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Black belt essays for karate

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british essay sample The remainder of this essay writing tutorial is essays for karate based on a short sample #039;divorce essay#039; (about 1,000 words). To complete all of the culture russian visual, associated tasks, it is easiest if you have the sample essay in front of you. For Karate. A major change that has occurred in the Western family is an essay increased incidence in divorce. Whereas in the past, divorce was a relatively rare occurrence, in recent times it has become quite commonplace. This change is borne out black essays clearly in census figures. For example thirty years ago in sat perfect, Australia, only one marriage in ten ended in divorce; nowadays the figure is more than one in three (Australian Bureau of Statistics, 1996: p.45).

A consequence of belt essays for karate, this change has been a substantial increase in essay, the number of single parent families and the attendant problems that this brings (Kilmartin, 1997). An important issue for sociologists, and indeed for all of society, is why these changes in marital patterns have occurred. In this essay I will seek to critically examine a number of sociological explanations for the #039;divorce phenomenon#039; and also consider the social policy implications that each explanation carries with it. It will be argued that the best explanations are to be found within a broad socio-economic framework. One type of explanation for essays, rising divorce has focused on changes in laws relating to marriage. For example, Bilton, Bonnett and migration and the of life essay, Jones (1987) argue that increased rates of divorce do not necessarily indicate that families are now more unstable.

It is possible, they claim, that there has always been a degree of marital instability. They suggest that changes in essays for karate, the law have been significant, because they have provided unhappily married couples with #039;access to a legal solution to pre-existent marital problems#039; (p.301). Bilton et al. therefore believe that changes in divorce rates can be best explained in terms of changes in the legal system. The problem with this type of russian tekstura, explanation however, is that it does not consider why these laws have changed in the first place. It could be argued that reforms to family law, as well as the increased rate of divorce that has accompanied them, are the product of more fundamental changes in society. Another type of black essays for karate, explanation is one that focuses precisely on these broad societal changes. For example, Nicky Hart (cited in Haralambos, 1995) argues that increases in and the quality of life, divorce and marital breakdown are the result of economic changes that have affected the family.

One example of these changes is the raised material aspirations of families, which Hart suggests has put pressure on black, both spouses to become wage earners. Women as a result have been forced to become both homemakers and economic providers. According to Hart, the contradiction of of life, these two roles has lead to conflict and this is the main cause of marital breakdown. It would appear that Hart#039;s explanation cannot account for all cases of divorce - for example, marital breakdown is belt essays for karate liable to occur in families where only the husband is working. Nevertheless, her approach, which is to relate changes in family relations to broader social forces, would seem to be more probing than one that looks only at expository essay format for middle school, legislative change. The two explanations described above have very different implications for social policy, especially in relation to how the problem of belt, increasing marital instability might be dealt with. Bilton et al. (1995) offer a legal explanation and hence would see the solutions also being determined in this domain. If rises in essay, divorce are thought to be the consequence of liberal divorce laws, the obvious way to stem this rise is to belt essays make them less obtainable.

This approach, one imagines, would lead to a reduction in divorce statistics; however, it cannot really be held up as a genuine solution to the problems of marital stress and breakdown in sat perfect essay, society. Indeed it would seem to be a solution directed more at symptoms than addressing fundamental causes. Furthermore, the experience of social workers, working in the area of black, family welfare suggests that restricting a couple#039;s access to divorce would in some cases serve only to exacerbate existing marital problems (Johnson, 1981). In those cases where violence is writing help involved, the consequences could be tragic. Apart from all this, returning to more restrictive divorce laws seems to be a solution little favoured by Australians. (Harrison, 1990). Hart (cited in black, Haralambos, 1995), writing from a Marxist-feminist position, traces marital conflict to changes in the capitalist economic system and their resultant effect on review of metaphysics dissertation contest, the roles of men and women. Black Belt. It is difficult to know however, how such an analysis might be translated into practical social policies. This is because the Hart program would appear to require in sat perfect, the first place a radical restructuring of the economic system.

Whilst this may be desirable for black belt for karate, some, it is not achievable in the present political climate. Hart is right however, to suggest that much marital conflict can be linked in some way to the economic circumstances of families. This is review dissertation borne out in many statistical surveys which show consistently that rates of divorce are higher among socially disadvantaged families (McDonald, 1993). Black For Karate. This situation suggests then that social policies need to be geared to providing support and security for these types of essay, families. It is little cause for optimism however, that in recent years governments of all persuasions have shown an increasing reluctance to black for karate fund social welfare programs of this kind. It is difficult to offer a comprehensive explanation for the growing trend of marital breakdown; and it is even more difficult to find solutions that might ameliorate the problems created by it.

Clearly though, as I have argued in essay visual, this essay, the most useful answers are to be found not within a narrow legal framework, but within a broader socio-economic one. Finally, it is worth pointing out that, whilst we may appear to be living in a time of increased family instability, research suggests that historically, instability may have been the norm rather than the exception. As Bell and Zajdow (1997) point out, in the past, single parent and step families were more common than is assumed - although the disruptive influence then was not divorce, but the premature death of one or both parents. This situation suggests that in studying the modern family, one needs to employ a historical perspective, including the possibility of looking to the past in searching for ways of dealing with problems in the present. Australian Bureau of Statistics (1996). Divorces, Australia . Canberra: Australian Government Printing Service.

Bell, R. and G. Zajdow (1997) Family and household. In R. Jureidini, S. Kenny and M. Poole (eds). Sociology: Australian Connections . Essays. St Leonards. Essay Help Free. NSW: Allen and Unwin. Bilton, T., K. Bonnett and P. Jones (1987). Black Belt. Introductory Sociology , 2nd edition.

London: MacMillan. Haralambos, M. Migration Quality Of Life A Review. (1995). Sociology: Themes and Perspectives , 3rd edition. London: Bell and Hyman. Harrison, M. (1995). Grounds for divorce. Family Matters . No 42 pp 34-35.

Johnson, V. (1981). The Last Resort: A Women#039;s Refuge . Ringwood: Penguin. Black Belt For Karate. Kilmartin, C. (1997). Children divorce and one-parent families. Family Matters . No. 48. ( Available On-line ) McDonald, P. (1993).

Family Trends and Structure in Australia . On Disadvantages Family. Australian Family Briefings No 3. Melbourne: Australian Institute of Family Studies. Problems? Questions? Comments? Please provide us feedback.

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16 December 2016, 13:00. Benedikte Grenov is defending her PhD thesis: The effect of black belt, probiotics on diarrhea in children with severe acute malnutrition - an intervention study in review dissertation essay contest, Uganda Read more. 14 November 2016, 12:00. Verena Lenneis is defending her PhD thesis: The life, work and belt essays for karate, recreational physical activity of female cleaners Read more. 11 November 2016, 14:00. Malte Nejst Larsen is essay on disadvantages family, defending his PhD thesis: Fitness and Health Effects of belt essays for karate, Frequent Intense Training in expository format school, 8-10-year-old Danish Children Read more.

21 October 2016, 13:00. Mads Vendelbo Lind is defending his PhD thesis: The role of black belt essays, diet in on disadvantages family, one-carbon metabolism and epigenetics - A metabolic syndrome perspective Read more. 13 October 2016, 14:00. Richard Thomas is defending his PhD thesis: Acute Exercise and Motor memory Consolidation Read more. 23 September 2016, 15:15. Janne Rasmus Hingst is belt essays, definding his PhD thesis: Glucose uptake and glycogen synthesis in recovery from exercise - Molecular mechanisms regulating the set-point for muscle glucose storage Read more. 30 June 2016, 15:00. PhD defence - Christian Ole Moller Madsen. Christian Ole Møller Madsen is defending his PhD thesis: Badminton specific testing and essay, development of physical on-court exercise capacity in elite youth badminton players Read more.

23 June 2016, 13:00. PhD defence - Esther Babirekere-Iriso. Esther Babirekere-Iriso is defending her PhD thesis: Polyunsaturated fatty acid status and black for karate, physical activity level in expository school, children admitted with severe acute malnutrition Read more. 23 June 2016, 13:00. PhD defence - Jane Nygaard Eriksen. Jane Nygaard Eriksen is defending her PhD thesis: Metabolism and potential health effects of carotenoids following digestion of green-leafy vegetables - an interdisciplinary approach Read more. 19 May 2016, 15:00.

Henrik Kirk is defending his PhD thesis: Measurement and treatment of passive muscle stiffness Read more. 12 May 2016, 14:00. PhD defence - Andreas M?chel Fritzen. Andreas Mæchel Fritzen is defending his PhD thesis: Emerging roles of AMP-activated protein kinase Read more. 29 April 2016, 14:00. Rasmus Kjøbsted is defending his PhD thesis: Role of AMPK in Regulating Muscle Insulin Sensitivity Read more. 25 January 2016, 13:00. PhD defence - Thomas Rostgaard Andersen. Thomas Rostgaard Andersen is defending his PhD thesis: Recreational Football in Veteran Football Players, Untrained Old Men and black, Men with Type 2 Diabetes Mellitus Activity Profile, Physiological Response, and family, Effects of black belt, a Life-long Physically Active Lifestyle and sat perfect essay, Supervised Training Read more. 20 November 2015, 13:00. PhD defence - Tanja Kongerslev Thorning.

Tanja Kongerslev Thorning is belt essays for karate, defending her PhD thesis: Cardiometabolic effects of cheese intake -does fat content and ripening duration matter? Read more. 6 November 2015, 14:00. Lasse Christiansen is defending his PhD thesis: Motor skill learning and corticospinal excitability A critical appraisal Read more. 7 October 2015, 13:00. PhD defence - Rasmus Baadsgaard M?rkedahl. Rasmus Baadsgaard Mærkedahl is defending his PhD thesis: Biomarkers of low-grade systemic inflammation: Association with metabolic syndrome and influence of whole grain intake Read more.

23 September 2015, 14:00. Joachim Fentz is on disadvantages of nuclear family, defending his PhD thesis: AMPKα in exercise-induced substrate metabolism and exercise training-induced metabolic and mitochondrial adaptations Read more. 21 September 2015, 10:15. Mette Korshøj is defending her PhD thesis: Physical work demands and fitness - Effects on risk factors for cardiovascular disease from a randomized controlled trial among cleaners Read more. 25 August 2015, 14:00. PhD defence - Morten Hostrup Nielsen. Morten Hostrup Nielsen is defending his PhD thesis: Acute and chronic effects of belt essays, ß2-adrenoceptor agonists in relation to exercise performance and doping with emphasis on terbutaline Read more. 3 June 2015, 13:00. Line Quist Bendtsen is essay russian tekstura, defending her PhD thesis: Dairy proteins and energy balance Read more. 11 May 2015, 13:00.

Peter Erik Lotko Pontoppidan is defending his PhD thesis: Nutrition and belt, gut mucositis in pediatric oncology Read more. 6 May 2015, 10:00. PhD defence - Thomas Christian Bonne. Thomas Christian Bonne is defending his PhD thesis: Effects of migration and the quality a review, exercise training on haematology and maximal cardiac output Read more. 4 May 2015, 14:00. Svenja-Maria Mintert is defending her PhD thesis: Football, Feminisation, Fans: Sociological Studies in a European Context Read more. 23 April 2015, 14:00. PhD defence - Johan Michael Wikman. Johan Michael Wikman is defending his PhD thesis: Development of an Evidence-based Sport Psychological Training Program for essays, Young Elite Athletes Read more. 16 April 2015, 14:00.

PhD defence - Andreas Borsting Jordy. Andreas Børsting Jordy is defending his PhD thesis: Skeletal muscle and review dissertation essay, liver lipidomics and belt for karate, the regulation of of metaphysics essay, FAT/CD36 - impact of high fat diet and essays, exercise Read more. 10 April 2015, 14:00. Maximilian Kleinert is help, defending his PhD thesis: mTORC2 Regulation of Muscle Metabolism and belt, Insulin Sensivity Read more. 19 March 2015, 13:00. PhD defence - Stine-Mathilde Dalskov. Stine-Mathilde Dalskov is defending her PhD thesis: Growth and quality of life, body composition of school-aged children - The influence of black essays for karate, a school meal intervention, hormones and and the quality of life a review, season Read more.

13 March 2015, 13:00. PhD defence - Maren Johanne Heilskov Rytter. Maren Johanne Heilskov Rytter is defending her PhD thesis: In-patient treatment of belt essays for karate, severe acute malnutrition - immune function, œdema and survival Read more. 6 March 2015, 13:00. Signe Marie Jensen is essay on disadvantages, defending her PhD thesis: Statistical analyses of growth and black essays, body composition in children Read more.

27 February 2015, 13:00. PhD defence - Sesilje Bondo Petersen. Sesilje Bondo Petersen is expository format, defending her PhD thesis: Impact of maternal diet on offspring bone fracture risk during childhood Read more. 19 February 2015, 14:00. Kasper Skriver is defending his PhD thesis: The Effect of Acute Exercise on essays, Consolidation and quality of life a review essay, Retention og Motor Memory Read more. 19 January 2015, 13:00. Anna Melin is defending her PhD thesis: Energy Availability and Reproductive Function in Female Endurance Athletes Read more.

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PhD defence - Lasse Gliemann Hybholt. Lasse Gliemann Hybholt is defending his PhD thesis: Vascular function and angiogenesis in aging and review dissertation, essential hypertension - adaptive response to belt for karate, physical activity and resveratrol supplementation Read more. 7 November 2014, 14:00. Jakob Friis Schmidt is defending his PhD thesis: Cardiovascular adaptations to essay help free, recreational football training in men with type 2 diabetes, untrained elderly men and in men with prostate cancer receiving androgen deprivation therapy Read more. 31 October 2014, 13:00. PhD defence - Louise Beltoft Borup Andersen. Louise Beltoft Borup Andersen is belt for karate, defending her PhD thesis: Dietary patterns in Childhood - Relation to Growth, Obesity and Parental Characteristics Read more. 24 October 2014, 14:00. Monika Judyta Bak is defending her PhD thesis: Determination of glucagon-like peptide-1, glucagon and oxyntomodulin in plasma Read more. 10 October 2014, 15:30.

Svein Barene is defending his PhD thesis: Soccer and Zumba as health promotion among female hospital employees Read more. 9 October 2014, 13:00. PhD defence - Tsinuel Girma Nigatu. Tsinuel Girma Nigatu is defending his PhD thesis: Bioimpedance in severely malnourished children An emerging method for expository essay format for middle, monitoring hydration of children with severe acute malnutrition Read more. 14 August 2014, 14:00.

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PhD defence - Maria Willerslev-Olsen. Maria Willerslev-Olsen is defending her PhD thesis: Spasticity in Children with Cerebral Palsy Read more. 2 May 2014, 13:00. Rikke A. Petersen is black belt, defending her PhD thesis: Vitamin D status in Danish children - Determinants, effects of school meals, and associations with cardio-metabolic markers Read more. 30 April 2014, 13:00.

PhD defence - Sanne Kellebjerg Poulsen. Sanne Kellebjerg Poulsen is defending her PhD thesis: The health effects of the New Nordic Diet Read more. 31 March 2014, 13:00. Mads Fiil Hjorth is defending his PhD thesis: Movement behaviors in children and indicators of adverse health Read more. 27 March 2014, 14:30. Lykke Sylow Hansen is defending her PhD thesis: Involvement of Rac1 and the actin cytoskeleton in insulin- and contraction-stimulated intracellular signaling and glucose uptake in culture visual, mature skeletal muscle Read more. 21 March 2014, 13:00. PhD defence - Line Brinch Christensen. Line Brinch Christensen is defending her PhD thesis: Physical activity and health in preschool children - The SKOT cohort study Read more. 20 March 2014, 13:00.

Laurine B.S. Harsløf is defending her PhD thesis: Determinants of DHA status and functional effects on metabolic markers and immune modulation in early life. Use of single nucleotide polymorphisms to support effects of n-3 LCPUFA Read more. 21 February 2014, 13:00. Jan Stanstrup is defending his PhD thesis: Metabolomics investigation of whey intake: Discovery of markers and biological effects supported by a computer-assisted compound identification pipeline Read more. 17 February 2014, 13:00. Yanqi Li is defending her PhD thesis: Bioactive Milk for Intestinal Maturation in Preterm Neonates Read more. 24 January 2014, 13:00. PhD defence - Maj-Britt Schmidt Andersen. Maj-Britt Schmidt Andersen is defending her PhD thesis: Discovery of food exposure markers in urine and evaluation of belt, dietary compliance by untargeted LC-MS metabolomics Read more.

13 January 2014, 13:00. PhD defence - Jutta Kloppenborg Heick Skau. Jutta Kloppenborg Heick Skau is on disadvantages, defending her PhD thesis: Preventing undernutrition in Cambodia - Assessing the effects of improved local complementary food on growth Read more. 10 January 2014, 14:00. PhD defence - Peter Moller Christensen. Peter Møller Christensen is belt essays for karate, defending his PhD thesis: Effects of oxygen delivery, dietary nitrate, intensified training and prior exercise on oxygen uptake kinetics and performance in culture essay visual, humans Read more.

10 January 2014, 13:00. PhD defence - Katrine Tschentscher Ejlerskov. Katrine Tschentscher Ejlerskov is defending her PhD thesis: Body composition at 3-years of age - The influence of early growth, infant feeding and IGF-I Read more. 20 December 2013, 13:00. PhD defence - Carl Frederik Hansen. Carl Frederik Hansen is defending his PhD thesis: Bariatric surgery, gut morphology and enteroendocrine cells - A study on black essays for karate, the morphological adaptations after surgery Read more. 18 December 2013, 13:00. PhD defence - Julie Bousgaard Hjerpsted. Julie Bousgaard Hjerpsted is defending her PhD thesis: Cheese and Cardiovascular Health - Evidence from observational, intervention and culture essay russian tekstura, explorative studies Read more. 29 November 2013, 13:00.

Daniela Rago is belt essays, defending her PhD thesis: Biomarker identification in metabolomics of expository school, dietary studies on essays, apple and essay, apple products Read more. 22 November 2013, 13:00. PhD defence - Michael Ladegaard Jensen. Michael Ladegaard Jensen is defending his PhD thesis: Antimicrobial and black belt, nutritional interventions in early life Read more. 21 November 2013, 13:00. Louise Bruun Werner is essay russian visual, defending her PhD thesis: Does green feed result in healthier dairy products?

How can dairy products contribute to a healty and sustainable diet? Read more. 1 November 2013, 10:00. Karina Arnberg is defending her PhD thesis: The effects of milk and milk proteins on essays, risk factors of metabolic syndrome in overweight adolescents Read more. 17 October 2013, 13:00. Kia Halschou Jensen is defending her PhD thesis: Inhibition of intestinal disaccharidase activity by expository school pentoses -with special reference to the uptake of glucose from starch and belt, sucrose and the insulin secretion in humans Read more.

9 October 2013, 13:00. Charlotte Mithril is defending her PhD thesis: Development of a healthy New Nordic Diet Read more. 4 October 2013, 13:00. Mette Frahm Olsen is defending her PhD thesis: Nutritional supplementation of HIV patients. Effects and feasibility of a lipid-based nutrient supplement among patients initiating ART in Jimma, Ethiopia Read more. 12 September 2013, 11:00. Julie Berg Schmidt is format for middle, defending her PhD thesis: Effects of Roux-en-Y Gastric Bypass on Energy Expenditure and Appetite Read more. 6 September 2013, 13:00. Malene Wibe Poulsen is defending her PhD thesis: Dietary Advanced Glycation Endproducts Effects on risk markers for belt essays, type 2 diabetes and essay, cardiovascular disease Read more. 27 August 2013, 13:00.

Martin Høyer Rose is defending his PhD thesis: Rehabilitation in black essays for karate, Parkinson's Disease Read more. 21 August 2013, 13:00. PhD defence - Nina Rica Wium Geiker. Nina Rica Wium Geiker is defending her PhD thesis: Optimizing patient nutrition Read more. 8 July 2013, 14:00. PhD defence - Michael Permin Nyberg. Michael Permin Nyberg is defending his PhD thesis: Vascular function and migration quality of life a review, regulation of blood flow in resting and contracting skeletal muscle. Insight from essential hypertension, aging, and physical activity. Read more.

25 June 2013, 13:00. Andreas Vegge is black belt essays for karate, defending his PhD thesis: Treatment of sat perfect, neonatal short bowel syndrome. Lessons from animal models - development, treatment and black belt essays, translation Read more. 21 June 2013, 13:00. PhD defence - Mette Viberg Ostergaard.

Mette Viberg Østergaard is defending her PhD thesis: Amniotic fluid and migration and the quality a review, development of the immature intestine. Responses to postnatal intake of amniotic fluid in essays, a preterm pig model of necrotizing enterocolitis Read more. 10 June 2013, 14:00. Mads Bendiksen is defending his PhD thesis: Activity profile and physical demands of ball games for children and essay free, adults of both genders - optimizing intermittent testing protocols Read more. 31 May 2013, 10:00. PhD defence - Anina Ritterband-Rosenbaum. Anina Ritterband-Rosenbaum is black essays, defending her PhD thesis: The sense of agency. Movement perception and behavior in healthy individuals and individuals diagnosed with spastic hemiplegic cerebral palsy Read more. 22 May 2013, 14:00. Louise Dalgas Høeg is defending her PhD thesis: Regulation of skeletal muscle insulin action in relation to dietary fatty acids and format for middle, gender Read more.

25 March 2013, 15:00. Birgitte Høier is black essays for karate, defending her PhD thesis: Regulation of angiogenesis in expository format for middle school, human skeletal muscle with specific focus on black belt essays, pro-angiogenic and review contest, angiostatic factors Read more. 26 February 2013, 13:00. Gözde Gürdeniz is defending her PhD thesis: Data Handling Strategies in belt, Nutritional Metabolomics illustrated using metabolic states and trans -fat exposures Read more. 22 January 2013, 10:00. PhD defence - Mahdi Mohammadi-nezhad. Mahdi Mohammadi-nezhad is defending his PhD thesis: Exercise impact on depressed patients’ self: The impact of exercise on physical self-perception and self-esteem of outpatients with depressive disorders in Denmark Read more.

18 January 2013, 10:00. Nicole Thualagant is defending her PhD thesis: Fitness Doping and Body Management. An Explorative Study of Body Investment Practices Read more. 26 November 2012, 14:00. Pia Christensen is sat perfect essay, defending her PhD thesis: Efficacy and Safety of Low Energy Diets in essays, the Treatment of Older Obese Individuals Read more. 22 November 2012, 14:00. Thomas P. Gunnarsson is defending his PhD thesis: Effects of intensified training on of nuclear, muscle ion transport proteins and kinetics in relation to black essays, fatigue development and migration and the, performance of endurance athletes and black belt essays for karate, soccer players Read more. 12 October 2012, 14:00. Lars Klingenberg is defending his PhD thesis: Acute Effects of Insufficient Sleep on sat perfect, Energy Balance Read more.

20 September 2012, 14:30. PhD defence - Christian Kirkegaard Pehmoller. Christian Kirkegaard Pehmøller is defending his PhD thesis: Regulation of TBC1D1 and TBC1D4 in skeletal muscle From mouse to man Read more. PhD defence - Sarah Fredsted Villadsen. Sarah Fredsted Villadsen is black, defending her PhD thesis: Strategic perspectives on of life a review essay, antenatal care. Development of a participatory antenatal care strengthening intervention in Jimma, Ethiopia Read more. PhD defence - Daniel Faurholt-Jepsen.

Daniel Faurholt-Jepsen is defending his PhD thesis: The Double Burden. The role of diabetes for tuberculosis risk, manifestations, treatment outcomes and survival Read more. 5 July 2012, 13:00. Brynjulf Mortensen is defending her PhD thesis: The impact of the intrauterine environment, exercise and physical inactivity on the skeletal muscle AMPK system and downstream targets Read more. 25 June 2012, 14:30. Tue Hvass Petersen is defending his PhD-thesis - Development of belt essays for karate, Neural Control of essay writing free, Human Gait Read more. 3 May 2012, 13:00. PhD defence - Mette Landau Brab?k Christiansen.

Mette Landau Brabæk Christiansen is defending her PhD thesis: Regulation of lipid metabolism in skeletal muscle - Insights from human cell culture and rodent models Read more. 16 March 2012, 12:30. PhD defence - Jonas Moller Kristensen. Jonas Møller Kristensen is black belt for karate, defending his PhD-thesis - Role of culture russian tekstura, metformin in regulation of AMPK activation, glucose uptake and mitochondrial function in skeletal muscle and adipose tissue Read more. Department of Nutrition, Exercise and Sports.

PhD thesis published in Danish by Department of Nutrition, Exercise and belt essays for karate, Sports, University of Copenhagen.

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Картинки по запросу black belt essays for karate

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Can the Chain of Causation ever be broken in cases of Manslaughter? The simple maxim that the accused in a criminal proceeding ought to have caused the crime is one of the potentially most important doctrines in law. It has a direct bearing on the entire scope of the criminal law and speaks fundamentally to how we view our society. The proximity between cause and effect that we consider to bring rise to a positive moral duty of care , when we refer to the imposition of punitive sanctions on members of black essays, society, is review dissertation essay contest, one of the black most important tests of criminality. Those areas in on disadvantages, the penumbrary cause the most difficulty for judges, academics and society in black belt, generally. Therefore the prosecution of drug dealers for the death of those they supply , doctors who were negligent and expository school, contribute to the death of their patients , Reckless transmission of HIV / Aids to sexual partners or the denial of access to life-saving treatment are all areas where the person being accused of the black essays crime may or may not be considered to have ‘caused’ the harm. Tekstura? The quotation above by Seneca represents one of the key difficulties in establishing a chain of causation from the accused to the victim of essays for karate, any crime. In English law omission to act cannot be considered the cause of a crime because there is not the causal link; however there is an undoubted argument that someone who refuses to help upon seeing a crime is encouraging that action. The main focus of the work is whether, if ever, the sat perfect essay chain of causation can be broken in cases of manslaughter , this attribute alone would be sufficient to make it generic.

The work starts with a section on the general principle of causation in criminal law. We will then move onto have an in depth discussion and analysis concerning the black belt essays for karate case law on the issue before finally using the sat perfect other jurisdictions and areas of law to compare to the application of the test in manslaughter. This is an incredibly vast subject matter and the restriction to consideration of essays for karate, manslaughter is hoped to essay of nuclear family give the essay more poignancy and give a more holistic understanding to the operation of causation from which we maybe able to extrapolate general principles about causation. Belt Essays For Karate? The main focus will be on the drug supply cases and essay for middle, their impact on the principles of essays for karate, causation . Causation is an extremely important part of the Actus Reus in result crimes. The failure of the prosecutor to establish causation is disastrous to a case because ‘if the death, damage or destruction occurred because of expository format for middle school, some other cause then the offence has not been committed even though all the other elements of the actus reus are present and the accused had the necessary mens rea’ However, it is far from black belt a simplistic concept of deciding that the action caused the result. The concept of causation represents a nexus between fact and law, they are at certain points clearly distinguishable and at expository school, others not. This work cannot possibly hope to do justice to the complexity and history of the concept of causation however the aim is to give a general overview of the concept so that we have a working understanding when we go onto consider the case law on manslaughter . The first principle that the law requires of the facts is that an act will only black belt essays for karate, be considered the of nuclear cause of an essays event if it is a ‘causa sine qua non’ . In other words this is essay writing help free, a test that requires the black belt essays for karate cause to be material; ‘it must be established that the consequence would not have occurred as and when it did not ‘but for’ the accused’s conduct’ . This principle is consequently referred to as the ‘but for’ or ‘sine qua non’ test.

The natural justice of this principle is clear but it is not simple necessarily to apply. At a conceptual level there is difficulty with the fact that the decision-maker has to decide between the ‘infinite number of prior conditions of which it is true that if it had not occurred some given event would not have occurred’ . This can be a tricky situation especially if we consider the penumbrary examples mentioned in the introduction. The death of somebody from a drugs overdose has numerous prior conditions but the two obviously competing ones would be the supply of review of metaphysics dissertation, drugs by belt essays for karate a dealer and the voluntary act of the deceased to take the essay writing help free drugs, they are both events but for black for karate which the person would not be dead. The choice of russian tekstura visual, these prior conditions as a ‘cause’ of the death is artificial, in reality both and many more are the cause including the friends the person made, family life, wealth, mental health and black belt, attitude to risk-taking. This is why the sine qua non test is migration and the quality of life a review essay, considered to belt essays be the purely factual element of writing help free, causation because once a decision-maker goes beyond these considerations they begin to make legal and policy judgements about which causes merit moral opprobrium. Black Belt? Hart Honore commented on this duality within causation: ‘These two aspects of causation, even if they cannot be crudely opposed as ‘factual’ and ‘non-factual’, are of very different character.

They occasion different kinds of doubts and difficulties, and different kinds of criteria are used in their resolution’ The classic example of the application of the migration and the quality of life a review sine qua non test is R v. White where a man had put cyanide in his mother’s drink, when his mother’s corpse was found the glass had not been fully drunk; evidence proved that she had died of black belt for karate, a heart attack. The accused was acquitted of murder because his mother’s death was not contingent upon essay for middle, the cyanide drink and would have occurred in belt, any case. The sine qua non test is conceptually and legally restricted so as to make it practical and equitable and it is these concerns that we need to turn our attention towards. In understanding the sat perfect essay various impinging concerns we need to have a deeper understanding of cause and effect as it is understood in the legal sense. The cause of something has to be ‘sufficient to bring about the consequences in conjunction with other ‘mere conditions’’ and furthermore a cause ought to be necessary.

However the ‘condition sine qua non’ doesn’t always embody these ideals and we can start to get into difficulty quickly if we do not pay attention to the fact that there are many situations where the test is satisfied but ‘the connection between X and black for karate, Y has nothing to do with any form of and the quality a review essay, causal connection even in the broadest sense of causal’ . The obvious example given by Hart Honore is that it is analytically true to state that a person would not be a widow if they had not been married but there is no factual connection between the marriage and her status as a widow. There is furthermore an intuitive distinction which we must be careful of distinguishing between facts which are causally related to the outcome and those which only black essays, serve to individuate the particular act in question. This will become even more important when we begin to consider cases of manslaughter which make a distinction between harm caused by an illegal act and those caused by a legal act. There is a tendency in dealing with causation issues here to blur the issues and argue that there must be a causal link between the wrongful act and the harm caused but in a situation where a person who is driving without a licence hits someone and injures them the fact of not holding a licence is essay, merely incidental to the harm caused. One final conceptual issue to remember is that most writers present the sine qua non test as the sole factual issue of causation, this doctrine is however not the only factual doctrine and black belt for karate, there are allowances for other approaches.

The inherent vagueness of the review essay sine qua non test means that there will be situations where the rule will not give a nice neat factual answer. It is perhaps correct therefore to endorse the approach that Ormerod has outlined and black, state that ‘The ‘but for’ principle is a starting point in the causation inquiry, but nothing more’ . As I mentioned above the duality of causation requires us to give consideration to the more complex and inherently more difficult legal side of causation. The first legal causation issue is essay on disadvantages family, that of culpability. The case of R v. Dalloway is the landmark case on this issue where it was established that if the culpable behaviour of the accused in black essays for karate, no way contributed to the result then the chain of causation would be broken. In that case a child was killed when he ran in front of a cart being driven by D, it so happened that the driver had not been holding onto tekstura visual, the reins. The accused was acquitted on the basis that even had the driver been holding the black reins he wouldn’t have had time to stop, thus the negligent act had not legally caused the death of the child.

In other words the causal link between an action and its consequence will not be assumed simply because there was a negligent act. The culpable act must have a degree of substantiality as a cause of death, the determination of essay format, this is for the judiciary and it certainly seems to be construed narrowly as was stated by Goff LJ in R v. Black Belt For Karate? Pagett ‘the accused’s act need not be the review of metaphysics sole cause, or even the main, of the victim’s death, it being enough that his act contributed significantly to that result’. The distinction between a minimal contribution and a significant contribution has no technical meaning and in most violent criminal cases it will be what the ‘twelve men and women sitting as a jury in the jury box would regard in essays for karate, a common-sense way as the cause’ . Review Of Metaphysics Contest? In Adams, where Devlin J stated that approach, he was discussing the issue in relation to a doctor administering his terminally ill patient with pain relieving drugs. This illustrates the distinction between a minimal and major contribution very well. Essays? If the administration of drugs was considered part of a doctors duty which had the incidental effect of shortening life then this was not murder however if it was considered to be an intentional attempt to end the life of the patient then it was a substantially intervening fact so as to be considered the cause of death.

Related to this distinction is the clear line of cases which has established that the negligence of of metaphysics dissertation, third parties doesn’t necessarily abrogate or dilute the liability of the accused. This flows naturally from the Pagett dicta that the accused’s act need not be the sole cause of essays for karate, any particular harm. In R v. Benge there was evidence that there was negligence over essay contest and above the black accused’s which had contributed to a train accident. In that case Pigott B had directed the jury that ‘if D’s conduct mainly or substantially caused the accident it mattered not that it might have been avoided if the others had not been negligent’ . The flipside of this approach is what is known as the Novus Actus Interveniens doctrine which is where the act of culture russian, a third party is ‘significant enough to acquire causative potency for itself’ . The border between the intervention of third parties being significant or not is sometimes incredibly difficult to demarcate to any great extent but the effect of an intervening act is to break the chain of causation. The easiest to identify as a novus actus interveniens is an ‘Act of God’ which is understood to have to be something occurring in nature which is random and unpredictable. There are various hypothetical situations given in the literature but the black essays distinction seems clear; if the natural event is foreseeable then it will not be considered to be an act of god: ‘the phrase is usually used in context of essay russian tekstura visual, very extreme climatic conditions, it can also be used to cover the equally unpredictable and unforeseeable operation of essays, animate forces, such as the rate which gnawed a hole in the cistern in Carstairs v Taylor (1870) LR 6 Ex 217’ The examples given in the literature show this distinction for example, if a man is assaulted and knocked unconscious then the situation can make a big difference. It is foreseeable that if it were on a beach then it is reasonably foreseeable he may die with high tide. However if it were in a building it is not reasonably foreseeable that an earthquake might occur causing the building to on disadvantages of nuclear family collapse and kill the person in belt for karate, question.

Aside from these situations it becomes more difficult to identify a novus actus interveniens when they are in the form of a third party. Goff LJ cited Hart Honore in Pagett when they stated ‘The criterion which they [Hart Honore] suggest should be applied in such circumstances is russian tekstura, whether the intervention is voluntary, i.e. whether it is free, deliberate and informed’. The court felt that this was the black belt correct approach to be taken to the situation. Review Contest? This automatically rules out innocent agents being forced by third parties, involuntary actions caused by a shock and acts done by ‘a police officer in the execution of his duty acts to prevent a crime, or to apprehend a person suspected of a crime’ . Essays? All of the above do not break the chain of causation, thus it is only in the very narrow category of a novus actus which is ‘free, deliberate and informed’. The cases on this issue cover a very wide area and discussion of the issues raised in essay format for middle school, those cases could form a piece of work on black belt their own right. However a brief outline of the issues raised is necessary; this work is primarily concerned with whether the chain of causation can ever be broken in cases of sat perfect, manslaughter. An understanding of this issue is fundamental for a comparative approach. For Karate? I will talk briefly about the various categories that have considered the intervention of third parties: • Negligent Medical Treatment. The issue of essay help, negligent medical treatment is black essays for karate, one that has occupied the courts attention on a number of occasions.

There are ancient authorities such as James Williamson where it was stated that ‘unskilful and tekstura visual, unjudicious treatement’ of a ‘simple and early cured wound’ . This was followed in modern times in the seminal case of R v. Jordan where a doctor’s negligence was held as sufficient grounds for the overturning of a conviction. The problem is that the court specifically declined to black belt essays make any comment about how this decision was grounded in migration and the quality of life, principles of causation. Furthermore in the case of R v. Smith negligent medical treatment wasn’t held as a novus actus interveniens. The distinction between the authorities is ambiguous . The most recent authority on black for karate the issue is the case of R v. Sat Perfect Essay? Cheshire where the court seems to black have significantly narrowed the operation of this doctrine, here the deceased was shot in the leg and suffered ensuing respiratory problems. This required a tracheotomy to be performed. The death occurred because of complications with the tracheotomy due to medical negligence, this occurred some 2 months after the shooting.

The court held that the gunshot was the cause of death and thus the accused was convicted. The rationale of the court was based on the fact that only the most extraordinary and unusual case would suffice and they argued ‘treatment which falls short of the standard expected of the competent medical practitioner is essay, unfortunately only too frequent in human experience for it to be considered abnormal’ . This is more in line with the authorities such as R v. Holland and essays for karate, Flynn where the refusal of a patient to receive treatment that exacerbates a minor injury will not constitute a novus actus interveniens. • Thin Skull Rule. It is clear from the authorities that where the victim has some pre-existent condition then this will not excuse the accused: ‘It would never do for it to go forth from this court that house-breakers or robbersshould be entitled to lay violent hands on very old or very sick or very young people, and, if their victim died as a result, to turn around and say that they would never have died if they had not been very weak or very old’ This is essay on disadvantages of nuclear family, a fundamental rule and obviously will not count as a novus actus. The previous two categories are examples of when the law has held that third parties do not intervene on the chain of causation. This is indicative of an extremely strict approach to issues of causation, they do not allow potentially large supervening factors to get in the away and if you were cynical then it would be tempting to black belt essays for karate state that consequences simply cannot be too remote from the culpable act. Essay Family? Only in belt essays, a situation such as R v. White can the chain really be broken and those situations have got to be truly extraordinary. Current Case Law on Manslaughter Chain of Causation. We now turn to consider the specific subject matter of culture essay russian tekstura visual, this work which is the chain of belt essays for karate, causation as it is applied in cases of manslaughter.

The major issue in this section will be focused on migration and the the penumbrary issues of manslaughter. Belt Essays? Undoubtedly in core cases the principles of causation sit nicely with the facts. The major issue of interest are areas such as prosecution of drug suppliers where the principles of causation are stretched to their limit and format, open to no small amount of criticism. The first issue is just to briefly recap what exactly the crime of manslaughter is and how it is distinct from murder. The nature of the crime can often have effect on the way principles of causation are applied.

Manslaughter is an offence which covers a vast area only belt for karate, ‘limited in scopeby murder at one extreme and accidental killings at the other’ . There are two forms of manslaughter; voluntary and involuntary, in the latter the person has the mens rea for murder but there is some mitigating circumstances which reduce the crime to manslaughter. Voluntary manslaughter was put into statutory form by dissertation essay contest the Homicide Act 1957 and black essays for karate, now only occurs in three defined situations: provocation, diminished responsibility and a suicide pact. Involuntary manslaughter covers a vast area such as negligence, recklessness and unlawful or dangerous acts. This means that the scope of the crime is far from distinct; issues of causation are thus inevitably raised in cases of involuntary manslaughter where the thing that caused death may have a remote link to the accused in the particular case. The linking of a criminal act to essay help death can be fraught with difficulty as can the difficulty of intervening acts. It is clear that the chain of causation can theoretically be broken in manslaughter, both the authorities and the case law agree on this issue. However, there have been a series of belt essays, cases over the 30 years regarding manslaughter which seem to imply that the chain of causation may not be able to be broken even by migration quality of life essay the voluntary intervention of third parties; the chain of causation may not be possible to belt break. In Cato the accused was charged with the expository essay format manslaughter of a man called Kennedy. Black Essays For Karate? The facts were that Kennedy had brought the drugs with him to a house, him and Cato had paired off and taken turn to inject each other with heroin throughout the night.

Kennedy was found to have died the next morning as a result of the overdose. One of the other important factors was that each party had made up the syringe with the requisite mix of heroin and water themselves and thus the partner was merely injecting the drugs. The accused was convicted of manslaughter by essay an unlawful and black for karate, dangerous act which requires proof of the basic act which was criminal. In this case it was held that heroin was a ‘noxious thing’ as understood under s.23 of the Offences Against the Person Act 1861 and that this base crime was sufficient to establish manslaughter. In the case there were a number of issues that revolved around causation and the interplay between legal and factual causation was nowhere better illustrated. In this case causation in review dissertation essay, the strictest sense was not really an black belt issue. There was an attempted argument on appeal that it had not been proved satisfactorily that it was heroin that had caused death but on the evidence this was rejected. The really interesting issues were sidestepped in this case because per se under the Misuse of Drugs Act 1971 the actions of Cato was an offence. The dubious judicial chicanery of using s.23 of the Offences Against the Person Act 1861 aside the expository format question sidestepped the issue of whether consent would have broken the chain of causation in a charge of manslaughter by black essays gross negligence or recklessness, Lord Widgery in Cato specifically stated that the argument was not pertinent, he went as far as to review of metaphysics dissertation essay contest say that they would have used unlawful possession as a substitute to s.23. This is obviously damaging to principles of causation in that actual possession cannot be considered to have caused the death, it would be one of these incidental factors that we have discussed in the previous section . Furthermore the case law under the Misuse of Drugs Act 1971 precludes any alternative such as supply of drugs interpretation: R v. Maginnis and black belt, R v. Harris , both on similar factual circumstances to Cato, found that it would be a farcical situation that where a person was merely insisting with the injection that it couldn’t be considered supply. It would seem to make sense, given the Pagett test of essay russian tekstura visual, a ‘free, deliberate and informed’, that the essays for karate consent of the person would constitute a novus actus to break the chain of causation.

However, this issue of the supply or administration of drugs has come before the courts on numerous occasions since Cato and we can derive a number of lessons from these cases about the expository essay format school operation of causation in cases of manslaughter however it has to be argued that the logic in Cato ‘seems to stretch credulity’ . The rationale that seemed obvious to essays for karate many commentators after Cato was upheld in R v. Dalby . Essay? On appeal the court came to consider whether someone who supplied a person with drugs was liable for manslaughter when the victim went onto make up the solution and inject themselves. The court decided that ‘Where the charge of manslaughter is based on an unlawful and dangerous act, it must be an act directed at the victim and likely to black essays for karate cause immediate injury’ . The major criticism of this judgement was that it wasn’t couched in terms of causation but made it very unclear what the basis for stating that an act not directed at the victim could not form the basis of a manslaughter by unlawful and dangerous act. Common sense seems to imply that it is the migration and the lack of causal relationship but this was not endorsed by the court. The requirement for an act to be ‘directed at the victim’ was considered to be incorrect in the later case A-G's Reference (No 3 of 1994) . Belt For Karate? However, the fundamental criterion that meant a supplier was not liable for manslaughter was considered to be the essay help likelihood to cause immediate injury. This makes it a causational issue. The fact that it is black belt for karate, a causational issue and essay, the correctness of the approach in black essays, R v. On Disadvantages? Dalby have been divisive issues which have been treated with a lack of coherence in subsequent case law on the issue. The case of R v. Armstrong considered whether or not it was manslaughter when the accused supplied the belt essays for karate victim with heroin and the means by which to mix and inject it. The court overruled the essay initial conviction on two grounds; there wasn’t sufficient evidence that the heroin was a major cause of death i.e. it fell foul of the de minimis principle and more importantly that the voluntary act of taking the drugs constituted a novus actus interveniens and consequently broke the chain of causation. Since this case there has been a great deal of oscillation by the courts on belt the issue. The cases of culture essay russian, Dalby and Armstrong seemed to imply that the voluntary act of the victim was enough to overcome a conviction of manslaughter and importantly was sufficient to black for karate breach the chain of causation. The problem was that Armstrong didn’t deal with the effect of an on disadvantages family unlawful act by the accused and Delby didn’t directly deal with the principles of causation.

It was therefore unclear whether the novus actus interveniens of voluntary injection was sufficient to overcome manslaughter by unlawful and dangerous act, furthermore the question of manslaughter by gross negligence was left completely aside in these cases, however I will discuss this issue in greater detail below. The next case to consider the issues was the much maligned R v. Kennedy which came to consider a different factual circumstance. Black Essays? In Kennedy the facts were such that the defendant had made up the mixture in the same room as the victim, handed him one of two syringes made up by himself and left the room. Prima facie this is incredibly similar to the facts of Armstrong and Dalby however the court in Kennedy managed to come up with a conclusion that, according to Heaton, would ‘have been a cause for embarrassment for any competent law student’ . Here, they drew a distinction, relying on Cato, that the defendant had ‘assisted or encouraged Bosque to inject himself with the mixture of heroin and water’ . They furthermore on the issue of causation came to the conclusion, based on the dicta of Goff LJ in Pagett, that the chain of review, causation was not broken because the appellant could be considered ‘jointly responsible for the carrying out of that act’. This imported a completely novel concept that appeared to belt for karate be some form of accessorial liability by assisting another commit a crime. The inconsistencies of this decision with basic causation principles and culture essay visual, the other case law have lead to belt for karate fairly universal condemnation. Primarily they failed to make adequate distinction between the sine qua non test and a novus actus interveniens, they seemed to assume that if the sine qua non test was satisfied then this somehow circumvented the voluntary injection of the drugs by the victim. Essay Format School? The legal argumentation was also completely flawed in that case because the victim hadn’t in himself been committing a crime so the defendant couldn’t have been art and part guilty of assisting him and even more forcefully a person cannot commit manslaughter on himself so the accused cannot be accessorially liable for that manslaughter. Furthermore, the rationale of dangerousness in Kennedy and the distinction from Dalby that the court made are not supported when we consider the dicta in the latter case that we mentioned above about ‘immediate harm’. It also doesn’t square with general principles of causation concerning the kind of ‘dangerous’ behaviour that ought to be exhibited. In the for karate cases of R v. Watson and R v. Dawson the courts accepted that if the act’s danger was contingent on natural conditions such as frailty then the chain of causation could be broken.

Thus in both cases there were robberies, in Watson the sat perfect essay victim was an old man but in Dawson the victim was seemingly healthy. In both cases the victims suffered heart attacks but the courts held the dangerousness of the act was only black belt for karate, established in Watson because the harm was foreseeable. It is at least arguable when we consider the fact that given Heroine can be a safe drug when taken in the correct quantities and with knowledge of the particular person’s tolerance level that there would have been no way the defendant’s actions could be considered dangerous. This aside the court in Kennedy made no reference to Armstrong, however it might be possible to of nuclear cynically distinguish the two on the basis that the accused in Armstrong couldn’t be bothered to black essays for karate make up the mixture and left it to the victim however in Kennedy he was the essay on disadvantages one who did the preparation. Kennedy’s rationale was never very clear and more recent judgements have even further complicated the issues by attempting to distance themselves from the dicta of that case whilst still achieving the same result. It seemed that lucidity had been achieved when the decision in R v. Dias was handed down by the court of appeal; on facts almost identical to Kennedy the court quashed the conviction of manslaughter. The court distanced itself from Kennedy and elaborated the conceptual difficulty with that court’s approach very well. Black Essays? Primarily, the injection of drugs was not an offence so the accused could not be considered to have been guilty of this by accessorial liability. Separately, the issue of causation cannot be made out as between the illegal supply of drugs and the death of the accused because of the voluntary actions of the victim. And finally the review dissertation essay contest main crux of confusion in Kennedy was highlighted from this point: ‘It follows from that that the appellant could only have been guilty of manslaughter as a secondary party and not as a principal.

But in that case who is the principal guilty of manslaughter? As there is no offence of self-manslaughter, it is difficult to see how the appellant could be guilty of belt for karate, that offence as a secondary party because of his encouragement or assistance to essay on disadvantages Escott over belt essays the injection of the drug’ The decision in Dias amply highlighted the difficulties the courts had been struggling with because of conflation of causation with the unlawful act itself. The failure to realise that accessorial liability to manslaughter where the principal was the victim made no logical sense was at of metaphysics essay, the heart of this confusion. It appeared as though trial judges had accepted that supply couldn’t be the cause of death and black belt, embarked upon reverse logic. They assumed that if they found a crime that could be considered to have caused the death then manslaughter could be established. This is to make a fundamental mistake about manslaughter by unlawful and dangerous act, the essay first step is to establish that an unlawful act has occurred and then to see whether that act caused the death. Given that this was the problem it is reasonable to see why the court in black belt essays for karate, Dias left the door open when they hinted that there could be certain situations where a Manslaughter by Gross Negligence may be able to be established when a duty of essay for middle school, care may arise. The main issue is just always to bear the distinction between causation and the unlawful act separately.

There was by this point a growing corpus of decisions in the form of Dalby, Armstrong and Dias with obiter support from Cato that the supply of drugs could not be considered manslaughter however the decisions in R. v Finlay and R. v Rogers have ‘muddied the waters’ . In Rogers the accused had held the tourniquet whilst the victim injected himself. Black Belt Essays? The victim had procured the drugs himself, injected the accused and then the accused had assisted the victim inject himself by holding the tourniquet. He was convicted of manslaughter by unlawful and dangerous act, the court relying s.23 of the Offences Against the Person Act 1861. The court distinguished Dias in that it was considered these actions fell within the remit of ‘administering’ the expository essay for middle school drug. Black For Karate? Like in Cato the court were obviously using a real stretch of logic. It was clear that ‘administer’ in the sense meant by the OAPA 1861 did not envision this kind of interpretation and has subsequently been criticized.

However, the case of Finlay was a blatant attempt at judicial chicanery to circumvent the line of authority ending with Dias. The facts were identical to expository for middle Kennedy and black for karate, Dias but the result was different. Help? They re-established the black essays for karate chain of causation between the supplier of drugs and the victim by relying on s.23 of the OAPA 1861 where it states ‘Whosoever shall unlawfully and maliciously administer to or cause to be administered’ The court used the famous case of Environment Agency v Empress Car Company to establish that in help free, fact the chain of causation could not be broken by the voluntary act of the victim as a novus actus interveniens when that action would be an black belt essays for karate ‘ordinary occurrence’ as opposed to an ‘extraordinary’ occurrence . The court in Finlay felt that the voluntary injection was an ordinary event and would not break the chain of causation, thus the voluntary nature was just a factor to be taken into consideration. The court confusingly relied on the idea of ‘joint principalship’ drawing on Rogers however it is extremely difficult to essay see how this escapes the problems identified above. The victim and the accused cannot be joint principals in an s.23 offence and also cannot be joint principals in belt essays, manslaughter. In both of these cases there is a requirement of a third party. Tekstura Visual? Furthermore the use of Empress Cars as authority is extremely dubious given that the case is also one which is subject to a high degree of criticism. The decision has been described as ‘perverse’ , ‘heresy’ , ‘aberrant’ and belt for karate, ‘bad principle, bad law, bad reasoning’ . The decision in Empress Cars was based on pollution and migration and the quality of life, the holding of someone responsible as causing the effect because the act which did it was not so extraordinary as to be unforeseeable. Black Belt For Karate? The decision in Finlay was simply terrible because it took one maligned case and applied the incredibly dubious logic to a separate set of factual circumstances. The latest case is unfortunately also to be lamented because it has once again moved in a different direction in order to achieve the same effect as Finlay, Kennedy and Rogers. This involved the second appeal of Kennedy to the court of appeal . In Kennedy (No2) the court impliedly rejected the Finlay approach and rejected the help free Empress Cars logic.

Instead the court fabricated a completely new doctrine of ‘joint participation’ which completely sidesteps the issue and seems to imply that causational issues are irrelevant . The court argued that in situations such as Kennedy the accused can be considered to be acting in black belt, concert with the russian victim to commit an offence under s.23 OAPA 1861. This seems prima facie to ignore the fact that a s.23 offence requires a third party, a ‘other person’ , the question of how the victim and the accused can act in belt essays for karate, concert to commit a s.23 OAPA 1861 is tautologous and amounts to essay on disadvantages the same argument in Kennedy. The whole decision tries to sidestep causation. The court is fully aware if it can establish an s.23 OAPA 1861 then it can establish causation in black, the natural manner. However, it has been unable to convincingly do this in review contest, the case where the accused merely supplies the victim. The reliance on joint participation cannot resolve the problems created by essays the drug supply question for two very important reasons that Ormerod Fortston identify: Primarily, the court in Kennedy (No2) recognised an review dissertation contest accused cannot be held liable as a secondary party for the reasons explained in Dias. However principles of secondary liability require that one person is the principal and one the belt secondary, thus when acting in a team both parties cannot be liable both as principles or if they can then the sat perfect court in essays, Kennedy (No2) has rewritten the principles of secondary liability without telling anyone.

Secondarily, the use of ‘Joint Participation’ would be unjust in many situations if taken to its logical extreme. Tekstura Visual? Ormerod Fortston give a specific example here: D who supplies the bullets for P's gun for him to murder V now becomes a murderer as a principal, not as an accessory. This undermines the principles of secondary liability in as fundamental a way as did the belt essays ruling in Kennedy (No.1)’ The clear message from the case law is that the judiciary seem willing to essay on disadvantages of nuclear convict at black, any cost no matter the damage to principles of causation and migration quality, the general criminal law.

The application of the black essays for karate law in these cases is incoherent and from Kennedy (No1) to Kennedy (No2) we have heard four different justifications all completely flawed. The chain of causation in these cases is continually held not to be severed by the seeming novus actus interveniens of voluntary injection but the rationale for essay on disadvantages of nuclear family this is very unclear. It is clear however from other case law on unlawful act manslaughter that the drug cases are not consonant with other principles of causation. Essays? In R v. Williams the court talked about the voluntary act by a third party on the chain of causation and stated that the voluntary act had to be ‘within the ambit of reasonableness and not so daft as to make it his own voluntary act which amounted to a novus actus interveniens and consequently broke the help free chain of causation’. Black Essays For Karate? This was dealing with cases where the victim was threatened and then did some act which caused his death; the key thing for these cases is that the voluntary act by the accused had to exhibit rationality. If the facts of the case indicated that the victim was being irrational then the accused couldn’t not be said to have caused the death. The rationale of the drugs cases is to completely circumvent questions of causation by attempting to say that the voluntary act of injection was somehow overcome. The principle of novus actus interveniens when the victim or another person makes a ‘free, deliberate and informed’ decision is one of the most important concepts of causation. The drugs and manslaughter cases have ridden rough shod over these principals. In cases involving manslaughter the essay russian prosecution always has open to them to attempt a prosecute under the belt idea of ‘recklessness’ or ‘gross negligence’.

The issues of essay of nuclear, causation are also pertinent here and given the speculative nature of the black for karate crime the chain of causation can sometimes be difficult to establish. However, for our purposes we will want to consider the principles as they potentially apply to drug suppliers and other categories where legal causation may be difficult to establish. There was considerable confusion in recent years but the confusion seems to have been settled by the court in R v. Adomako . Sat Perfect Essay? Following that case it is clear the prosecution must establish three criteria: • Must be in breach of the duty of care under established principles of negligence. • The negligence must have caused death. • The action must be considered as ‘gross negligence’

In the drug supply cases it was suggested by black for karate R v. Dias that ‘manslaughter by way of gross negligence may arise if a duty of care can be established’ . Heaton was of the opinion in this case that whilst undoubtedly a duty of care would have existed on essay help free the facts as they had existed in Cato however the finely balanced issues may preclude a finding of ‘gross’ negligence. In cases such as Dalby, Kennedy and Finlay where the essays victim self-injects it is hard to see how this progresses the issue of causation any further. The main problem with drugs cases is that the reasoning is migration a review essay, completely circular and very difficult to grasp without detailed contemplation of black belt for karate, potential analogies. The crucial distinction for the whole case law is between the situation in Cato and those in sat perfect, Kennedy. The difference between those two is that Cato could be considered to have ‘caused’ the death of the victim in that he was the one doing the injecting, the consent of black, a victim is no defence for good reason. Prima Facie in the supply case the intervening voluntary act of the essay writing victim acting in a free deliberate and informed manner would normally break the chain of causation. Black Belt? What the essay russian visual court did in essays, Kennedy (No2) was to leave the law in confusion, especially because they didn’t couch their approach in terms of causation. The problem was amply highlighted by Heaton: ‘An individual, D, might be regarded as a factual cause of the prohibited result where his action combined with others brings about that result. This does not mean on orthodox principles that he will necessarily be held to be a legal cause: his actions may well be treated in law as too remote’

The use of expository format school, joint participation to establish the s.23 OAPA 1861 doesn’t close the causation gap because the supplier still is too remote. The court attempted to belt essays for karate circumvent this inevitability by relying on R v. Latif and others : ‘The free, deliberate and informed intervention of a second person, who intends to a review essay exploit the situation created by the first, but is not acting in concert with him is held to relieve the first actor of criminal responsibility’ Thus causation becomes reliant on the perception of ‘acting in concert’ however this causes a beehive of problems. Whilst they maybe acting in concert how does this create an black unlawful act? S.23 was clearly instituted for the ‘protection of the essay person to whom the substance is administered ’ and thus surely they cannot act in black belt essays for karate, concert to commit a crime that only one of them can commit. The court seems to culture russian tekstura visual have made a mistake here and conflated legal causation with factual causation, they seem to think that Cato has created authority that if you can establish administration then automatically causation is established. It is clear that this is not the case however the court in Kennedy wants to shift the legal basis the facts remain the same there was not a traditional causational link. The basic answer to whether the chain of causation can be broken in cases of black belt, manslaughter is that theoretically and it has been broken in numerous cases. Culture Essay Russian? However, the logic and approach of the courts in the drug supply cases threatens to undermine all these principles. 2: Comparison to other areas of Criminal Law.

The decisions in Empress Cars and black belt, the drug supply cases have been heavily criticised as having caused ‘a revolution within the field of criminal causation’ . It is primarily because in Empress and the drug supply cases they have completely disregarded the novus actus interveniens of a third party’s voluntary actions. Essay On Disadvantages Of Nuclear? The chain of causation can only really be broken by a limited number of defined cases as we discussed in the first section these are roughly stated, failure to be a sine qua non or failure to establish an intervening act between the cause and effect. The removal of the for karate voluntary action intervention distorts these principles and of metaphysics essay, if taken to belt essays its logical extreme could cause serious defects in criminal causation. Review Essay? However, the principles of causation, as traditionally understood always seem to find the ‘best illustrations supporting the thesisin cases other than homicide’ , this is undoubtedly an accurate description. The interesting thing about essays for karate, this area of law is that whilst there are plenty of academic authorities to the fact that ‘The novus actus rule is of fundamental importance’ it is particularly difficult to find cases other than the ones we have mentioned already where the review of metaphysics dissertation essay contest court has upheld a novus actus. However, one of the main justifications for the existence of the rules on causation is the distinction in criminal law between principal and accessory ; it is in these cases that we are able to black belt essays for karate find dicta which are at odds with the approach in the drugs supply cases. The whole basis of accessorial liability is based on the fact that the accused didn’t in migration a review, fact cause the harm, in fact he may have had absolutely no intention to commit the crime but he can still be an accessory to belt essays for karate the crime. Thus take the famous case of R v. Bainbridge as an example of migration quality a review essay, why the logic of causation is heinously wrong in the drug cases. In Bainbridge the accused sold oxygen-cutting equipment to black another person, that person in turn broke into a bank and stole £18,000.

The accused was convicted as an tekstura visual accessory to the theft. Here we have analogous facts to the drugs supply cases, if we leave aside the fact that the third party did in fact commit an offence in this case. One cannot be accessory to theft where there are only belt essays for karate, two parties. For example if the third party had taken the oxygen-cutting machine and broken into his own house and ‘stolen’ £18,000 then no offence is sat perfect, committed by the accused. However it maybe that the accused is essays, guilty of an offence such as supplying the oxygen-cutting machine without a licence. The problem is that in this case there is no extra element such as in a homicide which is an essay writing unlawful act resulting in death.

Therefore lets say when the third party is black belt, using the oxygen-cutting machine breaking into his own house he cuts himself, there is expository format school, no crime of black belt, self-injury but there is one of writing help free, assault. Using the logic in black belt essays for karate, Kennedy (No 2) the accused and the third party could somehow be ‘joint participants’ in causing an assault on the third party. This obviously makes absolutely no sense and would be completely ridiculous. Thus the approach taken in the manslaughter cases doesn’t sit easily with principles of accessorial liability because as I have argued above legal causation seems to have taken precedence over factual causation which means that establishment of who is the principal and the accessory become questions of legal construction as well as fact. The rest of the migration and the a review essay criminal law of result crimes however shows a distinct pre-occupation with voluntary actions, thus there have been plenty of black essays, cases such as R v. Writing Help Free? Hanson where the accused was the original thrower of a squib which then was thrown away by the intended target and caused injury to a third party. The fact that the throwing of the target was not voluntary meant that it couldn’t break the black for karate chain of causation. In the cases surrounding Assault occasioning actual bodily harm we can see the causation element become of great importance.

In R v. Roberts the assault was an attempt to remove a woman’s coat which occasioned her to jump out of a car and sustain injury. The court again upheld the dicta that the on disadvantages of nuclear action had to be so unreasonable or irrational that it was unforeseeable. The clear theme arising from these cases is that the voluntary action of a victim must be caused by the criminal act of the accused. This can be established in these ‘escape’ cases such as Roberts because the facts bear out belt for karate that it was the cause, however it is clear in drug supply questions the implied assertion and on disadvantages family, the one accepted in Dias is that the supplier cannot be said to cause the essays for karate death. The foreseeability issue that Finlay raised was taken in the wrong context, it is clear the stressed mindset of the victim was what made the harm foreseeable. It is a warning as to why principles of causation ought not to be treated holistically in help, that they are often fact sensitive and can be used as they were in Finlay to distort their intention.

It is arguable that the principles in other result crimes such as assault ought not to be treated as being binding on the approach in manslaughter. We will see that the crime can make a difference to the way causation is established in the next section when we turn to black belt essays for karate look at the approach in other jurisdictions. 3:Comparisons to other Jurisdictions. The issue of the supply of drugs has been raised in a few cases north of the on disadvantages family border and it is interesting to belt essays for karate look at their approach as a comparator. The courts have taken a similar view to the courts in England but based on different grounds. However, the decisions north of the border have consistently found suppliers to review be guilty and that the Novus Actus Interveniens of voluntary behaviour doesn’t break the chain of black belt, causation. In both Khaliq v. HMA and Ulhaq v. Essay Russian Tekstura? HMA the supply of solvents was enough to establish the crime of ‘Culpably and recklessly endangering life and health’.

In Lord Advocate’s Reference (No1 of 1994) the essays for karate court considered a directly analogous case to migration of life those of the drug supply when the accused was charged with the Scots Law equivalent of manslaughter, Culpable Homicide. On Appeal to the High Court after an belt for karate initial acquittal the High Court upheld the views of Khaliq and Ulhaq and specifically stated: ‘The purpose and the intention of the essay supply libelled was that the solvents should be abused, employing the black essays for karate means of abuse provided. The solvents were, it is averred, abused, and this could be regarded as the expected, intended and probable consequence of the culture visual supply’ This knowledge of abuse thus in black belt for karate, Scots Law was held to be vital because the foreseeability of the use meant that the chain of essay, causation was not broken. They argued that the distinction between supply and administration was so negligible where ‘supply is closely related to the use by words of instigation or by some act of instigation on the part of the panel’ . The proximity and foreseeability of use therefore negate the Novus Actus Interveniens on that basis. Belt Essays? The argumentation is more convincing than in sat perfect essay, the English cases although it is submitted this is because of the black belt essays double test requirement of Manslaughter by Unlawful Act. It seems quite clear that the supply of drugs can constitute a murder charge in certain states of help free, America. In particular two cases are pertinent on this issue and these are State of Iowa v. Albertson and Lofthouse v. Commonwealth of Kentucky the courts came to essays consider very similar issues as we have discussed in the cases above. In the latter case the accused was charged with reckless homicide under the Kentucky Penal Code. The courts in Kentucky made a distinction as far as supervening factors were concerned between an ‘independent intervening cause’ and a ‘’dependent intervening cause’.

The latter did not relieve the writing help accused of belt essays, criminal responsibility unless the human act was completely abnormal, the former would relieve unless it was ‘reasonably foreseeable at migration and the quality of life a review, the time of his conduct’ . The issue of causation was thus circumvented on the basis of black essays, foreseeability based on the inherent dangerousness of the drugs: ‘The Commonwealth posits that, as a matter of law, the act of visual, furnishing narcotic drugs to another creates a substantial risk of death to the transferee sufficient to belt convict of either second-degree manslaughter (awareness of and conscious disregard of the risk) or reckless homicide (failure to perceive the risk)’ The test is culture essay russian visual, very similar to the Empress and Finlay approach and the distinction between ordinary and extraordinary occurrence that was made in the latter case, however the main issue here is that whilst foreseeability is the test they have specifically attuned the offence so that the issue of causation is black belt for karate, correctly centred on the foreseeability of the harm resulting from an action. The crime is reckless homicide and the only way the novus actus interveniens can intervene was held to family be, much like our escape cases such as R v. Roberts and R v. Mackie was where the act of the victim was abnormal or completely irrational in the situation. Interestingly the US has completely rejected what was known as the felony murder rule which is defined as: ‘If death ensues as a consequence of the commission of a dangerous felony, the intent to commit the dangerous felony provides the element of intent necessary to black belt for karate convict of the homicide’ The court in Lofthouse discussed the case law surrounding this crime which bears obvious analogies to manslaughter by unlawful and dangerous act. Essay Help? It appears as though the approach has been abandoned in belt essays for karate, Kentucky and other states for a number of reasons. One of the main reasons is that many states have their own statutory crime of homicide caused by the supply of narcotics this includes states such as Connecticut, New Jersey and Florida. However the for middle school use of the felony-murder doctrine is belt essays for karate, identical in most respects to the manslaughter by unlawful and dangerous act, including the attendant difficulties of establish a causal relationship between the felonious conduct and the death. The approach in the seminal case of Heacock v. Commonwealth was too hold that the distribution of cocaine was an inherently dangerous act enough to establish second degree murder under the felony murder rule. It has subsequently been held in numerous cases that the supply of drugs under the felony murder rule will constitute a crime see Ingleton v. State , State v. Whitted and Sheriff, Clark County v. Morris . The South African approach to causation issues seems to be very similar to the one in writing free, this country.

In two particular cases; S v. Belt Essays? Grotjohn and S v. Hibbert the South African Courts fell to consider the effect of the voluntary act of the contest victim on the accused’s liability in homicide cases. Essays? In both these cases the victim had committed suicide but the accused had handed her a gun in a manner where it was very foreseeable that they would shoot themselves., Steyn CJ stated in the case of Grotjohn that the important issue was that the novus actus interveniens be ‘a completely independent act, in the sense that it should be totally unconnected and has no relationship to the act of the perpetrator’ . The cases are not completely analogous because in sat perfect essay, the cases there was an intention or desire to bring about essays for karate, a fatal result and they had a particularly close involvement in the instigation of the actions of the victim. In a situation very similar to Cato the court in essay writing, the New Zealand case of R v. Bennett found that a young man who had injected drugs into his friend at a party was guilty of manslaughter. Continental Approach to black belt essays Causation. In surveying the foregoing case law it becomes apparent that in both Scotland and the U.S.A the law is in migration quality of life, effect much the same as the result in black, Kennedy (No 2). Essay? However, what we see is that both on belt essays the continent and in these other jurisdictions is that undoubtedly any liability is based upon the idea of negligent manslaughter or culpable homicide because death was reasonably foreseeable. In all the jurisdictions the interrelation between foreseeability and causation is essay russian visual, that the causal link can be established by negligence. This is because in those situations the seemingly voluntary action of the black belt essays for karate victim is foreseeable, or ought to be, so the accused is deemed to culture russian tekstura have been aware of the dangers and continued any way. The English approach to the question has seemingly been correct then in embracing the Empress Cars foreseeability test in criminal law. The problem is that this is not really relevant in manslaughter by unlawful and dangerous act.

The act must have caused the death, the foreseeability of the issue isn’t relevant because if the for karate act was unforeseeable then it is established that the chain of causation can still be established (i.e. the person had a thin skull or a rare disorder). However, in other jurisdictions the foreseeability issue goes to negligence not causation and essay of nuclear, this avoids the problems. Black Essays For Karate? In all jurisdictions the supply of drugs is a causa sine qua non however the chain of causation is held not to be broken because the crime is consequent upon negligence by definition whereas the manslaughter cases require a standard causational link between the act and death. This work has concentrated predominantly on essay the drug supply cases in manslaughter; this mirrors the domination that is given to them in all the textbooks and articles on the issue. It is well understood that there are numerous things which could potentially break the chain of causation in black belt essays for karate, manslaughter such as failure to be a causa sine qua non, intervention by an act of and the of life a review, nature, intervention by a third party, it may not be a substantial cause of death. Black Essays For Karate? The intervention of a third party, particularly where that third party is the review dissertation essay victim himself, is a foundational principle of causation and as mentioned above the basis for accessorial liability. The drug supply cases seem to belt essays offend these principles and review essay contest, yet there is a paucity of good authority to contradict their conclusions.

In many ways the conclusions in Kennedy (No 2) defy logical explication, however it is an obvious attempt at black belt for karate, maintaining the policy that drug dealers can be guilty of manslaughter. This principle is recognised both north of the border and in the USA which in turn creates pressure for conformity. However, the detriment to causational principles seems to lie in the fact that it in many respects completely bypasses the operation of culture russian visual, causation. It doesn’t pay attention to the fact that causation is a mixture of fact and black belt, law, the essay writing help free one cannot exist without the other, and furthermore it is black belt, simply not tenable to argue that once de minimis factual cause is established that the review of metaphysics dissertation facts have no effect. Kennedy (No 2) tried to create some kind of belt essays, legal chain of causation, whereby the establishment of ‘administration’ by culture essay tekstura constructing the facts so as to fit into the definition somehow changed the facts from what they were, thus legally all administration causes death where in fact it does. The chain of black for karate, causation can be broken in cases of manslaughter; it is clear from American authorities such as People v. Elder and writing, Smith v. State that where the accused commits a minor crime which is then followed by black belt essays a grossly disproportionate killing by a third party then this will break the chain of causation. However there are virtually no examples in essay family, English law and if we follow the approach under R v. Dear as we discussed above the chain of causation in for karate, cases concerning homicide may be incredibly difficult because even the review of metaphysics dissertation most unreasonable behaviour of the victim in exacerbating an initially trivial harm are not relevant in breaking the chain of causation. It is as well to remember however that this doesn’t necessarily entail a conviction of manslaughter, causation is primarily concerned with the actus reus of a crime and the mens rea may have a very important bearing on the outcome. Allen, Michael Textbook on Criminal Law 2005 / OUP / 8th ed.

Fletcher, George Rethinking Criminal Evidence 2000 / OUP Hart, HLA Causation in the Law 1985 / OUP / 2nd ed. Honore, T McCall Smith, R Scots Criminal Law 1997 / Butterworths / 2nd. Sheldon, D 2nd ed. Ormerod, David Smith Hogan Criminal Law 2005 / OUP / 11th ed. Heaton, Russell Dealing In Death 2003 CLR 497 Principals?

No Principles 2004 CLR 463 Ormerod, D Drug Suppliers As Manslaughterers (Again) 2005 CLR 819. Fortson, R Padfield, N Clean Water And Muddy Causation: Is 1995 CLR 68 Causation A Question Of Law Or Fact, Or Just A Way Of Allocating Blame. Phippen, L Drugs and manslaughter 2005 NLJ 1054. Radlett, D Reed, Alan Involuntary Manslaughter And Assisting 2003 JCL 431. Drug-Abuse Injection Court of Appeal: Causation and Assisting 2005 JCL 384. Drug-abuse Injection Toczek, L Is the supplier also the killer? 2002 NLJ 595 Weait, M Taking the blame: criminal law, social 2001 JSWFL 441. responsibility and the sexual transmission of belt essays, HIV Williams, R Policy And Principle In Drugs Manslaughter Cases 2005 CLJ 66.

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