The Community Guide, American Association, And American...

Know How Paper #3 Program planning involves the use of many well defined evidence based practice and services. In this paper we will elaborate on three services which public health professionals may use in a variety of ways to perform their job more effectively. Our focus areas include the Community Guide, American Diabetes Association, and American Heart Association. For each area we will include a brief discussion summarizing the areas, their values in the field, relevant theories the area encompasses, and how each might be applied in the profession. While the topics of each area may differ, we hope you will gain a better understand for each and see how much of their goals and approaches overlap. Area Summaries The Community Guide The Community Guide (TCG) is a website offering a plethora of resources useful to community health workers (Truman, Smith-Akin, Hinman, et al., 2000). It is one place in which professionals may seek information on which interventions do and do not work. The literature provided is valid and backed by the Centers for Disease Control and Prevention (CDC) and other supporting organizations, agencies, and researchers. The U.S. Department of Health and Human Services (DHHS) established this resource, also known as The Community Preventive Services Task Force, in 1996. As mentioned above, the original goal was to simply provide communities with interventions for disease prevention and health promote on in regards to what does and does notShow MoreRelatedThe 10 Essential Public Health Services908 Words   |  4 Pagesand policy development. Every community and public health organization should undertake activities that represent the 10 essential public health service s. The American Heart Association is a nonprofit agency that embodies some of the essential public health services. Headquartered in Dallas, Texas, the AHA has many local offices that serve various communities across the country. It is important for the AHA to be involved in building healthier communities because heart disease and stroke are the numberRead MoreEssay On Health Advocacy Campaign761 Words   |  4 Pagesthe number one source of death globally. They account for around 17 million deaths in the world each year (American Heart Association News, 2017). AHA mentions for African-Americans, high blood pressure usually develops early in life. The prevalence of high blood pressure (HBP or hypertension in African-Americans in the United States is amongst the largest in the world (American Heart Association, 2016). High blood pressure is equally preventable and treatable. Increasing public alertness is importantRead MorePublic Health Policy Evaluation And Treatment Of Overweight And Obesity1451 Words   |  6 Pages Public Health Policy Evaluation Benedictine University Susanna Johnson Clinical Guidelines on the Identification, Evaluation and Treatment of Overweight and Obesity in Adults. National Heart, Lung and blood Institute. 1998. Surgeon General’s Call to Action. Heart Disease, the number one cause of death in the United States, as well as Stoke (4th) and Diabetes the 7th leading cause of death all have a common denominator; Obesity (CDC). All of these statistics have continued toRead MoreThe Dietary Guidelines On The Consumption Of Saturated Fats1563 Words   |  7 PagesFor decades, the US Dietary Guidelines on the consumption of saturated fats has been suggesting that consumers should be mindful of how dangerous they are to the human body and take active steps to reduce these fats in their diets (American Heart Association). This advice is usually presented as the claim that increased cholesterol levels and their adverse health effect can be attributed to these â€Å"harmful† fatty substances. However, scientific research is forcing a change of perspective on how saturatedRead MoreTherapy Dogs Essay1022 Words   |  5 Pagesthat dogs can provide company, affection and support to people who are going through a difficult time or w ho feel lonely. Dogs have aided humans in tasks such as hunting, livestock herding, and guarding. However, as society moved from small rural communities to increasingly large metropolitan areas, the dog’s role changed. Throughout the years a more specific type of canine has helped improve the quality of human life in many ways. These animals are known as therapy dogs. Therapy dogs have been tremendouslyRead MoreAffordable Care Act ( Aca ) Shift American Health Care1090 Words   |  5 PagesAffordable Care Act (ACA) shift American health care system.The Institue of Medicine (IOM) report recommends the future of nursing are one of the important workforces leading the change. The Robert Wood Johnson Foundation (RWJF) sponsored the Initiative on the Future of Nursing (IFN) research in America (Robert Wood Johnson Foundation Initiative on the Future of... n.d.). In this essay, the student will discuss the IOM report on the IFN leading healthcare system reform. And Acknowledge the significanceRead MoreTransforming Nursing And Health Care1702 Words   |  7 Pagesdiscipline states: ?Nursing informatics science and practice integrates nursing,its information and knowledge and their manaement with information and communication technologies to promote the health of people,families and communities worldwide?(International Medical Informatics Association-Nursing Working Group,2010).Unfortunately,very few attempts were made to generate a broad theoretical framework for nursing informatics.There are several challenges to generate such framework.First,the interdisciplinaryRead MoreAmerican Nurses Association : The Protection, Promotion, And Optimization Of Health And Abilities, Prevention Of Illness907 Words   |  4 Pages According to American Nurses Association nursing can be defined as â€Å"the protection, promotion, and optimization of health and abilities, prevention of illness†. (American Nurses Association 2016) Nursing is a career where a person, should have compassion, a caring heart, and be devoted to their client care. Sometime person goes into the nursing field for the money, job stability, and because a person s family member wants them to go into the nursing field. I feel like the future of nursing haveRead MoreDifferent Definitions For Cultural Competency1660 Words   |  7 Pagescore values are entrenched in social work practice to ensure clients receive fair and competent service. As social workers, practicing in culturally sensitive ways is of the highest importance. The National Association of Social Work Standards for Cultural Competency include 10 standards to guide social work practice. These standards include (1). Ethics and Values (2). Self-Awareness (3). Cross-Cultural Knowledge (4). Cross-Cultural Skills (5). Service Delivery (6). Empowerment and Advocacy (7). DiverseRead MoreAPA procedures1465 Words   |  6 Pagespublished in 2005, would be cited like this in the text of the paper. If there is no author, use the first few words in the title of the source in quotes. If there is no publication date, use the initials n.d. Example: A Web page called â€Å"Student Guide to Using APA,† with no publication date would be cited like this in the text of the paper. If you are quoting directly from a source, you must include the page number the quote is found on. Example: A quote by John Smith, published in a book

The Harlem Renaissance By Zora Neale Hurston - 1896 Words

Personal Identity The Harlem Renaissance was a period from the end of World War I through the middle of the Great Depression, during which a group of talented African-American writers produced a body of poetry, fiction, drama, and essays. Zora Neale Hurston is considered to be one of the most influential contributors to the Harlem Renaissance period. Hourston grew up in this culturally affirming setting due to her father’s mentality, despite frequent confrontations with her preacher-father, she lived a happy childhood. Her father was said to crush her â€Å"wild† spirit and later influence her views on life. Her mother, on the other hand, urged Hurston and her siblings to jump at de sun. Hurston explained, We might not land on the sun, but†¦show more content†¦Finishing off with her relationship with Tea Cake (last marriage), as Janie experiences true fulfillment and enlightenment and becomes secure in her independence. All this falls under the theme of the Harlem Renaissance, a divided awareness of finding one s identity. Nanny’s hopes for Janie’s future was wrapped up by her own disturbing experiences. Nanny herself lived through slavery and had a child, Janie’s mother, by her white master. To follow, Nanny’s daughter was raped, gave birth to Janie, then became an alcoholic. As a result, Nanny had high hopes that Janie would marry and be a legitimate wife. This goal seems to be the most important thing for Nanny, and in her goal to get Janie married to a suitable man, due to her slave mentality. In, Their Eyes Were Watching God , Nanny is upset with Janie for kissing a young man who isn’t Nanny’s ideological view of a husband, stating to Janie she must get married to Logan Killicks, You come head wid yo’ mouf full uh foolishness on uh busy day. Heah you got uh prop tuh lean on all yo’ bawn days, and big protection, and everybody got tuh tip dey hat tuh you and callShow MoreRelatedThe Harlem Renaissance By Zora Neale Hurston1906 Words   |  8 Pagesthe truth. The Harlem Renaissance is real. It is identified as a spiritual re-awakening, a rebirth in culture, a sense of pride and self awareness. However, African Americans were not always allowed this prodigious freedom. Prior to the Harlem Renaissance African Americans were slaves; considered a piece of property who had no rights whatsoever. Despite, their harsh history, Civil Rights were enforced, this helped bring them out of their misery; which is why the harlem renaissance is such an importantRead MoreThe Harlem Renaissance By Zora Neale Hurston925 Words   |  4 PagesThe Harlem Renaissance was a cultural movement in the 1920s that led to the evolution of African-American culture, expression through art, music, and literary works, and the establishment of Afric an roots in America. Zora Neale Hurston contributed to the Harlem Renaissance with her original and enticing stories. However, Hurston’s works are notorious (specifically How it Feels to Be Colored Me and Their Eyes Were Watching God) because they illustrate the author’s view of black women and demonstrateRead MoreAnalysis Of The Harlem Renaissance By Zora Neale Hurston1751 Words   |  8 PagesAnalytical Essay During the Harlem Renaissance many African American were coming out of the shadow and started a cultural movement. They migrated to the north throughout 1915 to 1918. They moved up north for the urban industrial centers like Harlem, Chicago, St. Louis, and Detroit which was known as the great migration for the African American community was now getting noticed by the white man. This was a breakthrough for the African American they moved to find better jobs to carve out better livesRead MoreThe Harlem Renaissance Movement By Zora Neale Hurston1446 Words   |  6 PagesHistory.com (2009) describes the Harlem Renaissance movement as â€Å"a literary, artistic, and intellectual movement that kindled a new black cultural identity.† The 1920s and 1930s emcompass a time in history where blacks found themselves ostracized from mainstream society. It was uncommon to see the expressions of black artistry in everyday life, especially on a literary level. Zora Neale Hurston, a novelist, folklorist, and Ethnographical Anthropologist was born in 1891 in Notasulga, Alabama butRead MoreThe Harlem Renaissance Movement By Zora Neale Hurston, Langston Hughes, And Ralph Waldo Ellison931 Words   |  4 Pagesthe Harlem Renaissance Movement represented a period of artistic and intellectual change that initiated a new identity on black culture. Often called the â€Å"New Negro† Era, the Harlem Renaissance opened doors for African American to express themselves in the form of visual arts, musical elements, and even performing arts during the 1920s. Due to this movement, Harlem became the city that â€Å"gave African Americans a physical cultural center.† [1] Renowned black artists such as Zora Neale Hurston, LangstonRead MoreRole Of Zora Neale Hrston In The Harlem Renaissance1237 Words   |  5 Pages The Societal Role of Zora Neale Hurston during the Harlem Renaissance Jasmine Graham Nichole Craig HUM2020 (178011) TR 3:30-4:45 The Harlem Renaissance was a very historical time for the African American community as a whole. The Harlem Renaissance helped to pave the way for the civil rights movements that began around the early 1950s. During this time there was an influx of people who decided to relocate from the south to the north. The Harlem Renaissance also sparked a rise inRead MoreStory in Harlem Slang976 Words   |  4 Pagesâ€Å"Story in Harlem Slang† by Zora Neale Hurston is written entirely in Harlemese. It contains a three-page appendix, at the end of the story, with the translated slang she used to aid the reader. Harlemese is used to describe things taking place in Harlem and to create a sense that Harlem is its own place, almost a country inside of a country for Blacks. During this time many Blacks believed that living in the North was much better than living in the Jim Crow consumed south. The idea that Zora Neale HurstonRead MoreSummary Of Zora Neale Hurston 1210 Words   |  5 Pages9:00 Zora Neale Hurston Zora Neale Hurston was born on January 7, 1891 in Alabama. She is known to be one of the most influential novelist of the twentieth century in African America literature. Hurston is described to be a very opinionated woman that stood for what she believed in; which reflected in some of her works. In addition to her many titles such as, being an anthropologist and short story writer, she was closely related and heavily focused on the Harlem Renaissance. Zora Neale Hurston andRead MoreDust Tracks on a Road Essay1901 Words   |  8 PagesHonors American Literature January 9th, 2013 Zora Neale Hurston autobiography Dust Tracks on a Road, sketches her own life living in Eatonville, Florida, was the first organized self-government African American community. Many people saw the African American community as racism and segregation. Hurston implies that the nicest people she met in her early stages were whites who showed her compassion. According to her official website Zora Neale Hurston, â€Å"Dust Tracks on a Road, was her account of herRead MoreA New Beginning For African Americans Essay1291 Words   |  6 Pagesmovement became known as the Harlem Renaissance, which is also known as the â€Å"New Negro Movement†. With this movement, African Americans sought out to challenge the â€Å"Negro† stereotype that they had received from others while developing innovation and great cultural activity. The Harlem Renaissance became an artistic explosion in the creative arts. Thus, many African Americans turned to writing, art, music, and theatrics to expres s their selves. The Harlem Renaissance opened doors to the African American

Earthquakes in MEDC’s and LEDC’s Free Essays

A well-known principle states that the impact of earthquakes in LEDC’s or Less Economically Developed Countries is generally more severe when compared with MEDC’s or More Economically Developed Countries. This shall be illustrated by comparing the Kobe Earthquake in Japan of 1995 with the Kashmir Earthquake of 2005. The Kobe Earthquake occurred on Tuesday, January 17, 1995, at 05:46 JST in the southern part of Hyogo Prefecture, Japan. We will write a custom essay sample on Earthquakes in MEDC’s and LEDC’s or any similar topic only for you Order Now It measured 7.2 on the Richter scale and lasted for 20 seconds. The duration of the tremors was around 20 seconds long. The focus of the earthquake was located 16km below the epicentre, on the northern edge of the Awaji Island, approximately 20km from Kobe. The proximity to the city was a major factor of its widespread devastation. The ground moved 18cm horizontally and 12 cm vertically. The Kashmir Earthquake was caused by the Eurasian and Indian tectonic plate boundaries colliding. Its epicentre was located in Azad Kashmir near the city of Muzaffarabad. It occurred at 08:52:37 Pakistan Standard Time (03:52:37 UTC) on 8 October 2005. According to the authorities, 79000 people died. A major factor in the severity of the earthquake was the poor construction – a salient feature of LEDC’s. The Indian Plate which was moving 40 mm a year north collided with the Eurasian plate and was forced beneath it. It measured 7.6 on the Richter Scale. As is evident, although the magnitude of both earthquakes was extremely similar, the impacts varied greatly. This was due to many factors, which most if not all are related to the economic situation of the countries. We shall begin by discussing the impacts of each of the earthquakes, thereafter we shall discuss why these effects differed. Kashmir Earthquake Immediately, 1400 people were killed. Buildings were swaying and many collapsed due to the strength of the earthquake. Electricity supplies were cut off, people were trapped in buildings and roads were blocked due to landslides which hindered initial rescue attempts. Of the 8 million who were affected, 100,000 were injured. Several trains on minor lines were derailed while 3.3 million homes were destroyed. These are the crux of the primary effects. Many cars were destroyed, trains were suspended, roads were blocked and in many areas the only way to access was through the air. Due to the impact on the buildings, many small businesses were shut down leading to severe job losses. Pakistan lost a total of approximately $500,000,000, which led to the president of the time, Musharraf, to appeal for international aid including money, tents, medical aid and helicopters. This suffices in illustrating the economic devastation brought to the country through the earthquake. Major hospitals were destroyed, putting the injured in an extremely grave situation, the skyline was practically non-existent and perhaps the worst secondary effect was the phenomena of landslides which destroyed much of the infrastructure and endangered those on the streets. As mentioned earlier, there were a great number of injured, homeless and jobless people. This caused widespread depression, which is understandable when the extended family set-up of households is examined. All in all, more than 87,000 people died and 138,000 were injured. The city’s infrastructure was destroyed, clean water was extremely rare, hospitals were destroyed and many were homeless even after a year. This led to major secondary impacts such as outbreaks of diseases due to contaminated water supplies; people were affected with respiratory infections such as pneumonia; and the harsh winter season caused the homeless to suffer. Around 3.3 million people were living in temporary accommodation by the end of the happenings. When we compare the impacts of the Kashmir earthquake with the Kobe earthquake, we find that the primary effects are similar. These include the fact that buildings collapsed and the fact that many trains derailed. Numerous bridges and expressways collapsed and 120 of the 150 quays in the port of Kobe were destroyed as well as gas and electricity supplies being disrupted. Fires were set off due to destroyed gas pipes and electricity mains causing a further 7500 houses to burn. The roads were gridlocked causing delays in emergency services. 716 aftershocks were recorded and these lasted for several days. Industries such as Mitsubishi and Panasonic were forced to close. The death toll, however, was only 5500, injuries were 40,000 and 180,000 houses were destroyed. The newly opened Kansai Airport, due to its brilliant structural foundations, withstood the earthquake, as well as the Akashi Bridge. However, when we consider the fact that the population density of both areas was similar yet the number of dead, homeless and injured was far more in the Kashmir earthquake than that of the Kobe earthquake. By July, in about 5 months, most of the infrastructure such as water, electricity, gas and telephone services were up and running. Most buildings in commercial areas were repaired and the places affected by fires had been cleared. Rail services were back in service by August. A year later, 80% of the port was functional i.e. all but the Expressway. There was an increase in the technology used to determine information on earthquakes and movements in the region, and steps were implemented to make sure that devastation to that scale would not occur again. When the impacts of the 2 earthquakes are compared, it becomes clear that, although the population density of both areas were similar and the magnitude of both were similar, the death, injured and homeless figures are totally out of proportion, with Kashmir suffering a greater loss than Japan. This is also the case when the speed of recovery of the areas is considered, and it can be safely concluded that the infrastructure was more reliable in Kobe than in Kashmir. In addition, Japan’s economy was able to self-fund the aid whereas Musharraf was left begging the international community for aid. We shall examine each of these points in detail in the forthcoming paragraphs. Firstly, in order to understand where the problem lies, one must examine the details in chronological order. We find that the primary effects were extremely similar with buildings falling, electricity, gas and water supplies being disrupted, roads blocked etc. In some instances, we even find that Japan was hit worse such as the fact that the gas supplies were set alight causing fires. However, we see that each figure is out of proportion as this table illustrates: Japan Kashmir Dead 5500 87,350 Homeless 230,000 3.3 Million Injured 40,000 138,000 In my opinion, the vast amount of people who died in the Kashmir earthquake could have boiled down to a number of factors. Illiteracy and Ignorance of emergency procedure when an earthquake strikes could have posed as a major factor in the amount of people that died. This idea could be further strengthened when you consider that many people in LEDC’s do not possess modern education. This is insofar as a the personal scale goes. On a governmental scale, due to the other priorities of LEDC’s, little emphasis would be placed on these types of events due to their minute chance of occurring. The government may wish to focus on other matters. This idea could be strengthened when we are to couple this fact with the reality of the Pakistani government which, according to a 2007 report of Transparency International, Pakistan ranks 7th most corrupt country in the world. It is highly likely that money may have been filtered in the wrong places. When compared with Japan, we see that they immediately increased the number of seismic instruments to record earth movements in the region. This would reduce the likeliness of it occurring again which is possibly the most important thing to do for the government. In addition, the Japanese government decreed that buildings were to be built much more strongly and outlined a new set of guidelines for this to take place. This would place too much of a burden on the Pakistani government. Although these long-term causes should be rectified, other short-term causes should be identified. These include that, since Saturday was a normal school day, many school children were studying and as a result were buried under collapsed schools. It was also during the month of Ramadan, when people were taking a nap after their pre-dawn meal, hence they may not have had enough time to escape. Entire villages were simply wiped out like this. In conclusion, although it is expected that LEDC’s like Kashmir would be hit worse than MEDC’s such as Japan due to their economies, it is nevertheless possible to prevent such grave impacts that took place in Kashmir happening again. The people should be educated with emergency procedures, the government should invest in relevant technology which would indicate and warn them ahead of time when seismic activity was occurring. In addition, the government should outline new guidelines for buildings in which they are earthquake resistant just as Japan did. These would strain the economy in the short-term, although in the long term this would relieve the economy should an earthquake such as this one would take place again. How to cite Earthquakes in MEDC’s and LEDC’s, Papers

Accounting for Business Decisions Premium Branding

Question: Discuss about the Accounting for Business Decisions for Premium Branding. Answer: Introduction Tasfoods Limited is producer of premium brand with food of good quality and innovative products and provenance. TasFoods Limited was earlier known as ONCARD International Limited. Tasfoods Limited will be making food with high value. Primary growth and improvement of the product of the company will be on the products supplied in Tasmania. Tasfoods Limited is situated is a very good isolated place in terms of destinations. The company is mainly focusing on the hospitality, retail, lifestyle and financing sector (Mouritse and Kreiner 2016). The company is concentrating on producing dairy products and premium cream products. Tasfoods Limited has headquarter in Tasmania as well as an senior management team is connected to agricultural and food industries of Tasmania. The company will be making number of benefits in the brands. The company will be giving loyalty, rewards and solution to the payment of the country. The company will be operating on the business of meander valley diary. Jane lle OReilly was made company secretary as well as general counsel. Tasfoods Limited is going forward to take acquisition with the CFO. Tasfoods Limited made announcement of the audited financial statement of the company at the year end June 2016 (TasFoods Ltd 2016). The company is aiming in the making more expansion with diversifying is more and more product and services. Present head office of the company is in Launceston, Australia. Discussion: Analysis of the balance sheet of TasFoods limited: The forecasting of the financial position of the company is well predicted by using the balance sheet. Al the liabilities, assets and the equities of the entity are summarized in the balance sheet and this is done at the given point of time. One of the components financial statements of the entity is the balance sheet and the same is stated at the end of the reporting period (Chambers 2014). The nature of the business and the activities in which it is involved depends upon the set of line of the items. The equity accounts and the liabilities should always be equal to the total amount of assets. The equity account of the company comprised of the shareholders equity, retained earnings and various reserves. Assets are the items which are owned by the business and it is used to generate the profits and there are fixed and the current assets. On the other hand, liabilities are the amounts which the company is owing to other parties such as creditors, provisions and bank loans and is liabl e to pay (Talbot 2015). The financial strength of the company is evaluated suing the balance sheet and it is relevant to determine the financial position of the company. The trends of the business line and the future outcome can be analyzed using the balance sheet and the balance sheet of a particular entity is unique in itself. The solvency position and the productivity of the company can be determined using the balance sheet. The working capital of the company and the leverage capacity of the company can be easily determined by using the balance sheet. The reputation of the company and the efficacy of the management can also be evaluated using the balance sheet. The financial strength of the company can further be evaluated sing the various tools. Some of the fundamental information available to the company and required by the shareholders is provided by the balance sheet (Ujah and Brus 2014). The annual report for the year ended 21st July 2016 has been considered for the purpose of analysis. The value of the noncurrent assets of the Tasfood limited has increased in the current year. The percentage of the noncurrent assets increased in the year 2016 by 3946.543%. The value of noncurrent in the current year has increased and the reason attributable to the increment is that in the previous year, the company does not have any amount goodwill and the value for goodwill in 2016 stands at $ 1879400. The total current assets of the comprised of cash and cash equivalents, current assets and the financial assets, trade and other receivables. The total value of current assets decreased in the year 2016 by 92.119%. This is because in this year, the company does not have any financial assets and the other current assets have also been disposed off. The company does not have any assets and has not made any investments made in the financial assets. The total current liability of the com pany has witnessed decrease in the current year and the decreased percentage is 8.69%. The company does not have any long outstanding debt and has zero noncurrent liabilities. The company does not have any tax liability in the current year. The provisions for the expenses of the hotel are zero in the year 2016 and this has reduced the total current liabilities. The value of the total stock holder equity has also reduced in the year 2016 by 90.323%. The retained earnings of the company is negative in the current year that is it suffered accumulated loss in the current year as compared to the previous year and the amounts stands at $ 1651129. The company does not have any non controlling interest in the current year that is 2016 (Lee et al. 2013). Analysis of stockholders equity section: The accounts expressing the monetary interest of the ownership in to the business are included in the accounts containing the shareholders equity. The stockholders equity has the credit balances in the balance sheet and is located in the balance sheet immediately after the liability accounts. Such accounts stands in opposition to the assets account. One of the major components in the balance sheet of the company is the section of the stockholder equity. It is represented by the difference between the amounts of assets and liabilities. It is the amount of capital that is received from the investors of the company that is the stake in the stockholders equity that is held in the book of company by the investors (Crosson and Needles 2013). The amount of the stockholders equity represents the interest of the stockholders in the company. The stock holders equity comprised of the retained earnings and the paid up capital. Paid up capital is the amount of money that is raise form the sale of the stock through the investors. That is it contains the contribution of the owner of business after they have bought the shares and also includes the amount of capital which is invested by the company (Disatnik et al. 2014). The proportion of profits, retained and the distributed earning is reflected in the stockholders equity. The equity of the st ockholders earn dividend on the amount of shares they have purchased. If the company has been running for long time and has huge amount of retained earnings then it implies that the shareholders are not getting dividend as a part of the profit and the profit earned is reinvested in the business. This is indicative of the fact that the company profitability position is good and has net worth of high level. The components of the total stockholder equity include the contributed equity, retained earnings, reserves and the interest of parent entity. The value of the contributed equity has decreased by the amount $ 31897655. The value of reserves has increased in the current year and the retained earnings are negative that is the company has incurred loss that is accumulated. The company does not have any non controlling interest in the year 2016. The value of the total stock holder equity has also reduced in the year 2016 by 90.323%. The number of outstanding shares of the company has reduced in the current year by 82.874%. The company did not pay any dividend in the year 2014. The company paid a special dividend in the year 2015 and the dividend per share of the company was $0.09. The dividend paid was not franked. The total amount of dividend paid to the shareholders was $ 15711560 (Vogel 2014). Analysis of income statement: The first financial statements in the annual report of the reporting entities are the income statements of the company. The income statement of the entity depicts the revenue generated by the company and the expenses and the profit over a period of time. The information provided by the income statements to the investors of the company is basically about the revenue generation or whether the company is making money or not due to its operation. The other name for the income statements is the profit and loss statements, statements of operations or the earning statement of the company. The performance of the company is measured in terms of expense and the revenue as depicted in the income statement. The net income of the company is depicted in the income statements (Rob and Heyler 2016). The revenue is the income generated from the sale of the items of the company and the profitability of the company would be increased by increasing sales. The revenue needs to be continued in the year in and out so as to contribute to the profitability of the company. The expenses comprised of many parts such as selling and administrative expenses and the cost of goods sold. One of the direct factors which contribute to the revenue of the business is cost of goods sold (Edwards 2013). The income statements reveal to the management and the investors about its loss and profit in the particular period of time. There are various process involved in forming the income statements of the company. The single step approach sums up the total of all revenues and the all the expenses is deducted from the totaled revenue. Under the approach of multi step, there are several steps involved in the running and arriving of the net income of the company (Weil et al. 2013). The income statement of the Tasfoods comprised of the income generated from the continuing operations and other comprehensive income. The total income of the company in the year 2015 has increase by 126.154%. The percentage of the cost of goods sold has decreased by 30.37%. The total expenses of the company have also reduced in the current year by 16.23%. The company incurred operating loss in the previous year that is in the year of 2014 and in the current financial year, the company gained from its operations. In the prior year, the company did not earn on shares. However, the earning per share in the current year is $ 0.09. Analysis of the cash flow statements: The statement depicts the inflow and outflow of cash arising from the various activities of the business. The fundamental of the company is critically understood by the cash flow statements. The ability and the payment of the operational activities of the business is analyzed form the cash flow statements. The potential investors seeking the investment in the company judge the performance of the company using the statements of cash flow and whether it is able to generate the cash (Kaplan and Atkinson 2015). Operating, financing and the investing activities are the three sections of the cash flow statements from where the income is generated. The current operating expenses of the business and the changes accompanying the balance sheet of the company are recorded in the balance sheet. One of the analytical tools for evaluating the viability of the company regarding the short term payments such as amount of debt is provided by the cash flow statements. The paying capacity and the payrol l of the companies also depicted using the statement of cash flow (Horngren et al. 2014). The cash flow statement is prepared using the two methods that is the direct and indirect method. The direct method is easily understood and prepared. The indirect method is a universal method and it is made necessary to produce the supplement report as per FAS 95. The cash flow statements of the Tasfoods limited comprised of the cash flow generated from the financing, operating and investing activities. The components of the cash flow from operating activities include the receipt from customers, interest received, taxes paid and the payment made to the supplier and employees. The cash was used in the operating activities and the amount has increased in the recent year that is 2015-2016. The amount used in such activities increased by 55.216%. The investing activities comprised of loan made to the other entities and the various payments made for the purchase of the financial assets and the payment made for the intangibles assets purchase (Bazley et al. 2013). There are also proceeds from the financial assets disposal. The company invested cash in the business combination. The company settled a legitimate claim. The invested activities provided cash in the previous year but in the current year the cash of the business is used in the investing ac tivities. Therefore, the company has used the cash in the current year investing activities and the percentage is 100.701%. The amount used in the business $ 21906035. The financial activities of the company comprised of the issue of the shares and its associated costs and proceeds, paying dividend, and the payment made for buying back of the shares (Richard and David 2016). The cash used in the financing activities of the business has increased by 4044.396%. The net increase in usage of cash from the overall activities of the business has decreased by 262.221%. The amount of cash and cash equivalent at the end of the financial year is $ 2798864. Conclusion: The analysis of the financial report of the company has been done correctly. The very action of the company has been achieved and it is done by extracting the data and it is based on the annual reports of the company. The Tasfood limited is a growing market and possess the capacity to supply and grow the export and the domestic market. However, the company needs to be expanded and should develop the new product lines which are not currently supplied, though majority of the customers of Australia are served by the company. The company needs to reduce the loss resulting from the continuing operations. The company needs to reduce the accumulated losses resulted in the current year. The cash flow statement of the company is not in proper position as all the activities are making use of the companys cash. It needs to increase the net cash held at the end of the financial year. The evaluation of the company has been done suing the financial statements of the company. Recommendation: The company has its cash flow statement in a not suitable as the company has not been able to receive the income from the various activities. The company needs to make investment in the intangibles assets as it has increased the amount of noncurrent assets. The company needs to place in the funding arrangement and the tax sharing. The company should try to reduce the investment assets to be held as cash. The company needs to prepare the budgets and project the cash flow for the intangibles assets. Reference: Amiraslani, H., Iatridis, G.E. and Pope, P.F., 2013. Accounting for asset impairment.London: Cass Business School. Bazley, M., Hancock, P., Fisher, C., Lovell, A., Berk, J., DeMarzo, P., Berk, J. and DeMarzo, P., 2013.Financial Accounting: An Integrated. Thomson Pty Ltd, South Melbourne. Brinca, P., Chari, V.V., Kehoe, P.J. and McGrattan, E.R., 2016. Accounting for Business Cycles.Handbook of Macroeconomics. Bull, R.J., 2014.Accounting in business. Butterworth-Heinemann. Campbell, D., Datar, S.M., Kulp, S.L. and Narayanan, V.G., 2014. Cost Accounting: A Managerial Emphasis.Journal of Management Accounting Research,27, pp.39-65. Chambers, R.L. ed., 2014.An accounting thesaurus: 500 years of accounting. Elsevier. Crosson, S.V. and Needles, B.E., 2013.Managerial accounting. Cengage Learning. David, A. and Christopher, N., 2016. Financial Accounting-An International Introduction. Disatnik, D., Duchin, R. and Schmidt, B., 2014. Cash flow hedging and liquidity choices.Review of Finance,18(2), pp.715-748. DRURY, C.M., 2013.Management and cost accounting. Springer. Edwards, J.R., 2013.A History of Financial Accounting (RLE Accounting)(Vol. 29). Routledge. Harvey, D., McLaney, E. and Atrill, P., 2013.Accounting for business. Routledge. Horngren, C., Harrison, W., Oliver, S., Best, P., Fraser, D. and Tan, R., 2012.Financial Accounting. Pearson Higher Education AU. Kaplan, R.S. and Atkinson, A.A., 2015.Advanced management accounting. PHI Learning. Kieso, D.W., Weygandt, J.J., Kieso, D.E. and Kimmel, P.D., 2012.Study Guide to Accompany Financial Accounting, 8e. John Wiley Sons. Lee, T.A. and Parker, R.H., 2013.Towards a Theory and Practice of Cash Flow Accounting (RLE Accounting)(Vol. 50). Routledge. Mouritsen, J. and Kreiner, K., 2016. Accounting, decisions and promises.Accounting, Organizations and Society,49(C), pp.21-31. Narayanaswamy, R., 2014.Financial accounting: a managerial perspective. PHI Learning Pvt. Ltd.. Needles, B.E., Powers, M. and Crosson, S.V., 2013.Principles of accounting. Cengage Learning. Richard, L. and David, P., 2016. Advanced financial accounting. Rob, R. and Heyler, P.B., 2016. Managing Cash Flow. Talbot, J.L., 2015. Get to Know Cash Flow Analysis. TasFoods Ltd. (2016).Reports. [online] Available at: https://www.tasfoods.com.au/reports/ [Accessed 26 Sep. 2016]. Ujah, N.U. and Brusa, J., 2014. Earnings Management, Financial Leverage, and Cash Flow Volatility: An Analysis by Industry. Vogel, H.L., 2014.Entertainment industry economics: A guide for financial analysis. Cambridge University Press. Weil, R.L., Schipper, K. and Francis, J., 2013.Financial accounting: an introduction to concepts, methods and uses. Cengage Learning.

Weep Not Child Essay Example

Weep Not Child Paper As I read through the novel Weep Not Child, by Ngugi wa Thiongo, I realized that there was a clear message of hope. As we progress through the novel we get an impression of a gradual loss of hope. In this essay I will discuss the possible message of hope that the book leaves us with. My first impression as I read through the first chapter is Njoroges dreams and hopes through education, Education for him, as for many boys of his generation held the key to the future. Njoroge was offered to go to school by his mother. It is a real privilege for him, because he is the first one out of his family, who is able to go to school. He knew that by going to school, he could provide a better future for himself and his family. As we read on we see that education starts to decay, and as we reach the end of this novel, Njoroge has been forced out of school, and is forced o work at an Indian Shop, which it was really bad for him, because when he was younger he said he would never work for an Indian Shop. As it was consider to be shameful. We will write a custom essay sample on Weep Not Child specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Weep Not Child specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Weep Not Child specifically for you FOR ONLY $16.38 $13.9/page Hire Writer This demonstrates to the reader, that one of the main sources of hope has been destroyed. As we reach chapter 2, we get another sence of hope, the Prophecy. According to this prophecy, it tells us that a man will rise and give the land back, that once belonged to the black people. To the reader this seams improbible as it may not happen. And when you reach the end of the novel, you see this prophecy is very far from happening. Njoroge has very strong religious beliefs, we see this throughout the book, when he prays and asks God for help, with his problems. The rest of the African people are also religious in the way that they compare their situation with the situation of Moses and the Hebrew slaves. As we move on the novel, Njoroge starts to doubt his faith, when two military officers killed Isaaka his schoolteacher and preacher. This was the end of his education. He had lost his faith in god. Politics also gave Njoroge some hope. The strike made him along with many other black kids believe that they could gain independence. But as strike fails, Ngotho the father gets into constant conflicts with Jacobo, Father of Mwihaki. The fact that Jacobo is a traitor to the black people, gives me a feeling of hopelessness to any political solutions to the problem of freedom. Also Jomo a political leader who was fighting for black people independence, a man whom Njoroge compared with Moses, was also arrested. After we read this we get sense of despair. As they lose all their hope on independence. Most of Njoroges hopes and dreams have turned into despair. All he had was his family. But it gets slowly destroyed, Njoroges brother called Kamau has also been imprisoned for lifetime. His father Ngotho got into constant conflicts with his other Jacobo. He only had his 2 mothers which would support him, this could be said to be a glimpse of hope however I believe that the fact that Njoroge had to leave school and go to work to support the family, wipes out any possibility that this a message of hope. Ngotho would not come back. The death of Ngotho was of great shock to the whole family, and him being the piller of hope, on his death day, the hopes vanished and a feeling of despair grew.

TASTE OF SALT essays

TASTE OF SALT essays This story takes place in the slums of Haiti. In a hospital bed, lays Djo, beaten and hardly alive. Djo is an innocent victim of a political firebombing. The Macoutes, or the bad guys, pour gasoline in and on the camps of the followers of Aristide. They rob and slaughter the members of the camps. He is also a vital member of Father Jean Bertrand Aristides. Father Aristide, or as the local Haitians call him, Titid, sends Jeremie to Djo. She has a tape recorder with her. Jeremie is there to listen and to tape Djos story as from a little child to present date. Djo tells her of how he was raised in Cit Soleil, a very poor and large part of Port-au-Prince. Djo lived in a one room house witch was a stall for a motor car, or a garage. He lives with his mother, father, two sisters and two brothers, also his cousin Lally. All of the children sleep in one bed together and the mother and father have a bed of their own. His family is very poor, just like the rest of the citizens of Port-au-Prince. During the story, Djo finds Aristide. Aristide, or as Djo calls him, Titid, is the first democratically elected president of Haiti. He is a Salesian priest whose first and continuing ministry has been among the poor of Port-au-Prince. Father Aristide wants Haiti to become better. He wants people to live decent lives, with food everyday, and clean water to drink. People like Djo and Jeremie are the one who try to overthrow military dictatorship in Haiti. I think that Djo is a very determined man. He was poor all of life and didnt just feel bad for himself. He rised above it to actually do something about the terrible case of poverty in his country. Djo almost gave his life to overthrow the militia government. Everyone who heard his story, because it was amazingly full of courage loved him. Salt tastes rancid and bitter. So, Francis Temple relates the taste of salt with the lives of the Haitians. In other words, &q...

Marketing Property Case Study Example | Topics and Well Written Essays - 2500 words

Marketing Property - Case Study Example Thereby earning a commission calculated on an agreed percentage of the final sale price, usually around 6% to 10%. As an estate agent I've been dealing in the property market for the past six months. A few weeks ago, I had canvassed throughout the area I had been given allocated when I had joined the estate agency. I had a special advert flyer printed with all the details of our estate agency's functions, our methods and ethics involved in selling properties and informing the public to contact me as soon as they have a property they would like to sell, because our agency has a fast sale rate, we are efficient, well presentable, professional and our clients investment and future would sit securely in the palm of our hands. We will attain the maximum sale price for our sellers. We always keep ethical obligations towards our sellers, buyers and any other parties involved in the sale, to ensure they are content with the entire agreement and all its processes. I had been contacted by new sellers who were in need to sell their property rather urgently. They were relocating to Europe and amid beginning a new business venture they were in desperate need of their profits earned from the sale to fund a property they had already signed for on a sale clause stating they had to sell their property within one month, or else it will be passed onto another interested party. Marketing Property 3 Without delay, I collected all the necessary documentation I needed to gather all the listing details of their property. A package of documents comprising of: (i) Company Portfolio including all recent major sales performed by our estate agency and myself, the strong ethics our firm stand by, awards our firm have received in the past and any other new developments or mergers our firm may have in the near future and possible factors such as the economic stability, ever changing exchange rate and political situations that may affect the prospective clients property investment value. (ii) A Sole Mandate, so I would hopefully be able to secure my new clients to our firm in a binding contract that will stand strongly and securely so we can be the 'sole' estate agency firm to be able to sell their property and not accidentally landing in any commission disputes with other agencies over any miscommunications. That is why we always push for a sole mandate and if we don't receive one and we can only attain an open mandate, we always inform our clients of every investor we show the property to, to remove any possible miscommunications. (iii) A Comparitive Market Analysis is very important to present to my clients. I'll pack my camera and laptop, so I can access the internet whilst my clients and I are discussing their properties details such as the fixtures, movable items, immovable items, immovable items they wish to add into the sale agreement that they would like to take that item with them, any special servitudes, or outbuildings that may belong to their property and

Business Issues and the Contexts of HR Assignment

Business Issues and the Contexts of HR - Assignment Example The human resource manager also plays a great role in reconciling the owners or managers of the company and the workforce, when a crisis arises in the company the human resource manager, as he is closer to the people than the owners are works to bring the two parties jointly to come up with a resolution. The economic world has been faced with similar problems when it comes to human resource management. This is because human resource is dynamic and ranges from skilled to semi skilled to skilled labour. The growing competitive world has worked to put resource managers on their heels to seek professionalism and to make the competitive in the economic world. As competition increases the natural resources decreases, this brings us to the term survival for the fittest and only the fittest company will survive, many companies are investing heavily on skilled labour that has also gained its competition in the market (Human Value Management, Jac Fitz-Enz, 1990). Technological innovations have taken a centre stage in the dynamic economic world creating need to arm the workforce with the skills. In many companies workforce competent in the IT sector have an advantage over the others. Information communication technology has enabled companies to save on costs of production and has made it easier to market their goods and keep a good flow of information within and outside the company. With the growing inflations and the world, economic crisis it has become essential for companies to cut on their spending and the human resource department has not been saved the headache. Networking has become another key factor in the evolving world. Social sites such as Face book, twitter, what sup and Skype among others have played a major task in the marketing of the products. This means that some human resource personnel have to be able to cope with this to remain competitive. It has changed people’s ways of living and doing

Next Shop Assignment Example | Topics and Well Written Essays - 1750 words

Next Shop - Assignment Example Next takes a long term view while deciding for its actions and ensures that its suppliers adhere to the same level of commitment too (Next Corporate Responsibility Report, p.3). It would be worthwhile to understand the operations of next before we delve into how the company trains and develops its employees to adapt to the market challenges. Understanding Next's Business Currently, companies are required to operate in the most challenging environment as they need to address complex set of issues for their business, for their customers, the environment in which they operate and the suppliers that they depend upon. Next fully realizes that these aspects cannot be tackled without taking into consideration its people on the job. With average 278,000 transactions done in a day, ‘Next’ claims to have 3 million active customers with them. With turnover of ?3,441million in the year ended January 2012, Next’s operation are spread in 7 countries with 26 its own stores and 1 64 overseas franchise stores in 27 countries operating in Asia, Africa and Europe continents. To cater to the customers efficiently and in time, ‘Next’ has established warehousing and distribution division. Next depends upon its suppliers to cater to the needs of its customers; at the same time, employees form a most crucial and strong link to service its valuable customers (Next Corporate Responsibility Report, p. 5-6). Next’s special emphasis on training and development of its employees should be seen in this perspective. Approach towards its People ‘Next’ believes in attracting and retaining the right people across all levels considering them a most valuable asset for the growth of the company. The company is committed to provide a healthy environment to its employees so that they can thrive in their personal and professional development. Moreover, the company works towards providing an environment where all employees are treated fairly, supported , respected and motivated so that they could reach to their full potential. The company has developed certain policies for training and the development of the employees. The company upholds basic human rights and follows International Labour Organisation (ILO) core conventions. Employees are imparted basic training so that they understand these principles. The company is well aware that committed employees can help grow the organization by delivering excellent services to the customers (Next Corporate Responsibility Report, p.16). Code of Practice Next lists key principles that speak about its employment policies. They are: Healthy and safe working conditions; reasonable working hours; equal opportunities; proper wages and benefits; no forced labour; employment security; no child labour; proper treatment to employees; and freedom of association to employees. Next applies above principles in each of the countries that it operates in and also insists on its suppliers that they also ad here to these norms (Next Corporate Responsibility Report, p.7). Safe Working Conditions Next gives top priority to the Health and safety of its employees. Next has taken necessary measures to protect their employees from high risk areas such as ‘falls from height’, construction and maintenance activities, vehicle movements, fire and many more. Next makes it very clear in its contracts with

Parliamentary Sovereignty in the UK in the Wake of Brexit

Parliamentary Sovereignty in the UK in the Wake of Brexit POn 23 June 2016, the UK government held a referendum to decide whether the country should leave the EU. The majority citizens voted for Brexit (51.89 per cent to 48.11 per cent) with a turnout of 72%, however, they thoroughly fell behind in Scottish and Northern Irish tallies. Be that as it may, the Government was still expected to trigger Article 50 of the Treaty on European Union (TEU) as soon as possible, without the express permission from Parliament. The Prime Minister at the time, David Cameron, had promised that he would follow through with the outcome, even if that meant leaving the EU (BBC, 2017).[1] However, the situation was not as straightforward as presented by the â€Å"Leave† campaign. The principle of parliamentary sovereignty meant that the referendum result had no legal binding. Therefore, the Prime Minister and government were free to ignore the referendum result if they saw fit. Furthermore, some argued that the government had no right to trigger a leave; only Parliament could do so, as a result of the principle parliamentary sovereignty (Weale, 2017).[2] This paper discusses the topic of parliamentary sovereignty in the UK, particularly in the wake of Brexit, and briefly touches on some social consequences had Parliamentary Sovereignty not been respected. The structure of this paper is therefore as follows: First, Section 1 briefly discusses the history behind parliamentary sovereignty in the UK. Then, Section 2 discusses the Miller Case, a case where the High Court upheld parliamentary sovereignty in the wake of Brexit. Finally, Section 3 explores the European Union (Notification of Withdrawal) Act 2017, an Act of Parliament that grants the government power to leave the EU. 1. The Principle of Parliamentary Sovereignty The idea of parliamentary sovereignty was conceived circa the Case of Proclamations in 1608 (Barnett, 2017).[3] This was a court decision that reduced the power of Monarchs. Essentially, the courts decided that moving forward, Kings and Queens would have to obtain Parliament’s permission to change laws. Specifically, the Case of Proclamations stated that â€Å"the King cannot change any part of the common law [†¦.] without parliament† (House of Lords, 1610).[4] Following this, the English Civil War occurred 1642–1651, where Parliamentarians fought against Royalists for ideals such as parliamentary sovereignty. The Parliamentarians were victorious on such occasion and thus began the ‘Glorious Revolution’ in 1688, which established parliamentary sovereignty in England (Goldsworthy, 2010).[5] Then, in 1689, parliamentary sovereignty was enshrined in the Bill of Rights. Similarly to the Case of Proclamations, this bill requires Monarchs to obtain pe rmission from Parliament before changing laws. Specifically, the Bill of Rights said, â€Å"Suspending the laws or the execution of laws by regal authority without consent of Parliament is illegal† (Parliament of England, 1689).[6] In modern day Britain, Parliament consists of three main decision making bodies: the Sovereign (the monarch, i.e. the King or Queen), the House of Lords (i.e. unelected members of parliament), and the House of Commons (i.e. elected Members of Parliament, or MPs). These three bodies form the highest power in the UK. The fact that Parliament has supreme power is known as parliamentary sovereignty. In the words of Legal commentator Albert Dicey, parliamentary sovereignty gives Parliament the power â€Å"to make or unmake any law whatever† (Dicey, 1915, p.3).[7] The only limits to parliamentary sovereignty are those that Parliament sets itself (Bradley, 2011).[8] An example of this self-enforced limit is Parliament’s subordination of the UK to the EU. This came into effect in 1972, when Parliament signed the European Communities Act, under which the UK was compelled to follow EU law (Barber, 2011).[9] Parliament also has the power to lift its self-imposed limits. For exampl e, Brexit means that Parliament will repeal the European Communities Act, thus ending the EU’s control over the UK (Supreme Court, 2017).[10] It is also important to note that only Parliament can repeal Parliamentary acts. Essentially, the government and Queen cannot repeal Acts of Parliament without Parliament’s permission. 23. Parliamentary sovereignty has been a significant part of many cases and has repeatedly been called upon during cases of importance. A quote from Lord Bingham of Cornhill in R (Jackson) v Attorney General [2005] UKHL 56; [2006] 1 AC 262 at para. [9] encapsulates this significance perfectly: The bedrock of the British constitution is the supremacy of the Crown in Parliament. 2. The Miller Case Following the Brexit referendum in June 2016, Times journalist David Pannick noted that the government could not trigger Article 50 by itself; the government would have to first obtain permission from Parliament (Pannick, 2016).[11] This was because of the principle of parliamentary sovereignty. Specifically, Pannick noted that Parliament had agreed to the European Communities Act in 1972, and because only Parliament can reverse its own decisions, and therefore only Parliament can repeal the act and withdraw from the EU. He also drew attention to Article 50 of the Treaty on European Union, which says, â€Å"any member state may decide to withdraw from the union in accordance with its own constitutional requirements† (EU, 2007).[12] Pannick argued that since parliamentary sovereignty is a constitutional requirement, the EU would not accept the UK’s withdrawal without parliamentary approval (Pannick, 2016).[13] Theresa May was dismissive of these claims. She asserted that they were a tactic to delay Brexit and subvert democracy (BBC, 2017).[14] She also stated that the government did not need parliamentary approval to trigger Article 50 (Freehills, 2016).[15] Notably, Theresa May stated, â€Å"It is up to the Government to trigger Article 50 and the Government alone† (BBC, 2017).[16] Many disagreed with Theresa May, as they believed that withdrawal from the EU without Parliament’s permission would be unlawful (Weale, 2017).[17] Several members of the public felt so strongly about this that took legal action against the government. Miller v Secretary of State for Exiting the European Union, or the Miller case as it was known informally, was heard in the High Court of Justice. Miller argued that Parliamentary involvement was necessary because: â€Å"By enacting the 1972 Act, Parliament surrendered aspects of its legislative sovereignty and conferred the same upon (what are now) the EU Institutions. Such conferral cannot be undone [†¦] without Parliamentary consent.† (Supreme Court, 2016, p.21)[18] In plain English, Miller’s argument was that considering Parliament surrendered power to the EU in 1972, only Parliament could take this power back (Supreme Court, 2016).[19] The government disagreed with this claim. They believed that once the UK leaves the EU, the European Communities Act 1972 would simply cease to apply, because former treaties would not exist (Supreme Court, 2016; Weale, 2017).[20] Furthermore, the government argued that they had the royal prerogative to override parliamentary sovereignty. The royal prerogative is an old power that allows governments to make decisions without Parliament, in exceptional circumstances (Freehills, 2016).[21] The government also noted a rule that â€Å"the making and unmaking of treaties is [†¦] within the competence of the government† (Supreme Court, 2017, p.84)[22] The case was debated in the High Court for several weeks until the High Court delivered its verdict on 3 November 2016. The High Court ruled in favour of Miller: the government had to obtain parliamentary authority to trigger Article 50. The High Court had agreed with Miller’s arguments about the principle of parliamentary sovereignty (Supreme Court, 2017).[23] The court explained that because of parliamentary sovereignty, only Parliament could repeal the European Communities Act. This is because only Parliament can repeal an Act of Parliament. The High Court also explained that Article 50 would nullify several rights of UK citizens (Supreme Court, 2017).[24] These rights included the right of UK citizens to live and work freely in other EU countries, and the right to 20 days paid holiday under the Working Time Directive 2003. Parliament put these rights in place when it passed the European Communities Act in 1972. The High Court also ruled against the government’s right to use the royal prerogative (Supreme Court, 2017).[25] To explain why, the High Court cited the case of Burmah Oil Co (Burma Trading) Ltd v Lord Advocate [1965] AC 75, 101. This case involved use of the royal prerogative. Lord Reid, dismissed the royal prerogative as a â€Å"relic of a past age† (House of Lords, 1965, p.101).[26] Lord Reid also explained that the royal prerogative is â€Å"only available for a case not covered by statute† (p.101).[27] Typically, the royal prerogative is only for situations such as declaring war, dissolving parliament and governing colonies (Wade, 1961).[28] So, in Miller’s case, the High Court explained that a royal prerogative was inappropriate for triggering Brexit. Therefore, the government did not have the power to trigger Article 50 without Parliament’s approval. The government was unhappy with the High Court’s decision and chose to appeal it, and as a result the case went to the Supreme Court. Ultimately, the Supreme Court dismissed the government’s appeal, citing the same reason as the High Court (Supreme Court, 2017).[29] Essentially, the court explained, the government in 1972 needed Parliament’s approval to sign the 1972 Accession Treaty. This meant that present-day government also needed Parliament’s approval to repeal this treaty (Supreme Court, 2017).[30] Of course, those in the â€Å"Leave† camp were outraged with the High Court’s decision. Like Theresa May, they believed that Parliament was attempting to obstruct the progression of Brexit. A Ukip donor accused the High Court of declaring war on British democracy (Maguire, 2016).[31] In reality, however, this was not the case; the High Court was merely upholding the British constitution as intended, by honouring the principle of parliamentary sovereignty (Weale, 2017)[32] and following the Rule of Law. Importance of the Rule of Law. On 29 March 2017, the Prime Minister wrote to the President of the European Council to notify the European Council of the United Kingdom’s intention to leave the European Unit and the triggering of Article 50 of the Treaty. Brexit is no longer a hypothetical question. It is a concrete fact – it is happening. An issue that has been brought to the front is the belief that the Government has the power, and right, to act on Brexit without Parliaments involvement. This is even more troubling as the very constitution is built upon Parliamentary sovereignty. The issue of human rights comes up as it can be dangerous, in a country where the legislature is mostly under the control of the executive, to leave it solely up to a sovereign Parliament with an absent constitution. If the Parliament can be avoided altogether, this can lead to an even worse situation overall and so highlights how important it was for the Supreme Court in Miller to stand up for and defend the power of Parliament over the executive.   Brexit is one of the most influential and far-reaching changes to the international social and political landscapes today. Brexit will shape Britain, and the international community, for years to come. It is for this reason that it is undeniable that this process should be founded in the rule of law. To comprehend the importance of the rule of law we must give it a clear definition. A well-known definition is that of Lord Bingham: â€Å"that all persons and authorities in the State, whether public or private, should be bound by and be entitled to the benefit of all laws publicly made, taking effect (generally) in the future and publicly administered in the courts.† The Venice Commission has identified the following 8 components of the rule of law: ‘(1) Accessibility of the law (that it be intelligible, clear and predictable); (2) Questions of legal right should be normally decided by law and not discretion; (3) Equality before the law; (4) Power must be exercised lawfully, fairly and reasonably; (5) Human rights must be protected; (6) Means must be provided to resolve disputes without undue cost or delay; (7) Trials must be fair, and (8) Compliance by the state with its obligations in international law as well as in national law.’ The importance of the rule of law is recognised in multiple international documents. For example, the preamble to the UN Declaration of Human Rights notes the importance of the rule of law in protecting human rights. The Treaty on European Union also couples ‘the rule of law and respect for human rights’. It is this human rights element that the remained of this short essay will focus on. Brexit will reform the social landscape of Britain and Europe. It is of paramount importance that the rule of law is respected in this reformation to ensure that fundamental rights, particularly those of minorities and vulnerable individuals, continue to be respected. This is especially true given that there has been much debate as to whether the Brexit vote was fuelled by xenophobia and racism. Research has shown that there was an increase in support for far-right groups during the Brexit campaign and following the murder of Jo Cox. There has also been an alleged escalation in hate crime targeting migrant communities as well an increase in anti-immigration rhetoric. The Brexit vote, coupled with Trump, and the rise of the far-right, summons fears surrounding the polarization of politics and the creeping rise of extremism. With this in mind, it is quite chilling to consider Lord Bingham’s thoughts on a system which is not founded on the rule of law: â€Å"The hallmark of a regime which flouts the rule of law are, alas, all too familiar: the midnight knock on the door, the sudden disappearance, the show trial, the subjection of prisoners to genetic experiments, the confession extracted by torture, the gulag and the concentration camp, the gas chamber, the practice of genocide and ethnic cleansing, the waging of aggressive wars.† In a time when international politics is becoming increasingly unclear and strained and communities are fraught with increased fear and racial tensions, now more than ever, the rule of law and the importance of Parliamentary Sovereignty must be respected. As noted by the Prime Minister, the task before the British nation is momentous but it should not be insurmountable. Britain post-Brexit has an unclear future and an undefined path. By adhering to the rule of law, the certainty, stability and protection that it provides will ensure that this difficult task is negotiated with the utmost respect for all peoples and their inalienable human rights. 3. The European Union (Notification of Withdrawal) Act 2017 Given that the Supreme Court had dismissed the government’s appeal, the government now needed Parliament’s approval to trigger Article 50. In order to receive this approval, the government introduced a new bill in Parliament. This bill was called the European Union (Notification of Withdrawal) Act 2017.Essentially, this bill would give Theresa May the power to trigger Article 50. However, Parliament had the power to reject the bill if it felt appropriate. This was again because of parliamentary sovereignty (Weale, 2017).[33] Despite that most voters voted ‘Leave’ in the referendum, this result was not legally binding and Parliament could ignore the referendum result. The principle of parliamentary sovereignty means that the ultimate power rests with Parliament, not the public nor the results of referendums. The public only have the power to elect MPs, and once elected, MPs can go against the wishes of their constituents and make their own decisions if they want to. MPs can even go against a referendum result, despite that this might cause great anger with the British public. As Dicey stated, â€Å"the electors can in the long run always enforce their will† (Dicey, 1915).[34] However,   all three decision making bodies of Parliament – the Queen, the House of Lords and the House of Commons – approved the Notification of Withdrawal Act (BBC, 2017).[35] The Queen gave the final green flag on 16 March 2017. This gave the Prime Minister the power trigger to Article 50 and inform the EU of the UK’s withdrawal. The government officially triggered Article 50 on 29 March 2017, when a UK envoy delivered a letter of withdrawal to the President of the European Council (BBC, 2017).[36] The issue of parliamentary sovereignty then took a back seat as the UK began exit negotiations with the EU. Of the 170,000 statutory instruments that have been sent to Parliament in the last 65 years, only seventeen have been rejected, and any substantive debate over individual instruments is a rare occurrence. Responsibility has been delegated for regulation both to the government and the European Union. For this reason, possibly up to sixty per cent of UK law may be derived from EU law in some way. Furthermore, for many years, legislative and technical expertise in the pertinent areas have again been delegated to Brussels. This leaves domestic civil servants under prepared to handle the of important decisions that will need to be made in the coming years. David Allen Green’s analysis is difficult to refute: â€Å"under the cloak of the referendum result there will be a power grab by Whitehall from Westminster. Those rejoicing at â€Å"taking back control† should be careful what they wish for. The executive is, as usual, wanting to take control away from Parliament.† On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. Does this mean that the claims of direct democracy, in the form of the referendum, trump the claims of Parliamentary representative democracy, with the paradoxical effect of giving more power to the executive? The greater part have affirmed that referenda are in and of themselves a product of Parliamentary authority and must accordingly rely on the statute which enables them. The 2015 EU referendum Act only called for the referendum to take place, without establishing how to approach it or the potential consequences. ‘Where, as in this case, implementation of a referendum result requires a change in the law of the land, and statute has not provided for that change, the change in the law must be made in the only way in which the UK constitution permits, namely through Parliamentary legislation.’ The actual political importance of a referendum is not subverted however. What is does assert is the basic dogma that, in a democracy, the people can speak through their representatives in Parliament. Nevertheless, direct democracy cannot be operationalised by giving undiluted power to the executive. 4. Conclusion This paper has discussed parliamentary sovereignty in the UK in the wake of Brexit. First, Section 1 introduced the concept of parliamentary sovereignty in the UK. This section explained that parliamentary sovereignty goes back to the 17th century, when the courts first enshrined the principle in the Bill of Rights. The section also drew attention to the rule that only Parliament can undo Acts of Parliament. I then discussed the Miller case in Section 2. In this case, members of the public argued that the government required Parliaments approval to leave the EU. The courts decided in favour of Millers side; that explained that Parliament was needed to trigger to Article 50 due to parliamentary sovereignty. The decision was controversial because some people saw it as an attempt to subvert the referendum result. Finally, Section 3 discussed the European Union Act 2017. This act that demonstrated the principle of parliamentary sovereignty. The government essentially asked Parliament for permission to trigger Article 50, and Parliament agreed by passing the act. In conclusion, the principle of parliamentary sovereignty was tested in the wake of Brexit. Ultimately however, courts respected the principle and gave Parliament the ultimate power over whether Britain should leave the EU. However, the future is still uncertain, as no-one yet knows what Brexit will look like. Perhaps a future Parliament will reverse the Brexit decision. After all, parliamentary sovereignty gives future Parliaments the right to reverse the decisions of previous Parliaments. What needs to be addressed is the potential consequneces that the referendum may have on Palimentary sovernety and represesentitive democracy throughout the UK. For this reason, Parliment needs to continue to be a central part of the process despite any predetermined preferences from the Government itself. Parliamentary sovereignty must remain intact as, for the many reasons stated, it is an integral part of the United Kingdom’s constitution, because its deliberate and representative functions and ability to hold the executive to account are defining features of the United Kingdom’s enduring constitution. 5. References Barber, N.W., 2011. The afterlife of Parliamentary sovereignty. International Journal of Constitutional Law, 9(1), pp.144–154. Barnett, H., 2017. Constitutional and administrative law, Taylor & Francis. BBC, 2017. BBC News website. Available at: http://www.bbc.com/news [Accessed July 14, 2017]. Bradley, A., 2011. The Sovereignty of Parliament–Form or Substance? The Changing Constitution, 23, pp.54–56. Dicey, A.V., 1915. Introduction to the Study of the Law of the Constitution 8th ed., Liberty Classics. EU, 2007. Treaty on European Union, Freehills, H.S., 2016. Judicial review litigation over the correct constitutional process for triggering Article 50 TEU. Lexology. Available at: http://www.lexology.com/library/detail.aspx?g=f43e102f-ea09-4449-b781-a35ecfe628fe [Accessed July 13, 2017]. Goldsworthy, J., 2010. Parliamentary sovereignty: contemporary debates, Cambridge University Press. House of Lords, 1965. Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75, House of Lords, 1610. Proclamations, Case of [1610] EWHC KB J22, Available at: http://www.bailii.org/ew/cases/EWHC/KB/1610/J22.html. Maguire, P., 2016. Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling. The Guardian. Available at: https://www.theguardian.com/politics/2016/nov/06/brexit-this-is-what-sovereignty-looks-like#img-1 [Accessed July 13, 2017]. Pannick, D., 2016. Why giving notice of withdrawal from the EU requires act of parliament. The Times. Available at: https://www.thetimes.co.uk/article/c8985886-3df9-11e6-a28b-4ed6c4bdada3. Parliament of England, 1689. English Bill of Rights, Supreme Court, 2016. Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†), Available at: http://www.croftsolicitors.com/wp-content/uploads/2016/11/139459-UKSC-2016-0196-Skeleton-for-Expat-Interveners-final-written-case-2.pdf. Supreme Court, 2017. Miller v Secretary of State for Exiting the European Union, London. Available at: https://www.supremecourt.uk/cases/docs/uksc-2016-0196-judgment.pdf. Wade, W., 1961. Administrative Law, London: Oxford University Press. Weale, A., 2017. The Democratic Duty to Oppose Brexit. The Political Quarterly, 88(2), pp.170–181. [1] BBC [2] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 177 [3] Hilaire Barnett, Constitutional and administrative law (Taylor & Francis 2017) [4] House of Lords, Case of [1610] EWHC KB J22 [5] Jeffrey Goldsworthy, Parliamentary sovereignty: contemporary debates (Cambridge University Press 2010) [6] Parliament of England, English Bill of Rights [7] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [8] Anthony Bradley, ‘The Sovereignty of Parliament–Form or Substance?’ (2011) The Changing Constitution 54 [9] Nicholas Barber, ‘The afterlife of Parliamentary sovereignty’ (2011) International Journal of Constitutional Law 149 [10] Supreme Court, Miller v Secretary of State for Exiting the European Union [11] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [12] EU, Treaty on European Union [13] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [14] BBC [15] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [16] BBC [17] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [18] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) 21 [19] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) [20] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [21] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [22] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [23] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [24] Supreme Court, Miller v Secretary of State for Exiting the European Union 84 [25] Supreme Court, Miller v Secretary of State for Exiting the European Union 85 [26] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [27] House of Lords, Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75 101 [28] William Wade, Administrative Law (Oxford University Press 1961) [29] Supreme Court, Miller v Secretary of State for Exiting the European Union [30] Supreme Court, Miller v Secretary of State for Exiting the European Union [31] Patrick Maguire, Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling [32] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [33] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 174 [34] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [35] BBC [36] BBC Parliamentary Sovereignty in the UK in the Wake of Brexit Parliamentary Sovereignty in the UK in the Wake of Brexit POn 23 June 2016, the UK government held a referendum to decide whether the country should leave the EU. The majority citizens voted for Brexit (51.89 per cent to 48.11 per cent) with a turnout of 72%, however, they thoroughly fell behind in Scottish and Northern Irish tallies. Be that as it may, the Government was still expected to trigger Article 50 of the Treaty on European Union (TEU) as soon as possible, without the express permission from Parliament. The Prime Minister at the time, David Cameron, had promised that he would follow through with the outcome, even if that meant leaving the EU (BBC, 2017).[1] However, the situation was not as straightforward as presented by the â€Å"Leave† campaign. The principle of parliamentary sovereignty meant that the referendum result had no legal binding. Therefore, the Prime Minister and government were free to ignore the referendum result if they saw fit. Furthermore, some argued that the government had no right to trigger a leave; only Parliament could do so, as a result of the principle parliamentary sovereignty (Weale, 2017).[2] This paper discusses the topic of parliamentary sovereignty in the UK, particularly in the wake of Brexit, and briefly touches on some social consequences had Parliamentary Sovereignty not been respected. The structure of this paper is therefore as follows: First, Section 1 briefly discusses the history behind parliamentary sovereignty in the UK. Then, Section 2 discusses the Miller Case, a case where the High Court upheld parliamentary sovereignty in the wake of Brexit. Finally, Section 3 explores the European Union (Notification of Withdrawal) Act 2017, an Act of Parliament that grants the government power to leave the EU. 1. The Principle of Parliamentary Sovereignty The idea of parliamentary sovereignty was conceived circa the Case of Proclamations in 1608 (Barnett, 2017).[3] This was a court decision that reduced the power of Monarchs. Essentially, the courts decided that moving forward, Kings and Queens would have to obtain Parliament’s permission to change laws. Specifically, the Case of Proclamations stated that â€Å"the King cannot change any part of the common law [†¦.] without parliament† (House of Lords, 1610).[4] Following this, the English Civil War occurred 1642–1651, where Parliamentarians fought against Royalists for ideals such as parliamentary sovereignty. The Parliamentarians were victorious on such occasion and thus began the ‘Glorious Revolution’ in 1688, which established parliamentary sovereignty in England (Goldsworthy, 2010).[5] Then, in 1689, parliamentary sovereignty was enshrined in the Bill of Rights. Similarly to the Case of Proclamations, this bill requires Monarchs to obtain pe rmission from Parliament before changing laws. Specifically, the Bill of Rights said, â€Å"Suspending the laws or the execution of laws by regal authority without consent of Parliament is illegal† (Parliament of England, 1689).[6] In modern day Britain, Parliament consists of three main decision making bodies: the Sovereign (the monarch, i.e. the King or Queen), the House of Lords (i.e. unelected members of parliament), and the House of Commons (i.e. elected Members of Parliament, or MPs). These three bodies form the highest power in the UK. The fact that Parliament has supreme power is known as parliamentary sovereignty. In the words of Legal commentator Albert Dicey, parliamentary sovereignty gives Parliament the power â€Å"to make or unmake any law whatever† (Dicey, 1915, p.3).[7] The only limits to parliamentary sovereignty are those that Parliament sets itself (Bradley, 2011).[8] An example of this self-enforced limit is Parliament’s subordination of the UK to the EU. This came into effect in 1972, when Parliament signed the European Communities Act, under which the UK was compelled to follow EU law (Barber, 2011).[9] Parliament also has the power to lift its self-imposed limits. For exampl e, Brexit means that Parliament will repeal the European Communities Act, thus ending the EU’s control over the UK (Supreme Court, 2017).[10] It is also important to note that only Parliament can repeal Parliamentary acts. Essentially, the government and Queen cannot repeal Acts of Parliament without Parliament’s permission. 23. Parliamentary sovereignty has been a significant part of many cases and has repeatedly been called upon during cases of importance. A quote from Lord Bingham of Cornhill in R (Jackson) v Attorney General [2005] UKHL 56; [2006] 1 AC 262 at para. [9] encapsulates this significance perfectly: The bedrock of the British constitution is the supremacy of the Crown in Parliament. 2. The Miller Case Following the Brexit referendum in June 2016, Times journalist David Pannick noted that the government could not trigger Article 50 by itself; the government would have to first obtain permission from Parliament (Pannick, 2016).[11] This was because of the principle of parliamentary sovereignty. Specifically, Pannick noted that Parliament had agreed to the European Communities Act in 1972, and because only Parliament can reverse its own decisions, and therefore only Parliament can repeal the act and withdraw from the EU. He also drew attention to Article 50 of the Treaty on European Union, which says, â€Å"any member state may decide to withdraw from the union in accordance with its own constitutional requirements† (EU, 2007).[12] Pannick argued that since parliamentary sovereignty is a constitutional requirement, the EU would not accept the UK’s withdrawal without parliamentary approval (Pannick, 2016).[13] Theresa May was dismissive of these claims. She asserted that they were a tactic to delay Brexit and subvert democracy (BBC, 2017).[14] She also stated that the government did not need parliamentary approval to trigger Article 50 (Freehills, 2016).[15] Notably, Theresa May stated, â€Å"It is up to the Government to trigger Article 50 and the Government alone† (BBC, 2017).[16] Many disagreed with Theresa May, as they believed that withdrawal from the EU without Parliament’s permission would be unlawful (Weale, 2017).[17] Several members of the public felt so strongly about this that took legal action against the government. Miller v Secretary of State for Exiting the European Union, or the Miller case as it was known informally, was heard in the High Court of Justice. Miller argued that Parliamentary involvement was necessary because: â€Å"By enacting the 1972 Act, Parliament surrendered aspects of its legislative sovereignty and conferred the same upon (what are now) the EU Institutions. Such conferral cannot be undone [†¦] without Parliamentary consent.† (Supreme Court, 2016, p.21)[18] In plain English, Miller’s argument was that considering Parliament surrendered power to the EU in 1972, only Parliament could take this power back (Supreme Court, 2016).[19] The government disagreed with this claim. They believed that once the UK leaves the EU, the European Communities Act 1972 would simply cease to apply, because former treaties would not exist (Supreme Court, 2016; Weale, 2017).[20] Furthermore, the government argued that they had the royal prerogative to override parliamentary sovereignty. The royal prerogative is an old power that allows governments to make decisions without Parliament, in exceptional circumstances (Freehills, 2016).[21] The government also noted a rule that â€Å"the making and unmaking of treaties is [†¦] within the competence of the government† (Supreme Court, 2017, p.84)[22] The case was debated in the High Court for several weeks until the High Court delivered its verdict on 3 November 2016. The High Court ruled in favour of Miller: the government had to obtain parliamentary authority to trigger Article 50. The High Court had agreed with Miller’s arguments about the principle of parliamentary sovereignty (Supreme Court, 2017).[23] The court explained that because of parliamentary sovereignty, only Parliament could repeal the European Communities Act. This is because only Parliament can repeal an Act of Parliament. The High Court also explained that Article 50 would nullify several rights of UK citizens (Supreme Court, 2017).[24] These rights included the right of UK citizens to live and work freely in other EU countries, and the right to 20 days paid holiday under the Working Time Directive 2003. Parliament put these rights in place when it passed the European Communities Act in 1972. The High Court also ruled against the government’s right to use the royal prerogative (Supreme Court, 2017).[25] To explain why, the High Court cited the case of Burmah Oil Co (Burma Trading) Ltd v Lord Advocate [1965] AC 75, 101. This case involved use of the royal prerogative. Lord Reid, dismissed the royal prerogative as a â€Å"relic of a past age† (House of Lords, 1965, p.101).[26] Lord Reid also explained that the royal prerogative is â€Å"only available for a case not covered by statute† (p.101).[27] Typically, the royal prerogative is only for situations such as declaring war, dissolving parliament and governing colonies (Wade, 1961).[28] So, in Miller’s case, the High Court explained that a royal prerogative was inappropriate for triggering Brexit. Therefore, the government did not have the power to trigger Article 50 without Parliament’s approval. The government was unhappy with the High Court’s decision and chose to appeal it, and as a result the case went to the Supreme Court. Ultimately, the Supreme Court dismissed the government’s appeal, citing the same reason as the High Court (Supreme Court, 2017).[29] Essentially, the court explained, the government in 1972 needed Parliament’s approval to sign the 1972 Accession Treaty. This meant that present-day government also needed Parliament’s approval to repeal this treaty (Supreme Court, 2017).[30] Of course, those in the â€Å"Leave† camp were outraged with the High Court’s decision. Like Theresa May, they believed that Parliament was attempting to obstruct the progression of Brexit. A Ukip donor accused the High Court of declaring war on British democracy (Maguire, 2016).[31] In reality, however, this was not the case; the High Court was merely upholding the British constitution as intended, by honouring the principle of parliamentary sovereignty (Weale, 2017)[32] and following the Rule of Law. Importance of the Rule of Law. On 29 March 2017, the Prime Minister wrote to the President of the European Council to notify the European Council of the United Kingdom’s intention to leave the European Unit and the triggering of Article 50 of the Treaty. Brexit is no longer a hypothetical question. It is a concrete fact – it is happening. An issue that has been brought to the front is the belief that the Government has the power, and right, to act on Brexit without Parliaments involvement. This is even more troubling as the very constitution is built upon Parliamentary sovereignty. The issue of human rights comes up as it can be dangerous, in a country where the legislature is mostly under the control of the executive, to leave it solely up to a sovereign Parliament with an absent constitution. If the Parliament can be avoided altogether, this can lead to an even worse situation overall and so highlights how important it was for the Supreme Court in Miller to stand up for and defend the power of Parliament over the executive.   Brexit is one of the most influential and far-reaching changes to the international social and political landscapes today. Brexit will shape Britain, and the international community, for years to come. It is for this reason that it is undeniable that this process should be founded in the rule of law. To comprehend the importance of the rule of law we must give it a clear definition. A well-known definition is that of Lord Bingham: â€Å"that all persons and authorities in the State, whether public or private, should be bound by and be entitled to the benefit of all laws publicly made, taking effect (generally) in the future and publicly administered in the courts.† The Venice Commission has identified the following 8 components of the rule of law: ‘(1) Accessibility of the law (that it be intelligible, clear and predictable); (2) Questions of legal right should be normally decided by law and not discretion; (3) Equality before the law; (4) Power must be exercised lawfully, fairly and reasonably; (5) Human rights must be protected; (6) Means must be provided to resolve disputes without undue cost or delay; (7) Trials must be fair, and (8) Compliance by the state with its obligations in international law as well as in national law.’ The importance of the rule of law is recognised in multiple international documents. For example, the preamble to the UN Declaration of Human Rights notes the importance of the rule of law in protecting human rights. The Treaty on European Union also couples ‘the rule of law and respect for human rights’. It is this human rights element that the remained of this short essay will focus on. Brexit will reform the social landscape of Britain and Europe. It is of paramount importance that the rule of law is respected in this reformation to ensure that fundamental rights, particularly those of minorities and vulnerable individuals, continue to be respected. This is especially true given that there has been much debate as to whether the Brexit vote was fuelled by xenophobia and racism. Research has shown that there was an increase in support for far-right groups during the Brexit campaign and following the murder of Jo Cox. There has also been an alleged escalation in hate crime targeting migrant communities as well an increase in anti-immigration rhetoric. The Brexit vote, coupled with Trump, and the rise of the far-right, summons fears surrounding the polarization of politics and the creeping rise of extremism. With this in mind, it is quite chilling to consider Lord Bingham’s thoughts on a system which is not founded on the rule of law: â€Å"The hallmark of a regime which flouts the rule of law are, alas, all too familiar: the midnight knock on the door, the sudden disappearance, the show trial, the subjection of prisoners to genetic experiments, the confession extracted by torture, the gulag and the concentration camp, the gas chamber, the practice of genocide and ethnic cleansing, the waging of aggressive wars.† In a time when international politics is becoming increasingly unclear and strained and communities are fraught with increased fear and racial tensions, now more than ever, the rule of law and the importance of Parliamentary Sovereignty must be respected. As noted by the Prime Minister, the task before the British nation is momentous but it should not be insurmountable. Britain post-Brexit has an unclear future and an undefined path. By adhering to the rule of law, the certainty, stability and protection that it provides will ensure that this difficult task is negotiated with the utmost respect for all peoples and their inalienable human rights. 3. The European Union (Notification of Withdrawal) Act 2017 Given that the Supreme Court had dismissed the government’s appeal, the government now needed Parliament’s approval to trigger Article 50. In order to receive this approval, the government introduced a new bill in Parliament. This bill was called the European Union (Notification of Withdrawal) Act 2017.Essentially, this bill would give Theresa May the power to trigger Article 50. However, Parliament had the power to reject the bill if it felt appropriate. This was again because of parliamentary sovereignty (Weale, 2017).[33] Despite that most voters voted ‘Leave’ in the referendum, this result was not legally binding and Parliament could ignore the referendum result. The principle of parliamentary sovereignty means that the ultimate power rests with Parliament, not the public nor the results of referendums. The public only have the power to elect MPs, and once elected, MPs can go against the wishes of their constituents and make their own decisions if they want to. MPs can even go against a referendum result, despite that this might cause great anger with the British public. As Dicey stated, â€Å"the electors can in the long run always enforce their will† (Dicey, 1915).[34] However,   all three decision making bodies of Parliament – the Queen, the House of Lords and the House of Commons – approved the Notification of Withdrawal Act (BBC, 2017).[35] The Queen gave the final green flag on 16 March 2017. This gave the Prime Minister the power trigger to Article 50 and inform the EU of the UK’s withdrawal. The government officially triggered Article 50 on 29 March 2017, when a UK envoy delivered a letter of withdrawal to the President of the European Council (BBC, 2017).[36] The issue of parliamentary sovereignty then took a back seat as the UK began exit negotiations with the EU. Of the 170,000 statutory instruments that have been sent to Parliament in the last 65 years, only seventeen have been rejected, and any substantive debate over individual instruments is a rare occurrence. Responsibility has been delegated for regulation both to the government and the European Union. For this reason, possibly up to sixty per cent of UK law may be derived from EU law in some way. Furthermore, for many years, legislative and technical expertise in the pertinent areas have again been delegated to Brussels. This leaves domestic civil servants under prepared to handle the of important decisions that will need to be made in the coming years. David Allen Green’s analysis is difficult to refute: â€Å"under the cloak of the referendum result there will be a power grab by Whitehall from Westminster. Those rejoicing at â€Å"taking back control† should be careful what they wish for. The executive is, as usual, wanting to take control away from Parliament.† On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. On many occasions, it has been asserted that because the ‘people have spoken’ through the referendum, it gives the executive the right to push onward without the consent of Parliament. Does this mean that the claims of direct democracy, in the form of the referendum, trump the claims of Parliamentary representative democracy, with the paradoxical effect of giving more power to the executive? The greater part have affirmed that referenda are in and of themselves a product of Parliamentary authority and must accordingly rely on the statute which enables them. The 2015 EU referendum Act only called for the referendum to take place, without establishing how to approach it or the potential consequences. ‘Where, as in this case, implementation of a referendum result requires a change in the law of the land, and statute has not provided for that change, the change in the law must be made in the only way in which the UK constitution permits, namely through Parliamentary legislation.’ The actual political importance of a referendum is not subverted however. What is does assert is the basic dogma that, in a democracy, the people can speak through their representatives in Parliament. Nevertheless, direct democracy cannot be operationalised by giving undiluted power to the executive. 4. Conclusion This paper has discussed parliamentary sovereignty in the UK in the wake of Brexit. First, Section 1 introduced the concept of parliamentary sovereignty in the UK. This section explained that parliamentary sovereignty goes back to the 17th century, when the courts first enshrined the principle in the Bill of Rights. The section also drew attention to the rule that only Parliament can undo Acts of Parliament. I then discussed the Miller case in Section 2. In this case, members of the public argued that the government required Parliaments approval to leave the EU. The courts decided in favour of Millers side; that explained that Parliament was needed to trigger to Article 50 due to parliamentary sovereignty. The decision was controversial because some people saw it as an attempt to subvert the referendum result. Finally, Section 3 discussed the European Union Act 2017. This act that demonstrated the principle of parliamentary sovereignty. The government essentially asked Parliament for permission to trigger Article 50, and Parliament agreed by passing the act. In conclusion, the principle of parliamentary sovereignty was tested in the wake of Brexit. Ultimately however, courts respected the principle and gave Parliament the ultimate power over whether Britain should leave the EU. However, the future is still uncertain, as no-one yet knows what Brexit will look like. Perhaps a future Parliament will reverse the Brexit decision. After all, parliamentary sovereignty gives future Parliaments the right to reverse the decisions of previous Parliaments. What needs to be addressed is the potential consequneces that the referendum may have on Palimentary sovernety and represesentitive democracy throughout the UK. For this reason, Parliment needs to continue to be a central part of the process despite any predetermined preferences from the Government itself. Parliamentary sovereignty must remain intact as, for the many reasons stated, it is an integral part of the United Kingdom’s constitution, because its deliberate and representative functions and ability to hold the executive to account are defining features of the United Kingdom’s enduring constitution. 5. References Barber, N.W., 2011. The afterlife of Parliamentary sovereignty. International Journal of Constitutional Law, 9(1), pp.144–154. Barnett, H., 2017. Constitutional and administrative law, Taylor & Francis. BBC, 2017. BBC News website. Available at: http://www.bbc.com/news [Accessed July 14, 2017]. Bradley, A., 2011. The Sovereignty of Parliament–Form or Substance? The Changing Constitution, 23, pp.54–56. Dicey, A.V., 1915. Introduction to the Study of the Law of the Constitution 8th ed., Liberty Classics. EU, 2007. Treaty on European Union, Freehills, H.S., 2016. Judicial review litigation over the correct constitutional process for triggering Article 50 TEU. Lexology. Available at: http://www.lexology.com/library/detail.aspx?g=f43e102f-ea09-4449-b781-a35ecfe628fe [Accessed July 13, 2017]. Goldsworthy, J., 2010. Parliamentary sovereignty: contemporary debates, Cambridge University Press. House of Lords, 1965. Burmah Oil Co (Burma Trading) Ltd v Lord Advocate AC 75, House of Lords, 1610. Proclamations, Case of [1610] EWHC KB J22, Available at: http://www.bailii.org/ew/cases/EWHC/KB/1610/J22.html. Maguire, P., 2016. Seizing our sovereignty or declaring war on democracy: split view on judges’ ruling. The Guardian. Available at: https://www.theguardian.com/politics/2016/nov/06/brexit-this-is-what-sovereignty-looks-like#img-1 [Accessed July 13, 2017]. Pannick, D., 2016. Why giving notice of withdrawal from the EU requires act of parliament. The Times. Available at: https://www.thetimes.co.uk/article/c8985886-3df9-11e6-a28b-4ed6c4bdada3. Parliament of England, 1689. English Bill of Rights, Supreme Court, 2016. Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†), Available at: http://www.croftsolicitors.com/wp-content/uploads/2016/11/139459-UKSC-2016-0196-Skeleton-for-Expat-Interveners-final-written-case-2.pdf. Supreme Court, 2017. Miller v Secretary of State for Exiting the European Union, London. Available at: https://www.supremecourt.uk/cases/docs/uksc-2016-0196-judgment.pdf. Wade, W., 1961. Administrative Law, London: Oxford University Press. Weale, A., 2017. The Democratic Duty to Oppose Brexit. The Political Quarterly, 88(2), pp.170–181. [1] BBC [2] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 177 [3] Hilaire Barnett, Constitutional and administrative law (Taylor & Francis 2017) [4] House of Lords, Case of [1610] EWHC KB J22 [5] Jeffrey Goldsworthy, Parliamentary sovereignty: contemporary debates (Cambridge University Press 2010) [6] Parliament of England, English Bill of Rights [7] Albert Dicey, Introduction to the Study of the Law of the Constitution (8th edn, Liberty Classics 1915) [8] Anthony Bradley, ‘The Sovereignty of Parliament–Form or Substance?’ (2011) The Changing Constitution 54 [9] Nicholas Barber, ‘The afterlife of Parliamentary sovereignty’ (2011) International Journal of Constitutional Law 149 [10] Supreme Court, Miller v Secretary of State for Exiting the European Union [11] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [12] EU, Treaty on European Union [13] David Pannick, Why giving notice of withdrawal from the EU requires act of parliament [14] BBC [15] Herbert Smith Freehills, Judicial review litigation over the correct constitutional process for triggering Article 50 TEU [16] BBC [17] Albert Weale, ‘The Democratic Duty to Oppose Brexit’ (2017) The Political Quarterly 180 [18] Supreme Court, Miller v. Secretary of State for Exiting the European Union Written case for Mr George Birnie & Others (The â€Å"Expat Interveners†) 21 [19] Supreme Court, Miller v. 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