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. 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

Education Essay -- essays research papers

â€Å"If the colored children are denied the experience in school of associating with white children, who represent ninety percent of our nation society in which these colored children must live, then the colored child’s curriculum is greatly being curtailed† (1).In the fifties and sixties the civil rights movement along with help of organization like the NAACP fought racial segregation, because blacks were not equal to their white brothers and sisters. African-Americans schools were usually undermined to white schools throughout America history. African-Americans were considered privileged if they received an education or could comprehend the reading and written language of society. Segregation of children in schools has a detrimental effect upon the colored child, who gains a sense of inferiority which later affects the colored child ability to sustain knowledge (2). In 1954, the United States Supreme Court in the Brown vs. the Board of Education ruled that racial se gregation in public schools was unconstitutional which violated the fourteenth Amendment, which granted equal protection to all citizens regardless of race. This outcome had overturned the old standard which was set in 1896 in the Plessey vs. Ferguson, which said separate but equal facilities were constitutional. The new ruling made it possible for a little third-grader named Linda Brown could attend a predominately white elementary that was just a mile away from her house, instead of walking about six miles to the rundown black elementary school. In 1955 following the United States Supreme Court case Brown v. Board of Education, granted equal access and opportunity for education of minorities to be carried out ASAP. But it was not until the passing of the Civil Rights Act of 1964 that efforts final took effect to desegregate schools in the south. This act made it possible for black children in twenty-one other states could attend white public schools, if their school was not equal to there counterparts. In the years that followed the public school systems of many states where reluctantly to bus black students off to far distances, because they were trying to maintain racial proportion (O’Connor 374). The color-lines of America will never change according to W.E.D Dubois: we as Americans need not to forget our past, because we have now installed a new school plan, called choice schools throughout t... ..., and religious societies. One of the primary purposes of schools is to prepare students for the working world, and it makes no sense to prepare them with a faulty model. If the world at large is desegregated, the schools should not be segregated, either† (Watson 4). The Civil Rights Project† 5 November 2003. Home page http://www.civilrightsproject.harvard.edu/research/choice/school_choice.php www.gsu.edu/mwwwsps/news/release/segergated_schools.htm O’Connor, Karen and Sabato, Larry J. American Government: Continuity and Change 2002 Edition, Addison Wesley Longman, Inc. Peterson, Paul E. â€Å"School Choice: A Civil Rights Issue† Home page. 5 November 2003. http://www-hoover.stanford.edu/pubaffairs/we/2002/peterson_0602.html â€Å"Public School Choice: Issues and Concerns for Urban Educators.† ERIC/CUE Digest No. 63. 5 November 2003. http://www.ericfacility.net/databases/ERIC_Digests/ed322275.html Ryan, Kelly. Home page. 5 November 2003. http://www.sptimes.com/News/101800/NorthPinellas/Pinellas_school_choic.shtml 5 November 2003. Tampa Bay Kids. www.tampabaykidsnet.com/pinellasschoolchoice.htm 5 November 2003. Civil Rights. http://www.watson.org/mlisa/blackhistory/early-civilrights/brown

Nonverbal Communication Is Important

Communication is the exchange of information from a person to another or a group of people; this includes a sender transferring information, ideas or feelings to a receiver. There are two ways to communicate: verbal and nonverbal. Verbal is the way that people use to communicate everyday: talking. Nonverbal communication does not use talking but involves body language, posture, gestures, eye contact, touch and physiological responses. Although people use verbal communication everyday, their nonverbal communication is more important than verbal.Nonverbal communication is a big benefit for business, because that is the important key when a business man can express himself; he can be confident when meeting a partner or clients. For example, the handshake is an important way to make a first impression. No matter the basis of the hand shake, it should become a part of repertoire. Handshake is a sign of trust and help build strong relationship. Imagine meeting a well – groomed, well – dress expert for the first time – but when you are shake his/her hand, you feel like you are grabbing an infant’s finger. â€Å"The important of nonverbal communication ten things your handshakes says about you†) When people meet someone with a strong handshake, they usually come up with some hypothesis like: that person is confident, serious and focused. On the contrary, a weak handshake will make people come up with some thinking like the person is weak in personality, uncertain or lacking in determination (â€Å"The important of nonverbal communication ten things your handshake says about you†). When people have a strong handshake, their hands usually have a warm temperature.Temperature is one of many first impressions, too. When people meet someone with a warm hand, they will think that person is kindness and gracious. Handshakes is the most important in business, nobody want their partner to have a bad impression about them. So nonverbal co mmunication is very important in business, without that, the business may not be develop and effect the economy of country. In the other hand, the role of nonverbal communication is very important in school environment.Sentence and Verbal CommunicationIn school, student from everywhere in the world with different cultures would like to hang out with their friend, that is social being and using different nonverbal communication can built or destroy a relationship of misunderstood action. A child first learns to communicate with those around him or her by using his or her nonverbal skills like pointing, clenching his fist, clapping his hands when excited, slapping away objects he does not want, being stubborn when he or she is sleepy, etc.Therefore,  those skills are more highly developed in the beginning than is his speech. By combining non-verbal and verbal when trying to reach the children you have a better chance to make connection (â€Å"the advantages and disadvantages of non verbal communication in school†). With some student lack of ability to explain them, so the teacher can look at their facial expression or their action and can easily understand what they are cannot say through verbal communication.

Endangered Species Criteria and Definition

Endangered Species Criteria and Definition What Are Endangered Species? Rare, endangered, or threatened plants and animals are elements of our natural heritage that are declining rapidly or are on the verge of vanishing. They are plants and animals that exist in small numbers that may be lost forever if we do not take quick action to stop their decline. If we cherish these species, like we do other rare and beautiful objects, these living organisms become treasures of the highest magnitude. Why Preserve Endangered Plants and Animals? Preservation of plants and animals is important, not only because many of these species are beautiful, or can provide economic benefits for us in the future, but because they already provide us many valuable services. These organisms clean air, regulate our weather and water conditions, provide control for crop pests and diseases, and offer a vast genetic library from which we can withdraw many useful items. Extinction of a species could potentially mean the loss of a cure for cancer, a new antibiotic drug, or a disease-resistant strain of wheat. Each living plant or animal may have values yet undiscovered. Scientists estimate there are thirty to forty million species on earth. Many of these species are represented by dozens of genetically distinct populations. We know very little about most species; less than two million are even described. Oftentimes, we do not even know when a plant or animal becomes extinct. Game animals and a few insects are watched and studied. Other species need attention too. Perhaps in them may be found a cure for the common cold or a new organism that will prevent millions of dollars of loss to farmers in their constant fight against crop diseases. There are many examples of a species value to society. An antibiotic was discovered in the soils of the threatened New Jersey Pine Barrens Natural Area. A species of perennial corn was found in Mexico; it is resistant to several diseases of corn. An insect was discovered that when frightened produces an excellent insect-repelling chemical. Why Have Species Become Endangered? Habitat Loss Loss of habitat or the native home of a plant or animal is usually the most important cause of endangerment. Nearly all plants and animals require food, water, and shelter to survive, just as humans do. Humans are highly adaptable, however, and can produce or gather a wide variety of foods, store water, and create their own shelter from raw material or carry it on their backs in the form of clothing or tents. Other organisms cannot. Some plants and animals are highly specialized in their habitat requirements. A specialized animal in North Dakota is the piping plover, a small shorebird which nests only on bare sand or gravel on islands of rivers or shorelines of alkali lakes. Such animals are much more likely to become endangered through habitat loss than a generalist like the mourning dove, which nests successfully on the ground or in trees in the country or city. Some animals are dependent on more than one habitat type and need a variety of habitats near each other to survive. For example, many waterfowl depend on upland habitats for nest sites  and nearby wetlands for food supplies for themselves and their broods. It must be emphasized that habitat does not have to be completely eliminated to lose its usefulness to an organism. For example, the removal of dead trees from a forest may leave the forest relatively intact, but eliminate certain woodpeckers that depend on dead trees for nest cavities. The most serious habitat loss totally changes the habitat and renders it unfit for most of its original resident organisms. In some areas, the greatest changes come from plowing native grasslands, draining wetlands, and constructing flood-control reservoirs. Exploitation Direct exploitation of many animals and some plants took place before conservation laws were enacted. In some places, exploitation was usually for human food or furs. Some animals, such as Audubons sheep, were hunted to extinction. Others such as the grizzly bear, maintain remnant populations elsewhere. Disturbance The frequent presence of man and his machines may cause some animals to abandon an area, even if the habitat is not harmed. Some large raptors, like the golden eagle, fall into this category. Disturbance during the critical nesting period is especially harmful. Disturbance combined with exploitation is even worse. What Are The Solutions? Habitat protection is the key to protecting our rare, threatened, and endangered species. A species cannot survive without a home. Our first priority in protecting a species is to ensure its habitat remains intact. Habitat protection can be done in a variety of ways. Before we can protect a plants or animals habitat, we need to know where this habitat is found. The first step, then, is to identify where these vanishing species are found. This is being accomplished today by state and federal agencies and conservation organizations. Second to identification is planning for protection and management. How can the species and its habitat be best protected, and once protected, how can we make sure the species continues healthy in its protected home? Each species and habitat is different and must be planned on a case-by-case basis. A few protection and management efforts have proven effective for several species, however. Endangered Species List Legislation was passed to protect the most endangered species in the United States. These special species cannot be destroyed nor can their habitat be eliminated. They are marked in the endangered species list by an *. Several federal and state agencies are beginning to manage threatened and endangered species on public lands. Recognition of private landowners who have voluntarily agreed to protect rare plants and animals is underway. All these efforts need to continue and be expanded to keep our natural heritage alive.​ This resource is based on the following source: Bry, Ed, ed. 1986. The rare ones. North Dakota Outdoors 49(2):2-33. Jamestown, ND: Northern Prairie Wildlife Research Center Home Page. npwrc.usgs.gov/resource/othrdata/rareone/rareone.htm (Version 16JUL97).

Free Essays on Specific Examples Involving The Interpretation Of The Parthenon’s Frieze

Specific Examples Involving the Interpretation of the Parthenon’s Frieze Looking at the Parthenon’s frieze you see many different characters in what seems to be some kind of procession. This is all noticeable to the common viewer, but does it actually have any meaning. Many interpretations have given the beautiful frieze different yet similar meanings. To many it is thought to be a piece of music transposed in to a pictorial story. The frieze seems to have a distinctive rhythm where it feels as if the characters are dancing. It is commonly thought that the scenes in the frieze are a representation of the Panathenaic procession, but scholars are arguing many of the actions and underlying meanings. Many of the actions that take place on the frieze may seem insignificant, but they actually take on a lot of meaning. The simple gesture of fiddling with a sandal marks the beginning of the festival of the Panathenaic procession. Since most scholars agree on this, their interpretations are set around the south-western corner of the frieze as being the beginning events of the procession. The characters in the frieze are all headed toward the eastern front. The Panathenaic procession was the beginning of the grand Panathenaic games. As depicted on the frieze, this ritual included the sacrifice of animals and also the offering of the Peplos to Athena. In one scene of the frieze, the priestess of Athena, the Archon Basilieus, and a young boy are folding a large piece of cloth. â€Å"Since the offering of the Peplos was the essential feature of the Panathenaic procession, and the Peplos, if not represented here, is not to be found anywhere else in the frieze, it is generally agreed that we must recognize it in the piece of drapery which the priest holds†(Gardner 89-91). It is thought that the folding of this cloth is a symbol of putting away the old Peplos to make offering of the new one. Joan B. Connelly has interpreted th... Free Essays on Specific Examples Involving The Interpretation Of The Parthenon’s Frieze Free Essays on Specific Examples Involving The Interpretation Of The Parthenon’s Frieze Specific Examples Involving the Interpretation of the Parthenon’s Frieze Looking at the Parthenon’s frieze you see many different characters in what seems to be some kind of procession. This is all noticeable to the common viewer, but does it actually have any meaning. Many interpretations have given the beautiful frieze different yet similar meanings. To many it is thought to be a piece of music transposed in to a pictorial story. The frieze seems to have a distinctive rhythm where it feels as if the characters are dancing. It is commonly thought that the scenes in the frieze are a representation of the Panathenaic procession, but scholars are arguing many of the actions and underlying meanings. Many of the actions that take place on the frieze may seem insignificant, but they actually take on a lot of meaning. The simple gesture of fiddling with a sandal marks the beginning of the festival of the Panathenaic procession. Since most scholars agree on this, their interpretations are set around the south-western corner of the frieze as being the beginning events of the procession. The characters in the frieze are all headed toward the eastern front. The Panathenaic procession was the beginning of the grand Panathenaic games. As depicted on the frieze, this ritual included the sacrifice of animals and also the offering of the Peplos to Athena. In one scene of the frieze, the priestess of Athena, the Archon Basilieus, and a young boy are folding a large piece of cloth. â€Å"Since the offering of the Peplos was the essential feature of the Panathenaic procession, and the Peplos, if not represented here, is not to be found anywhere else in the frieze, it is generally agreed that we must recognize it in the piece of drapery which the priest holds†(Gardner 89-91). It is thought that the folding of this cloth is a symbol of putting away the old Peplos to make offering of the new one. Joan B. Connelly has interpreted th...

If computer security is the answer, what is the problem, and how can Essay

If computer security is the answer, what is the problem, and how can computer security solve that problem - Essay Example As stated above, computer security deals with several issues, which are related to technology (Wong & Yeung 2009). Facebook is one of the most popular social network site globally (Kirkpatrick 2010). However, there are several security issues that pose a danger to the users. It is quite clear that Facebook has fallen victim to various security issues such as hacking, hoax applications, counterfeit product pages and affiliate spam among other issues (Stoll 2011). The number of facebook hackings has continually increased in the recent years. There are numerous aspects that make Facebook more prone to hacking since, most individuals usually post their personal information (Sterling 1993). This information enables the hackers steal the personal identity of the account (Reese 2008). Therefore, it is much easier to protect account hacking using computer security. There are several methodologies that can be employed to impede hackers from accessing a facebook account. These methodologies include using a strong password, logging out after finishing, changing the password more often and using an anti-spyware software (Erickson 2008). Using complicated passwords is one of the best ways to deal with facebook security issues. In fact, individuals are advised to use complicated passwords, which hackers are not able to retrieve (Kabay & Bosworth 2011). This will ensure that their personal information and that of their friends is protected against any alterations. Facebook users are also supposed to logout immediately they are done using the social network (Tipton & Krause 2012). This is because another individual can download malware and key loggers which affect privacy terms of the account (Burger 1991). Changing the password more often also reduces the chances of the account being hacked (Mitnick, Simon & Wozniak 2011). This toughens the ability of the hackers to find out

Systems and Operations Management Assignment Example | Topics and Well Written Essays - 2750 words

Systems and Operations Management - Assignment Example After deciding to go into retirement, Lachlan Atokowa handed over the reins of the business to his eldest son Jonathan Atokowa, who, like his father, was very passionate about the business. Both of them shared the passion to try out the latest technology: Lachlan Atokowa decided to test Xerox 914, Jonathan Atokowa decided to added Commodore 64 and the IBM PC 5100 into the business’s product portfolio. Today, a business that started in a garage has escalated into complex network business processes. Too many parties are now associated with the business, bring along different set of variables into the business environment. Organizational Structure: The company has four different departments which are governing the operations of the business. These four departments are: Retail Operations, Purchasing and Supply chain, Marketing and Human Resource Management and last but not the least the Finance Departments. Each of these departments is headed by a company director who reports dire ctly to the chief executive officer. Under each director are his personnel which are responsible for the functioning of the department. The following table describes the titles which come under each function: Retail Operations Purchasing and Supply chain Marketing and Human Resource Management Finance Director Director Director Director Area Manager Category Manager HRM Manager Company Accountant - Import Manager Training Manager Management Accountant - Warehouse Manager Marketing campaign coordinator Financial Planning Manager - General Manager In-store promotion coordinator. Purchasing and Payment Manager All the company directors are very enthusiastic about the growth of the company. They work along with their individual teams very diligently to resolve problems that are arising in their departments. However, the organisation’s directors have been unable to develop a boding force between the departments. The biggest evidence of this fact is that each department is having i ts own management systems, which are not linked with other systems. It this age of globalisation, the importance which is placed on information sharing by experts is immense. According to the experts, this single aspect of doing business is so important that it can decide the fate of today’s firms. In a fast paced globalised world, information sharing with key stake holders is vital for organisational success and survival (Krajewski, Ritzman, & Malhorta, 2007). And in this case the organisational departments are failing to share vital operational information with one another. This, obviously, is leading to duplication of effort, greater cost, declining productivity, redundancy and frustration in the organisation (Schemenner, 1984). Employees have to do cumbersome paperwork every day, accurate forecasting has become impossible, inventory holding cost is being incurred, wrong inventory is being maintained and above all, customers are feeling dejected. Rather than adopting an or ganisational model which allows the company to become nimble and flexible, so that it can compete effectively in the market place, the company has taken a structure which has made it inflexible and less than competitive (Loader, 2006). Absence of an integrated organisation wide enterprise management system is creating havoc for the company. The company is not doing accurate forecasting of demand, it has failed to satisfy customers’ needs and most importantly, it is not operating efficiently and effectively.