Quality in Universities Online Learning vs Class Learning - 550 Words

How Online Learning is Conducted and if it is Better than Class Learning (Essay Sample) Content: Quality in universitiesNameInstitutionReview on the quality of tertiary education has become a norm in most countries. The universal address to issues of quality assurance is evident in higher learning education system. The use of ISO standards, cross-national analyses examples of steps taken to ensure the quality and standards met. Governments have helped a great deal in this by calling for improved management practices, use of resources in the assurance of quality and challenging institutions to submit quality audits. University assessment refers to the minimum threshold required to be meet by this institutions. It is essential not only to guide the development of these systems but also to monitor and continuously improve the programs that are in place. University bodies are responsible for quality management through the internal accreditation process and codes of practice. The Australian government department responsible for tertiary education is the department of education. All institutions that want to receive government support must meet quality and accountability standards set in the higher education Act 2003.In 1986, the Commonwealth tertiary education commission published the efficiency and effectiveness in higher education and noted the urgent need for rationalization. From mid-1970 the Australian government through Commonwealth higher education commission (CTEC), introduced (EIP) that is an evaluations and investigation program which promoted assessment of learning in the higher institution. In the mid-1980 various institutions got merged under one unified system of higher education. The majority of these establishments had now gained the university status. In 1986, report on efficiency and effectiveness of tertiary education indicated that this institution had not developed overall standard procedures for systematic self-assessment. A series of the review of the system in these universities began to examine the quality of teaching an d researching techniques across the whole system. In 1991, the federal minister for higher education and employment service of Australia released a paper on quality and diversity which addressed the need for a credible process for quality assurance put into place. (Westerheisden, Stansaker Rosa, 2007) The committee for quality assurance is then established in 1993.It gave institution invitations voluntarily to participate in quality reviews to receive government funding. During the commencing year of the reviewing program, the quality assurance committee took a full approach by mainly viewing three areas of university activity: learning, teaching, and relationship with the community. In the second year, the primary concern was for learning and teaching. In the third was the relationship with the surrounding community. Pending the outcome of these studies institutions received varying funds from the government. Globally federal initiatives for quality have challenged inst...

One of the Most Incredibly Disregarded Options for Presentation Online

<h1> One of the Most Incredibly Disregarded Options for Presentation Online</h1> <h2>What Presentation Online Is - and What it Is Not </h2> <p>Maintain a scratch pad and pen convenient as you might need to take notes. Elective introduction programming can give one of a kind visual qualities that draw in individuals past the ordinary visual cue slides everybody is used to viewing. CustomShow is an introduction instrument which merges an endeavor level library with a full-included slide developer to empower you to oversee introductions internationally and offer the most appropriate substance each time. If it's not too much trouble note that you couldnot alter your introduction or imprint it utilizing a highlighter or pen as you are introducing a slide show on the web. </p> <p>You don't have anything to be worried about when requesting from our web website. PowerPoint Online recoveries your work each and every time you make a move. Whenever you spare completely free online for school and testing undertaking. </p> <h2> Why Almost Everything You've Learned About Presentation Online Is Wrong </h2> <p>Church introduction programming makes it workable for ministers and ministers to impart their lessons to a far bigger crowd. It's important that the administration you select knows without a doubt they're just choosing the perfect article journalists. Getting to solid on-line task help is among the difficulties that understudies face. In case you're one of the understudies wishing to obtain premium-level PowerPoint help, we can give you whatever you need at The-Essays.</p> <h2> The Rise of Presentation Online </h2> <p>Whether you're thinking about an update or another introduction program buy, the choice technique can be direct and straightforward in the event that you are prepared to give a limited quantity of direct front work. Every ha its own advantages, so find the technique wh ich works best for your current condition. When there are factors that we consider in determining the financial plan of your work, for instance, time accessible for finishing the endeavor, we've discovered innovative methodologies to reduce the costs in question. Learn more regarding the matter of the changes. </p> <p>Dedicate a plan to a solitary section in particular, consequently it is less complex to see. There for you when you require an individual to get a paper. End PowerPoint introductions additionally fuse an end yet it's basic they arekept brief and legitimately focus on the point. </p> <h2> What You Don't Know About Presentation Online</h2> <p>If it isn't as of now chose, settle on the hyperlink. You will be very helpful for other Read Full Report on the site that give flawless quality. At the point when you ought to achieve something in PowerPoint Online however don't see how, you may utilize the Tell Me search highlight to quickly fin d what you're scanning for. In the event that you have the choice, select your point cautiously. </p> <p>No program ought to be downloaded and it tends to be utilized with any program. It's cloud based which licenses you to view and store all your work on the web. After you find a help you like, don't disregard to take a gander at my survey of it. The absolute first time you attempt to show an introduction on the web, you are mentioned to give your Office 365 username and secret key. </p> <p>Clients utilizing our on-line task assist organizations with getting a charge out of probably the best rates and subsequent cost reserve funds conceivable in the business. Obviously there's no cash made by giving data with respect to the market to financial specialists. Everybody can buy or sell their own home without realizing what a writ of compensation is or how to figure the Gross Rent Multiplier, yet should you wish to step into the real domain contributing field as a serious financial specialist one of the underlying things you ought to do is handle a firm cognizance of the insider language. At the point when taken in little nibbles it is easy to get familiar with the real bequest language. </p> <h2>Presentation Online Options </h2> <p>To secure all around structured innovative introduction thoughts without PowerPoint, you should initially comprehend what things to search for. At the point when everybody is going to see the introduction, click Start Presentation. In the event that you wish to send out your introduction in PowerPoint to HTML, at that point there are different methodologies that you can follow. Discover increasingly about sharing an introduction. </p> <p>To make uniquely designed activitys, you will require the PowerPoint work area application introduced on your PC. Intrigue permits you to develop and control 3D scenes consolidating an immense scope of items and segments. On the off chance tha t you buy PowerPoint introduction from our business, you can be totally certain your tweaked ppt will be coherently organized, blunder free and unique. </p> <p>At 20 years of age it's as yet the top introduction program. In case you're a little group with insignificant plan understanding, Zoho is an amazing exchange to PowerPoint. The plan strategy is incredibly clear. With the development of current advances, you'll discover custom PowerPoint introduction on the web, yet it doesn't demonstrate that its quality will be satisfactory. </p> <h2> Presentation Online at a Glance</h2> <p>Such a business should be the best web composing organization with the goal that it might offer the best scholarly and non-scholastic papers. A trustworthy web based composing administration must be reasonable. Use Ultius and get the quality you have earned in an internet composing organization. A believed organization should offer modest or reasonable on-line composing administrations. </p> <p>You'll need the web for your video to take care of business. When your video is transferred, you may give the hyperlink to anybody you have to see it. Watch the video beneath to learn all the more with respect to various methods by which you can share your introduction. See your introduction to take a gander at your video plays the way wherein you might want it to! </p>

What Are Some Good Topics For A Debate?

What Are Some Good Topics For A Debate?The topic for a persuasive essay will decide the outcome of the entire essay. The argumentative essay, in contrast to the composition about a topic that deals with the arguments in favor of the position which is being written, should be based on facts and evidence which can be checked and compared with the facts and evidence that supports the opposing positions. A purpose of the argumentative essay is to create controversy, stir up emotions, be interesting, and change the opinions of the readers or audience.The question as to what are some good topics for a debate is often looked at as an entertainment question, but the reality is that this is not entertainment at all, it is a very serious matter that may affect many people's lives. A situation where there is a disagreement among the members of the group may arise one day. That is when the debate can begin. A debate is essentially a discussion between two or more individuals or groups, with each one trying to convince the other as to which view is correct.There are several factors that should be taken into consideration when coming up with what are some good topics for a debate. One of these factors is the type of group that will be represented. As a group, a group that consists of people from different backgrounds may present a variety of viewpoints. But since all people are not individuals from the same background, they may take a variety of views and opinions from different perspectives and these viewpoints must be reflected within the discussion, which will then form the basis of the entire argument.Another factor that should be considered when choosing the subject for the argumentative essay is the group of people that are to be included in the discussion. A debate will not be successful if there is no one present to talk about what is to be discussed. A group is formed through the selection of the topic of discussion. Therefore, everyone should know what the subject is before the topic is discussed.A third factor that should be considered when coming up with the topic for an argumentative essay is the amount of information that is to be presented. A short argumentative essay can contain only a few sentences or even only a single paragraph, while a long argumentative essay has to cover a longer time period. A simple argumentative essay will not necessarily be very interesting, and a long argumentative essay may not reach its full potential.It is advisable to use different subjects for different discussions. If there is to be an essay about a particular subject, then there should be no problem discussing what is to be included in the discussion. A longer argumentative essay is more convincing than a short one. However, the arguments can be very well researched, so that people are able to see the correct logic and analysis of the information.A fourth factor that determines what are some good topics for a debate is the way in which the argumentativ e essay is written. Good arguments are not written in a biased manner. An example of a biased essay is one which is written by a person who is trying to convince the reader to agree with his point of view, instead of the other person. In such a case, the argumentation is biased and so is the topic, which the author should reflect the other way around.What are some good topics for a debate? The answers to these questions are not all the same.

Essay Topics on Fahrenheit 451 What Does Your Child Really Know About the Book

Essay Topics on Fahrenheit 451: What Does Your Child Really Know About the Book?Have you ever wondered how some students learn so much about essay topics on Fahrenheit 451? Perhaps a simple example will help you.Imagine you're in the school library in July and it's a full house of children playing in the library. A second-grade class in front of you has their attention riveted to an older child in the front row. You can see in her eyes that she is probably about to read the book to them, and soon after, that she is excited for the book.While you are talking to her in the back of the room, her teacher walks over to the front of the room. The teacher thanks to the parents for bringing their children to the library. 'We encourage parents to bring their children to the library, as well,' she says. Her eyes move across the room to meet yours. She seems to be sizing up your child.'Your son brought his friend along and her children to the library,' she says. 'Where were you?' your teacher c ontinues. 'Do you know the book?'Your child smiles and says, 'It's called The Little Engine That Could.' 'Thank you,' the teacher replies. She then turns to you. 'What is this book about?''It's about a woman who works as a clerk in a concentration camp,' you reply. 'She finds her escape when she reads The Fireman by Ray Bradbury.' Your teacher says, 'Wow! I have never heard of that book!'If you've never read Fahrenheit 451 before, you may not understand how the teacher could possibly have not heard of it. When I was in school, we read novels all day long. We don't go home and watch PBS or C-SPAN on our DVR. But we read books for the rest of the day, and at night, we study the next morning's readings.Reading a book like Fahrenheit 451 is different than studying a book in class. It doesn't take hours to finish the book; it takes just a few minutes. When you are in the middle of reading the book, you can't turn away from it, because you're riveted to the dialogue or the violence of the book. That's why you should focus on your essay topics on Fahrenheit 451 when you're teaching English composition.

Anorexia Essay Introduction - How to Write an Essay Introduction For a Patient With Anorexia

<h1>Anorexia Essay Introduction - How to Write an Essay Introduction For a Patient With Anorexia</h1><p>Anorexia is a kind of dietary problem which can be depicted as a sickness wherein an individual turns out to be sick because of starvation. The sickness as a rule originates from the limitation of food consumption or the longing to eat a lot of food. It can even bring about death when it isn't dealt with appropriately. Luckily, there are treatment alternatives that may enable the individuals who to experience the ill effects of this condition.</p><p></p><p>There are numerous online sources that will assist you with your instruction. On the off chance that you don't have the foggiest idea what to compose, at that point a book or article would be the best choice. Truth be told, you could even utilize a glimmer fiction to compose your article introduction.</p><p></p><p>It is strongly suggested that you compose an exposi tion presentation for the patient who is determined to have anorexia in the wake of counseling a clinical determination. This is on the grounds that the goal is to get into an increasingly close to home point of view of the patient. Besides, it additionally gives a spot to communicate considerations and emotions that would be improper in a formal interview.</p><p></p><p>Once you have composed your article presentation, you can even place it into a web structure. You could spare it and afterward present it on different sites to show that you are not kidding about giving data and counsel to those experiencing anorexia.</p><p></p><p>There are numerous manners by which you can treat anorexia; notwithstanding, it is amazingly hard to control the impacts of the infection on the off chance that it is hereditary. That is the reason a few people resort to an alternate kind of treatment known as life training. This includes a couple of meetings, which are said to give mental support.</p><p></p><p>Anorexia isn't only an individual issue; it influences numerous individuals and their families. Thus, when managing patients who are experiencing this sickness, it is imperative to offer directing as a last resort.</p><p></p><p>If there is the chance, you can proceed to visit the patient and promise them that you are there to help. This would just assistance in expelling the enthusiastic pressure they are encountering because of being determined to have anorexia.</p>

Finding Scholarship Essay Topics That Are Convenient

<h1>Finding Scholarship Essay Topics That Are Convenient</h1><p>Heroes article themes are the subjects of your papers. In the event that you have picked a theme for your grant paper that incorporates legends or the individuals who accomplished extraordinary things, ensure you locate the correct one to get acknowledged for your scholarship.</p><p></p><p>Writing regarding a matter which has numerous saints is a decent alternative for your grant. There are grants that are explicitly for understudies who expound on saints, and there are a lot more that require the articles center around legends when all is said in done. Utilize these two choices to your advantage.</p><p></p><p>If you decide to compose on a specific saint, try to bring up all the manners by which the understudy's capacities and accomplishments helped individuals. This will assist the peruser with seeing how the understudy utilizes their forces for good. You may even need to incorporate insights concerning how the understudy may have the option to additionally help the world after the moves they made. For instance, a dad may have lost his youngster to a mishap, and this understudy might help other children.</p><p></p><p>If you decide to compose on legends when all is said in done, ensure you call attention to how the hero's capacities or victories helped other people here and there. For instance, the author may depict how the understudies of the school soccer group were motivated by the presentation of their headliner or the townspeople of the town may be roused by the legend's endeavors in ensuring the individuals of the town.</p><p></p><p>The grant paper is a significant piece of an understudy's secondary school vocation, and the focal point of their life as they get ready for school. So ensure that the focal point of your grant exposition is exceptionally centered around extraordinary accomplishments, and not really on a solitary student.</p><p></p><p>Heroes article themes ought to be anything but difficult to compose. Likewise with some other article, there are key thoughts that should be secured, however the key thought isn't the focal point of the paper. Truth be told, so as to compose a phenomenal paper, it is fundamental that you leave some space for the author to take other significant ideas.</p><p></p><p>Heroes exposition themes are something that can be hard for understudies to think of. So ensure that you discover a legend who fits the interests of the understudy, and base your paper around that.</p><p></p><p>When searching for grant exposition themes, understudies can likewise think about thoughts from the school's educational program. School first year recruits can expound on how thoughts from writing, history, or science have motivated their choices for attending a university, and an understudy's class advisor can propose points that will permit understudies to talk about significant subjects.</p>

Writing a High School Research Paper

<h1>Writing a High School Research Paper</h1><p>Writing a secondary school inquire about paper is exceptionally simple to do, however you can improve your odds of progress by having some fundamental tips. Since it is imperative to get something out of the entirety of the data you put in writing, it is significant that you follow a couple of rules. This will assist with making the procedure a lot simpler. Following these tips will enormously build your odds of success.</p><p></p><p>It is likewise critical to have a decent research aptitudes. In the event that you don't have the foggiest idea how to direct a decent research venture, at that point you should employ an understudy to do it for you. There are a few distinct sorts of research tasks, and you ought to have the option to get a new line of work for anybody with great research aptitudes. You ought to have the option to discover somebody who will have the option to direct a decent researc h venture for you at the rate that you are looking for.</p><p></p><p>Have a working information regarding the matter you are expounding on. By recognizing what's in store, you will have the option to stay away from any issues that may emerge. You will have the option to get ready for whatever circumstance emerges on the off chance that you comprehend what's in store. You may find that you have a simpler time with a specific point on the off chance that you have contemplated the subject already. This will make it simpler for you to concentrate regarding the matter matter.</p><p></p><p>In request to compose an effective research paper, you have to have a lot of things recorded. A decent strategy for doing this is to begin by putting down just as much data as possible recollect. This will shield you from returning and change your report in the event that you overlook something.</p><p></p><p>Before you start to comp ose a secondary school look into paper, you should assemble the entirety of the important data. Notwithstanding a rundown of inquiries, you ought to likewise have some test addresses that you can use to test the understudy. The more things you have prepared, the more ready you will be to compose an effective research report.</p><p></p><p>While there are a wide range of sorts of research extends that you can look over, there are a few things that you should attempt to maintain a strategic distance from when composing a secondary school investigate paper. These incorporate rehashing a similar research thing over. You should attempt to abstain from doing this since it will make it harder for the understudy to perform well in the last grade.</p><p></p><p>Writing an exploration paper can be enjoyable. In any case, it can likewise be very difficult work. A few understudies find that they can't proceed with their work once they begin. This is generally on the grounds that they are experiencing difficulty finding the right words to portray their examination results.</p><p></p><p>The most ideal approach to figure out how to compose an exploration paper is to peruse a variety of research papers. At the point when you are attempting to make sense of how to compose an examination paper, it tends to be useful to peruse many papers with the goal that you can get a general thought of how to compose an exploration paper. You would then be able to utilize the data you get from these various papers to assist you with composing a decent research paper.</p>

Essay Topics For the Immortal Life of Henrietta Lacks

<h1>Essay Topics For the Immortal Life of Henrietta Lacks</h1><p>Essay points for the undying existence of Henrietta Lacks can be dubious to compose and frequently think of your best thoughts exactly when you need them the most. Your composing abilities should be adaptable so you can adjust to an assortment of circumstances. It is critical to consider what you are composing as this will give you a guide concerning how you can best present your thoughts in a manner that is right, exact and simple to understand.</p><p></p><p>The points can incorporate logical research, thoughts of significance to society, unique thoughts, or any number of thoughts that you have not considered before. It is conceivable that a portion of these might not have been utilized in your whole composing profession, yet they will offer incredible bits of knowledge which will help you during a meeting or on the job.</p><p></p><p>Being ready to think well is significant and this is significant when you have to do look into. You may need to look at changed sources before concocting the best thought for your article theme. Obviously, you ought to consistently recall that you ought depend on your thoughts, yet you should look at how others utilize their thoughts. This will give you a bit of leeway in that you will recognize what to do with regards to reusing data in your writing.</p><p></p><p>If you need to give your exposition points for the undying existence of Henrietta Lacks the opportunity to excel, you should write in a sensible way, breaking down the life of Henrietta so as to expound on the effect that her work had on clinical science and how her life has affected others. This may incorporate undeveloped cells and cloning.</p><p></p><p>In request to introduce your thoughts such that will talk well about your paper, you should likewise consider that you will utilize material f rom various sources. You may need to utilize unique thoughts from authors who have never composed anything as such. You have to ensure that the source you pick won't just have the option to introduce your thoughts in the most ideal manner, yet that they will likewise have the option to increase the value of your article.</p><p></p><p>By introducing your thoughts in a way that is right, exact and straightforward, you will have the option to persuade potential bosses to recruit you into the business you are attempting to enter. Not exclusively will you have the option to introduce your thoughts in a manner that is right, yet you will likewise have the option to introduce yourself in a manner that is powerful. You ought to have the option to exhibit what you resemble in writing.</p><p></p><p>When you have introduced your thoughts in a legitimate way, you would then be able to proceed to utilize unique thoughts. For whatever length of time that you can utilize material from various sources, you ought to have the option to introduce a unique thought that will make others see and acknowledge what you have written.</p>

How To Find The Best Writing Service

How To Find The Best Writing ServiceFinding the best writing service can be a daunting task, but it is not as difficult as you may think. Writing is an art that requires you to use creativity and imagination in order to convey your ideas and thoughts in the most effective manner possible.For a small business owner, home-based services can offer an extremely cost effective way to produce articles that will generate higher profits for the business, while also offering your family and friends the opportunity to have quality content to read every day. In this article, I will go over the types of writing services available, and how they differ from each other.The first type of writing service that you can use is to hire someone to write an article about you and your company. You are able to choose who will write this article based on your tastes and personality. They can write about any subject you would like, including hobbies, family, and other personal information.Another writing servi ce, you might consider hiring to write articles for you would be to hire a ghost writer. This type of article writing service is based around ghost writers, or the person who wrote the articles for you, when you were not able to attend to the writing. Since you will not be there for the completion of the work, the ghost writer is there to take all the credit and send it out to the various article directories.Some people might find that the third type of writing service is the best and one that you should definitely consider. This service is called an article ghost. Using this type of service you are able to have someone to write articles for you based on what you want to read, rather than on what you would want them to write.For this type of service, you simply provide the information that you need, and the freelance article writer will go ahead and produce the articles that you want. You will need to know exactly what you are looking for in an article, and then the freelancer will turn your article into the exact piece of writing you want.The benefits of using a freelance article writing service are numerous. As mentioned above, you will save money by not having to pay a large price to hire someone to write an article for you.

The War On Drugs And America Essay - 1573 Words

The war on Drugs played a heavy role in minority American society. It affected policing and most importantly the American minority people. The war on drugs started by President Nixon and up until President Bush was a disaster that affected America with high incarceration and high recidivism rates for low level and non-violent drug offenses that mainly targeted minorities in America. The war on drugs was a massive American failure that mainly affected minorities. President Obama and his drug reform alongside the American public’s strong opinion to switch towards marijuana reform which we see in places like Colorado and Washington has caused the war on drugs to lose steam. The American public’s decision for drug reform is no surprise after nearly 40 years of the unsuccessful war on drugs. The war on drugs brought the United States the highest incarceration rate in the world, mandatory minimum sentences, and racial disparity in our criminal justice system. The war on drug s greatly affected the way policing works in America. Policing and racism have always intertwined in America but the war on drugs fueled it. As a result minorities were the most affected by policing. During the war on drugs funding for police departments rose to support it, Cooper (2015) reports that a 2012 study done by lynch states that â€Å"between 1992 and 2008 state and local departments expenditures on police doubled from $131 per capita to $260 per capita† (p. 1189) This increase in law enforcementShow MoreRelatedThe Drug War Of America1407 Words   |  6 PagesThe drug war in America has shaped our society into what we know it as today, the war has so far been a failure where hundreds of millions of dollars, workforce, and policies have only served to maintain the same rates of usage as those in the 1970’s. When the drugs hit America, they hit hard. Overwhelmed by drugs showing up in almost every town, America decided to declare war. Drugs first surfaced in the late 1880’s with Opium. Opium at the time was the most in demand drug choice. Opium comes fromRead MoreWar On Drugs And America2460 Words   |  10 PagesWar On Drugs Fifteen billion dollars. The possibilities of things to do with fifteen billion dollars are endless. Some may use this towards college. Others towards health care facilities. Some may even use this hefty amount to renovate homes and still be left with a fortune to spare. All in all, the average American would use this currency toward benefit life in some way or another. The U.S Federal government wished the same when they used these fifteen billion dollars towards the â€Å"War on Drugs†Read MoreWar on Drugs in America Essay991 Words   |  4 PagesHuemer: â€Å"America’s Unjust Drug War† In the essay â€Å"America’s Unjust Drug War† by Michael Huemer, Huemer discusses the facts and opinions around the subject on whether or not the recreational use of drugs should be banned by law. Huemer believes that the American government should not prohibit the use of drugs. He brings up the point on drugs and how they harm the users and the people in the user’s life; he proves that the prohibition on drugs in unjust. Huemer believes that drug prohibition is an injusticeRead MoreThe War On Drugs And Its Effects On America1065 Words   |  5 Pagesdeclared drug abuse public enemy number one, initiating an unprecedented global campaign, the War on Drugs. Today, the War on Drugs is a huge failure, with devastating unintended consequences. It led to corruption, violence, and mass incarceration. It negatively affected the lives of millions of people. All of this while we waste billions of dollars every year only to create and fuel powerful drug cartels. This glo bal conflict has to end. The core strategy of the War on Drugs is to eradicate drugs andRead MoreAmerica s War On Drugs Essay1299 Words   |  6 Pagesserved time in prison for his connection in the Watergate scandal, the Drug War was â€Å"intended to disempower the anti-war and black rights movements in the 1970s.† It’s no secret that drug use in the United States has been a problem. Many Americans have struggled with addiction to some of the worse drugs. Many lives have been affected in some of the most terrible ways. It can be easily said that due to America’s history with drugs that former president Richard Nixon noticed the problem and felt thereRead More America And The War On Drugs Essay1216 Words   |  5 Pagescountries with problems. Why does America care about what is happening in other countries like Columbia, when they have their own problems with drugs? The Untied States of America has a rather large drug trafficking problem but compared to Columbia it is fairly small. To help Columbia solve their problem the U.S. senate has decided to send troops over there and take control. This new involvement will have many consequences in and what can you make for instance the cost of a war, the loss and gain of jobsRead MoreAmerica s War On Drugs1306 Words   |  6 Pagesas eugenics. One of the primary focuses of America s War on Drugs has always been the controversial drug Marijuana. In the early twentieth century, Henry Anslinger became the first commissioner of the Federal Bureau of Narcotics where he remained between 1930-62. Anslinger’s campaign was driven primarily by racism. He convinced the public to believe Blacks were negative influences in society and negatively associated African Americans with the drug. Anslinger made heavily racist remarks such asRead MoreAmerica s War On Drugs1539 Words   |  7 Pages On June 17th, 1971, President Richard Nixon declared drug abuse to be â€Å"America’s Public Enemy #1† in a press conference in which he called for an â€Å"all out offensive† against this enemy, an initiative that would later be known as America’s War on Drugs. By giving this speech, thus starting â€Å"The War on Drugs,† President Nixon created what would eventually become one of the most catastrophic fa ilures in United States political history. Analysis of the historical events surrounding Nixon’s declarationRead MoreAmerica s War On Drugs2885 Words   |  12 PagesRunning head: AMERICA’S WAR ON DRUGS 1 America’s War on Drugs: A Battle against Drugs or a display of Racial Intolerance? Sharon Curry-Robinson, Duval County Court Bailiff Florida Gulf Coast University â€Æ' America’s War on Drugs 3 Abstract It was surprising to learn that, while the United States makes up just five percent of the world population, over twenty-five percent of the world’s detainees are from the United States. Yes, at a projected figure of moreRead MoreAmerica s War On Drugs2030 Words   |  9 PagesThe â€Å"War on Drugs† has been a hot topic for several decades in the United States. The argument for the success of this campaign usually varies depending on one’s political affiliation. The government handled the ongoing campaign differently with each new administration taking command, most of them having no little success. The fact of the matter is that the ideal of a â€Å"drug free civilization† is far from reality. The world is coming to terms that the various drug-fighting programs across the world

Relationship Between Vicarious Liability And Non Delegable Duty

Question: Discuss the relationship between vicarious liability and non delegable duty? Answer: Introduction Vicarious liability: It is vicarious liability when wrong is done with a third party by the employee when he is in the employment. Its employer's vicarious liability for the wrongdoing of employees of the third party when he is in employment, For vicarious liability to exist, there has to be an employer, employee relationship and the wrong is done during his employment.The employer is directly liable for other way of behaving, conduct and wrongdoing to third parties. Non delegable duties: Whereas Non delegable duties are duty to care for others. For eg. Any Hospital or Any public institution has non delegable duties towards their patients or r public in the institution.Hospital would be liable if it does not show duty to care of patients.If employer fails to duty to care for others for the work delegated,he is liable to pay damages personally.In this case, employers earn lots of profits and so has to bear the risks arising therefrom.Since the employer has a duty to care, he will try to prevent accidents and will take all the possible steps to provide insurance to his employees. In Vicarious liability there should be employment relationship which means that provision of law of torts apply when the relationship is of employer and employee.It was held in Hollis V/s Vabu that an employer is vicariously liable for the wrong done by employees when in employment. Once the employment relationship is satisfied, it is essential that wrong was done in the course of employment. The relationship of employment also includes Principal and agent. Authorizing agent to act or do things on behalf of Principal establishes an employment relationship in law of Torts. The owner of the car is vicariously liable for the neglected conduct of his driver.[1] In non-delegable duty, hospital is vicariously liable for all the persons who are in the services of the hospital and do so in the name of the hospital. In Kondis V/s State Transport Authority, an employer had hired an independent contractor who operated crane, the jib of the crane fell upon the employee. In this case the employer was not vicariously liable for negligence of the Contractor but was liable to the employee or claimant on whom the jib fell as per the provisions of non delegable duty. [2] Whenever there is a breach of nondelegable duty it can be so determined only if it were treated as vicarious liability. Thus the factor of vulnerability is relevant in the circumstances if the act of employee was carried out through delegation. In recent times, the question had arisen in respect of Independent Contractors. Whether Employer was vicariously liable for the wrong done by the independent contractor. It was held that an employer is not only vicariously liable for the wrong doing of his employees, but his liability extends to the independent contractor too.[3] The U.K. Laws have taken into consideration many instances where it is the non delegable duty of the independent contractor to take due care. One such instance is that of extra hazardous acts. In the case of Honeywill Stein Ltd V/s Larkin Bros 1934 Lord Sumption had held that defendant was held for non delegable duty who had hired an independent contractor for extra hazardous activities. Another instance is of work carried out for highway. [4] It is the non delegable duty of independent contractor to take due care of all passing on the highway and that his work though of an independent contractor should take due care that his operations do not cause any harm or danger to passersby. One more instance is of withdrawal of support of neighboring land. It is the non delegable duty of the landlord to take due care of the common wall of his and his neighbors while carrying out any work on one's own land in spite of employing independent contractor. In Rylands V/s Fletcher, If an individual keeps anything on his land that would escape, it is his non delegable duty to take due care is taken by him if it escaped and no harm or injur y is caused to anyone due to such escape though the things are bought by an independent contractor. A bailment is another instance where it is the duty of bailee to take due care of goods bailed with him. In case of negligence bailee will be held liable for non delegable duty. An employer's duty to care for his employees. Employer in this case is liable to take due care to his employees by keeping them in safe conditions or environment. Any harm or injury if caused to them, the employer is directly liable for damages and compensation. Hence employer cannot avoid this even if the employer has delegated his work to someone else. Relationship between vicarious liability and non delegable duty In Vicarious liability, an employer is liable for any wrong done by the employee when in employment irrespective of the relationship between injured and the employer. Whereas in non delegable duty the relationship between injured and the employer has to be established.In vicarious liability it is the duty of the employee and breach by employee. In Cassidy v/s Ministry of health Lord Denning observed that the most important factor was not of the relationship between hospital and the negligent doctor but between claimant and the hospital. When hospitals employ or hire doctors or specialists or nurses or any other person for taking care of patients, than if any surgeon, doctor, nurse or any person so appointed is negligent in his duties in taking due care of patients than a hospital is liable for the negligence of any person whose services are taken by the hospital. So here the relationship between the claimant and hospital is to be examined (Salvador-Coderch, Garoupa and Gmez-Ligerre, n.d.). The provisions of vicarious liability were applied in most of the cases, but here Lord Denning observed that hospitals had a non delegable duty to care of the patients who came for treatment. Lord Sumption has observed that there were two categories of non delegable duty. The first is where the an independent contractor is hired by the defendant for his work the operation of the said work is hazardous. The second category has three features where duty (i) arises because of the relationship between the defendant and the claimant which is antesedent relationship and not due to the negligence of the work carried out (ii) is a not a negative duty .it is either positive or affirmative duty to protect certain class of people against certain kinds of risks and not simply to move away from or get away from acting in such a way that causes injury and (iii) is one by the value of that relationship personal to the defendant.[5] Applicability of non delegable duty Lord Sumption observed that the main problem with this was to not allow a wrongdoer to eat up the rule So this duty has following features: 1. The claimant may be a patient, pupil, student a prisoner or the resident of a care home or one who is vulnerable or dependant on the defendant's protection against risk of injury. 2. An antecedent and different type of relationship between the claimant and the defendant and where claimant is under the charge of the defendant and where it has been assumed to protect the claimant from harm, a duty being positive. 3. The claimant is not aware as to how the defendant performs his work or operations and neither any control on defendant. 4. The defendant has delegated a part of his work or duty to a third party and so the claimant is in care of a third party who is carrying on his work delegated to him by the defendant. 5. The third party in the work delegated to him by the defendant commits negligence in the matter of claimant. The most important factor is the third party's control over the claimant for which the responsibility is assumed by the defendant. Since the Courts should be just, fair and reasonable, so It is right to say that the school should be answerable for all the acts done by its delegate while carrying out the work and should exercise control carefully.It was further held that though schools have a duty to care a non delegable duty they cannot be held liable for duty which it cannot perform but has to make arrangements for the performance of certain duties such as school trips. But schools are under statutory obligations. They are bound by statutes, hence they always assume the role of parent, which means they have a much bigger responsibility than the parent as schools develop intimacy with every child in school and this intimacy of the school with the child cannot be explained in any language of law. The result is that the school had a non delegable duty to care if the child was injured d ue to negligence by the contractor who was delegated work on behalf of the school. The school is in breach of duty. Lady Hale too agreed what Lord Sumption observed, but opined that new situations may take place every day and this is not enough so precaution is essential. Though the case of Woodland V/s swimming teachers association would raise the levels of fear in the minds of people, there is no need for such anxiety as the schools have started giving the work to the staff which would make school vicariously liable. Henceforth schools will take steps to indemnify the child from any such external arrangements.[6] In the case of Woodland V/s Swimming Teachers Association Essex Count Council a school was alleged that it had a non delegable duty as loco parenti to take due care of children in school. In the Appeal Court judges held that it was unjust and unfair to make Essex County Council liable for non delegable duty in view of the fact that swimming lessons were given outside the school and that school had no control over the exercise of powers given to the swimming pool. Lord Sumption disagreed with the judges of the appeal court and rejected what was said. Lord Sumption held that the school was not having powers over the swimming pool cannot be considered as even if in this case school had no powers, in spite of it the school was liable for non delegable duty. The claimant was injured in the environment for which the defendant school had assumed responsibility of due care.Lord Sumption further rejected that it would not be fair and reasonable to put the burden of duty on school. He reasoned that it is always the policy and rule of law under the provisions of this law to protect the vulnerable and dependant against those who have control over them. The parents repose trust in the school when they send their children to school. It is right for school to owe greater responsibility to their students than that of a parent as schools are governed by statutes and it is their statutory obligation to take due care of its students. In any legal context the intimacy of school with students cannot be explained. As after home their second home is a school. Swimming was a part of school lessons so if the lifeguard and swimming teachers were negligent in their operation of work delegated to them, it was the breach of duty to care on the part of school for not providing safe swimming lessons. Assumption of responsibility Lord Blackburn had referred that assumption of responsibility had risen by the value of the relationship that the defendant has with the claimant. To determine whether the defendant has the duty to care only as far as the loss of the claimant is concerned as a tool to the law of negligence by assuming the responsibility. Undoubtedly, in this case the public services and educational institutes like schools are responsible and owed a duty of care to its pupils protection and has to see that no harm or injury is caused to its pupils. But the concept of assumption of responsibility has to determine its scope, whether the potential loss is economic or physical. In the said circumstances, it is a must that the defendant should not only have an affirmative or positive duty, but the duty to the assumption of responsibility in its true sense. The defendant should have that virtue of assuming responsibility for all the wrong or negligence of his delegates.[7] This is a markedly more onerous obligation. What are the circumstances in which a person may be taken to have assumed it? The circumstances in which it is assumed in many cases where employees, hospital patients, school pupils and invitees are injured by the persons working for the defendant where the defendant was not vicariously liable. In many situations where the defendant is held liable and further held that defendant had assumed positive duty due to some special relationship. Henderson v Merrett Syndicates Ltd [1995] 2 AC 145 is a classic example of a duty of care to perform professional services which has arisen due to the said specific relationship and not due to contract. All of these features were also present in Hughes v Percival (1883) 8 App Cas 443, which was one of the first cases in which the same principle was applied to a duty of care. The parties were living next door and had a common party wall. A builder was carrying out some work in the house of the defendants Due to the builder's act of negligence a cut was formed into the party wall, which led to the collapse of both the neighbors house living next-door. On its facts, therefore, the case had many of the classic features about non-delegable duties in the law of nuisance. The question mark has never been seriously put on the fact that when a patie nt in the hospital is injured due to the negligence of a nurse it matters whether the nurse is employed by the hospital or by an agency; or if a pupil at school is injured by a teacher it matters whether the teacher is employed by the school or is self- employed.[8] Yet these are not employees of the hospital or school, nor can it be said that their relationship with the school is akin to employment in the sense in which the relationship of the individual Christian Brothers to their Order was akin to employment in the case of Various Claimants v Catholic Child Welfare Society and others [2012] UKSC 56, [2013] 2 AC 1. The hospital or for that matter any such utilities as school or any educational institutions have undertaken to take care for the patients and pupils thereof and hence are liable school, and that hiring of or taking the services of competent people does not give any relief to the defendant but it is the duty of school and hospital to see that due care is taken in delega ting the duties. The delegates in view of the exercise of powers have to bear in mind that schools and hospitals are responsible if due care is not taken by delegates. To speak about law of negligence in a general sense, the defendant is liable only for the acts which he has omitted to do or which is done by him negligently. The court does not hold the defendant liable for the wrong done by others in ordinary cases but as far as vicarious liability and non delegable duties are concerned the law of negligence can be said to be fault based.[9] This is because, as Cory J observed, in the Supreme Court of Canada in Lewis v British Columbia [1997] a common law in duty of care the defendant does not have to comply with any specific or particular obligation.It is only when any work or operation or act is undertaken by a party than it is the duty of the party to take due and reasonable care.The concept expressed asnon-delegable duty has been adopted in modern law and has taken the place of ordinary law while dealing with the cases where more carefulness is required for the performance of work delegated to others. The provisions of principles as laid by Lord Sumption has become the conventional way of dealing with all such cases.[10] Conclusion: In 2010 Clerk and Lindsel observed that it was not possible and difficult to admit when the non delegable duty arises as English law has not laid any relevant principles in common law to arrive at such a decision. But after the judgement in Woodland V/s swimming teachers association Lord Sumption had laid down certain principles which the lawyers can rely upon and will help them in applying the principles laid down by his Lordship in respect of non delegable duties so that a right path is clear to them. The distinction between vicarious and direct liability depends on whether the defendant's liability is triggered by its relationship with the plaintiff or the wrongdoer. As that distinction has been gradually eroded through cases such as S v Attorney-General and Lister, vicarious liability has become less strict. However, those cases in which the reasoning has focused mostly on the defendant's own duties to the plaintiff can be distinguished using breach of non-delegable duties. This preserves the non-faulted character of vicarious liability.[11] The distinction between non-delegable duties and vicarious liability also helps to keep the latter in its proper context, the employment relationship. Developing the doctrine by reference to the characteristics of this type of relationship, as the English Court of Appeal did in Portsmouth, retains the underpinning rationale of vicarious liability and ensures the test is simple to apply. This approach should be preferred to the vague extension of the doctrine in S v Attorney-General by references to the agency. It is not suggested that the principles underlying the provisions of non delgable duty are not favorable to the defendant. The main reason for dealing with cases was to apply the provisions of vicarious liability and non delegable duty to work in harmony. Though U.K. Supreme court is very clear, but there are many questions which are still to be solved. 1. When the conditions of vicarious liability do not satisfy the case, can the provisions of non delegable duty be used in case of negligence by employee and can the employer be liable for such negligence. 2. Are vicarious liability and non delegable duty distinctive or apart from each other. It is suggested that both the concepts should be integrated as they both when applied give the same result which can be practically applied. 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(2013) 15 Nurs Residential Care. [2] Aharon Barak, 'Mixed And Vicarious LiabilityA Suggested Distinction' (1966) 29 The Modern Law Review. [3] Graeme Lockwood, 'The Widening Of Vicarious Liability: Implications For Employers' (2011) 53 Int Jnl Law Management. [4] 'Master And Servant. Non-Delegable Duty Of Master. Vice-Principal' (1926) 12 Virginia Law Review. [5] D. Fox, 'Non-Excludable Trustee Duties' (2010) 17 Trusts Trustees. [6] John Bell, 'VICARIOUS LIABILITY FOR CHILD ABUSE' (2010) 69 The Cambridge Law Journal. [7] Tabitha Cave, 'The Evolution Of Vicarious Liability: When Are Employers Responsible?' (2013) 15 Nurs Residential Care. [8] B. Barrett, 'Vicarious Liability For Harassment By An Employee' (2006) 35 Industrial Law Journal. [9] Pablo Salvador-Coderch, Nuno Garoupa and Carlos Gmez-Ligerre, 'Scope Of Liability: The Vanishing Distinction Between Negligence And Strict Liability' (2009) 28 European Journal of Law and Economics. [10] 'Strict Liability And Negligence: The Distinguishable Twins Of Products Liability' (1987) 27 Microelectronics Reliability. [11] Paula Giliker, 'Vicarious Liability Or Liability For The Acts Of Others In Tort: A Comparative Perspective' (2011) 2 Journal of European Tort Law.