule of law. Generally, most of the scholarly interest in the system is related to judicial review as a form for mediation relations among the state and the individuals. Going towards a few main mechanisms which underline the functioning of administrative justice it can be stated that there are four for consideration which include consultatio n requirements, tribunals, parliamentary ombudsmen and judicial review. These mechanisms provided that how disputes can be addressed before the need of increased formal mechanisms are applied. Taking the example of judicial review a well-established pre action protocol exists which has to be observed in most of the cases before any proceeding can be directed towards the High Court[22]. Consultation requirements are in the Australia are provided through traditional common law principles of fairness which is also known as the rule of natural justice and the value which include informed decision making. The principles of common law provide a right to fair hearing to all individuals which was liked historically to a more constrained protection of rights and interest are now potentially applicable whenever anything is decided. The winding of the scope related to a fair trial has been a part of the narrative doctrine which has developed in around the system of judicial review where the im portance of hearing rights have been provided to the persons even in case of complex national security cases. However, according to the consultation requirement is not the only thing which ensures common law principles as they can also be applied by a legislation which delegates an authority of decision making to public decision makers. The bodies are also involved with the concept of soft law where the views of those affected by decision making are taken into consideration[23]. The debate which stands now is that whether administrative law should be used or it should be totally eradicated and a structured court system should be the only platform for problem solving in Australia. As discussed above there are several advantages and disadvantages which the administrative law system is subjected to just as there are several limitations to the process of judicial review by the courts. Considering, the system of justice provided through the court is also not only limited to advantage, one may conclude that the system of courts is not reasonable to be relied upon independently without the administrative framework supplementing it. Reference List Asimow, M., 2015. Five models of administrative adjudication.The American Journal of Comparative Law,63(1), pp.3-32. Barnett, Hilaire.Constitutional and administrative law. Taylor Francis, 2017. Bingham, L.B., 2010. The next generation of administrative law: building the legal infrastructure for collaborative governance.Wis. L. Rev., p.297. Buck, Trevor, and Richard Kirkham.The ombudsman enterprise and administrative justice. Routledge, 2016. Cane, P., 2011.Administrative law. OUP Oxford. Douglas, Roger, and Michael Head.Douglas and Jones's administrative law. 2014. Elliott, M. and Varuhas, J., 2017.Administrative law: text and materials. Oxford University Press. Farber, Daniel A., and Anne Joseph O'Connell. "The Lost World of Administrative Law." (2014). Forsyth, C.F., 2016. Leading Administrative Law Cases: M v The Home Office [1994] 1 AC 377. Gageler, S., 2017. Controlling Administrative Power: An Historical Comparison. By Peter Cane [Cambridge University Press, 2016. xxiii+ 583 pp. Hardback 59.99. ISBN 978-1-107-14635-8.].The Cambridge Law Journal,76(2), pp.430-433. Gardbaum, S., 2014. Separation of powers and the growth of judicial review in established democracies (or why has the model of legislative supremacy mostly been withdrawn from sale?).The American Journal of Comparative Law,62(3), pp.613-640. Hawke, N., 2013.Introduction to administrative law. Routledge. Law, Matthew Astley. "Attaining Locus Standi as a Private Party in Judicial Review Proceedings in European Community Law: A virtually impossible task?."Diffusion-The UCLan Journal of Undergraduate Research2.2 (2015). LeDuc, Don.Michigan Administrative Law. Thomson Reuters, 2013. Leyland, P. and Anthony, G., 2016.Textbook on administrative law. Oxford University Press. Leyland, Peter, and Gordon Anthony.Textbook on administrative law. Oxford University Press, 2016. Loughlin, M. and Tschorne, S., 2016.Public law(pp. 324-337). Routledge. Loveland, I., 2012.Constitutional law, administrative law, and human rights: a critical introduction. Oxford University Press. Manaster, A. Kenneth, and Daniel P. Selmi.Administrative Law Issues. Vol. 1. California Environmental Law Land Use Practice, 2016. Marume, S.B.M., Jubenkanda, R.R., Namusi, C.W. and Madziyire, N.C., 2016. The Principles of natural justice in public administration and administrative law. Parpworth, N., 2016.Constitutional and administrative law. Oxford University Press. Parpworth, Neil.Constitutional and administrative law. Oxford University Press, 2016. Raadschelders, Jos.Handbook of administrative history. Routledge, 2017. Rawlings, R., 2014. Administrative law in context: restoring a lost connection.Public Law, pp.28-42. Simon, William H. "The organizational premises of administrative law."Law Contemp. Probs.78 (2015): 61. Vermeule, Adrian. "Rationally Arbitrary Decisions in Administrative Law."The Journal of Legal Studies44.S2 (2015): S475-S507. Werhan, Keith.Principles of Administrative Law, 2d (Concise Hornbook Series). West Academic, 2014 Douglas, Roger, and Michael Head.Douglas and Jones's administrative law. 2014 LeDuc, Don.Michigan Administrative Law. Thomson Reuters, 2013. Craig, P., 2015.UK, EU and global administrative law: foundations and challenges. Cambridge University Press. Gageler, S., 2017. Controlling Administrative Power: An Historical Comparison. By Peter Cane [Cambridge University Press, 2016. xxiii+ 583 pp. Hardback 59.99. ISBN 978-1-107-14635-8.].The Cambridge Law Journal,76(2), pp.430-433. Parpworth, Neil.Constitutional and administrative law. Oxford University Press, 2016. Asimow, M., 2015. Five models of administrative adjudication.The American Journal of Comparative Law,63(1), pp.3-32. Parpworth, N., 2016.Constitutional and administrative law. Oxford University Press. Loveland, I., 2012.Constitutional law, administrative law, and human rights: a critical introduction. Oxford University Press. Raadschelders, Jos.Handbook of administrative history. Routledge, 2017. Simon, William H. "The organizational premises of administrative law."Law Contemp. Probs.78 (2015): 61 Elliott, M. and Varuhas, J., 2017.Administrative law: text and materials. Oxford University Press. Manaster, A. Kenneth, and Daniel P. Selmi.Administrative Law Issues. Vol. 1. California Environmental Law Land Use Practice, 2016 Buck, Trevor, and Richard Kirkham.The ombudsman enterprise and administrative justice. Routledge, 2016. Marume, S.B.M., Jubenkanda, R.R., Namusi, C.W. and Madziyire, N.C., 2016. The Principles of natural justice in public administration and administrative law. Australian Conservation Foundation v Commonwealth[1979] HCA. Administrative Decisions (Judicial Review) Act 1977(Cth) Aboriginal Affairs v Peko-Wallsend Ltd[1986] HCA 40 Australian Communist Party v Commonwealth[1951] HCA 5 Pape v Commissioner of Taxation[2009] HCA 23 Plaintiff S157/2002 v Commonwealth[2003] HCA 2 Batemans Bay Local Aboriginal Land Council v Aboriginal Community Benefit Fund Pty Ltd[1998] HCA 49 Ruddock v Vadarlis[2001] FCA 1329 Minister for Immigration and Citizenship v Li[2013] HCA 18, (2013) 249CLR332