Declaratory Theory

â€Å"Declaratory theory is propounded on the belief that judges' decisions never make law, rather they only constitute evidence of what the law is. However, this view is no longer accepted. There are three reasons for the persistence of the declaratory theory. In the first place, it appealed in the separation of powers. Secondly, it concealed the fact that judge-made law is retrospective in its effect and finally, when the judges confronted with a new, unusual, or different point, they tend to present as if the answer is provided by the common law.One of the most widely-accepted principles of the English legal system is what is known as the ‘declaratory theory' of judicial decision-making. This principle states that when judges are required to make decisions, they do not create or change the law, they merely ‘declare' it. That is, a judge says what he or she finds the law to be; no ‘new' law is ever created by judges. New law comes from Parliament. For example, th e Criminal Justice Bill that is currently going through Parliament will make fairly radical changes to the criminal law.It will take away the blanket immunity that currently exists from being prosecuted twice for the same offence. No-one is suggesting that this Bill declares the law: the ancient ‘double-jeopardy' principle has existed for centuries. When the Bill is enacted, the law will simply change. This article attempts to show, first, that the declaratory theory itself is based on indefensible assumptions of fact. Second, it shows that the theory sometimes leads to bizarre conclusions, which can only be avoided by the most strained reasoning.Finally, it examines why the theory commands so much reverence, when most academics and many judges believe it to be fatally flawed. Why the declaratory theory is factually indefensible The classical exposition of the declaratory theory is that of Lord Esher in Willis v Baddeley (1892): There is, in fact, no such thing as judge-made l aw, for the judges do not make the law, though they frequently have to apply existing law to circumstances as to which it has not previously been authoritatively laid down that such law is applicable.That judges appear to create and change law is undeniable; cases like Donaghue v Stevenson, Hedley Byrne v Heller, and Wednesbury represent significant developments in the law. In Lord Esher's view, the judges in these cases would simply be applying existing principles to new fact situations. But where do these existing principles come from? Some of them, no doubt, come from previous case law. When a judge is called on to decide a case, most often a decision can be made by looking at previous cases whose facts are similar to those at issue, and reasoning from them.Very often there will be previous cases that are binding on a particular court, and these will dictate the outcome. But unless we are to accept an infinite regress of case law, back to the very dawn of time, there must be some point in the past at which an issue was first decided. The romantic view is that the earliest judicial decisions were made by the ‘wandering justices' of the 13th century, who travelled the land at the King's behest, applying and unifying the existing law of the land.The pragmatic view is that the English common law results from an attempt by the Norman French nobility to apply its standards of law in a conquered country, while giving an illusion of continuity. Whether the legal developments of the medieval period followed from a process of approving established legal custom, or from the imposition of a foreign jurisprudence, neither represent an answer to the question where the foundational principles come from. There are really only two possibilities: either they were, at some point, created by the judges, or they were based on existing ‘universal truths' that were self-evident to the judges.The declaratory theory repudiates the notion that the judges ‘made thin gs up', so the only alternative is that they were based on universal truths. The notion that law is based on fundamental, self-evident principles of ethics is often called ‘natural law' jurisprudence. To be fair, the idea of ‘natural law' has had a bit of a revival in the last fifty years or so, after being out of favour since the 18th century. The idea that the declaratory theory can be traced back to natural law therefore does not attract the same scepticism today as it would have in the 19th century.The problem with natural law is that even if one is prepared to accept its basic tenet, that there indeed are self-evident principles of ethics, it is by no means obvious that every situation that requires a judicial decision is one in which such fundamentals are at issue. Consider, for example, the well-known case of Entores v Miles Far East Corp (1955). This concerned the formation of a contract by telex machine, in the very early days of this technology.Previously most formal business transactions would have been carried out by post; the ‘postal rule' was – and still is – that if person A offers to contract with person B, then the contract is formed when B's letter of acceptance is posted to A. This is the case even if B's acceptance never even reaches A. When considering the use of telex, the court had to decide whether the same principle could be applied to telex as to post, that is, whether a telexed acceptance was effective on sending, or on receipt. The leading judgement in Entores was given by Denning LJ.In his judgement he does not refer to any existing case law, or any legal principle. Instead, he says that it is simply reasonable and obvious that a telex must be received to be effective. If the declarative theory is correct, then Denning's judgement cannot be creating law: it must be declaring what the law is. But since he does not refer to any existing law, it must, presumably, be derived from universal principles. No w, a proponent of natural law may believe it is self-evident that, for example, murder and rape are wrong.But it takes a real leap of faith to believe that there are principles of natural law at stake in deciding when a telexed contract is formed. The reality, of course, is that when Entores was heard, no-one really wanted to see the ‘postal rule' extended to a new technology. Denning's judgement is an entirely pragmatic one. It does not require any higher principles to be considered. In summary, the declaratory theory is predicated absolutely on acceptance of a natural law view of jurisprudence, not just for fundamental principles of ethics, but for everything.This, I suggest, is just too much to swallow. Why the declaratory theory produces bizarre results Law students generally know about the ‘retrospectivity of the declaratory theory'; but it doesn't seem to be well understood that this is not a doctrinal matter, or something that can be argued either way, it is an in evitable conclusion of the declaratory theory. If a judicial decision cannot create new law, then when the judge declares the law, as a matter of plain logic he is declaring what the law always was. In the Entores example discussed above, this does not create a problem.It established that the use of telex had certain legal consequences, but since telex was only just coming into use when this decision was made, the fact that Denning was declaring what the law was is of no consequence. It is purely a matter of academic discussion whether the ‘postal rule' would have applied to telex in, say, the 15th century. It is, surely, of not practical consequence. Perhaps the first occasion on which the full implications of the declaratory theory had to be confronted squarely by a court was in the case of Kleinwort Benson v Leicester CC.Here, the House of lords had to rule on what should have been, for a court of this standing, a routine matter. The question at issue was whether money was recoverable in a restitution action, if it was paid from one party to another in a mistaken understanding of law. It had always been the case that money paid under of a misunderstanding of fact was recoverable. It was widely believed that the inability to reclaim money paid under a mistake of law was unjust, and incompatible with other legal principles and other jurisdictions.Both parties to the case, and all five of the law lords, were in agreement on this point: it should be possible to recover money paid under a mistake of law. The disagreement was on whether the decision that it was recoverable should apply only to new cases, or to past cases. Kleinwort Benson, a bank, had already paid its money to the defendant local authority. It therefore argued that the decision should operate retrospectively, so it could reclaim its money. The Local Authority, on the other hand, argued that the decision should not have retrospective effect.The problem was that if the issue were decided in f avour of the claimant bank, it must have retrospective effect. This is a direct consequence of the declarative theory. After all, if the law at time T1 was X, and it is later changed at time T2 by judicial ‘declaration' to Y, then the effect of that declaration is to deem that the law at T1 was Y as well. Of course, no-one at time T1 knew this, and so a decision made on the basis that the law was X, not Y, was necessarily mistaken. You may be wondering why this would have such dramatic consequences.Well, a potentially large number of businesses could suddenly find that the they had grounds for litigation arising from things that happened in the distant past, and which they had no way of knowing at the time would be actionable. No-one would wish to see a barrage of ancient, poorly-remembered cases dragged up before the courts in the hope of gain. For technical reasons which I don't have space to explain here, the Limitations Act would not prevent this. So the Law Lords were fac ed with a problem.They could decide justly, in favour of the claimant bank, by ruling that it could recover its money, and accept the inevitable problems that the retrospectivity of its decision would bring. Or it could decide against the claimant, and avoid the problems, but at the expense of leaving in place an unjust and criticised rule of law. It was simply not open to the judges to change the unjust law, without the change being retrospective, unless they were prepared to openly attack the declarative theory. It is interesting to see how the various judges attempted to deal with this problem.It should be noted from the outset that all the Law Lords in Kleinwort Benson agreed that, in practice, judicial decisions do change the law, rather than simply declaring it. No-one suggested for a moment that the declaratory theory was actually true. For example, Lord Goff says: It is universally recognised that judicial development of the common law is inevitable. If it had never taken pl ace, the common law would be the same now as it was in the reign of King Henry II†¦ However, there was very little enthusiasm for making an official pronouncement to that effect.We will discuss possible reasons for this later. Lord Browne-Wilkinson proposed a judicial damage-limitation exercise. He suggested that although the declaratory theory should be upheld, it could be prevented from giving rise to actions arising out of past conduct. †¦ retrospection cannot falsify history: if at the date of each payment it was settled law†¦ [the claimants] were not labouring under any mistake of law at that date. The subsequent decision †¦ could not create a mistake where no mistake existed at the time.In other words, what he seems to be saying is that although the claimants did in fact err in law, they had not made a mistake of law, so they could not reclaim their payments. This is quite a neat trick, because it upholds the revered declaratory theory, while preventing it giving rise to an undesirable situation. However, it does rely on accepting that there are two different metas of ‘mistake of law'. One meta occurs when a person misunderstands the law that actually subsists at the time he applies it, and which continues to subsist.The other meta occurs when a person correctly understands the law at the time he made the decision, but his understanding was later made wrong by a judicial decision. Even if one accepts this arbitrary and unfounded distinction, it seems impossible to avoid the conclusion that it is unjust. If a person makes a mistake of law, and the law remains the same, then the mistaken person can reclaim any money paid as a result of that mistake. On the other hand, a person who later finds that he was mistaken as a result of judicial decision cannot reclaim anything.Yet the latter person is blameless: his decision has been ‘wronged' by later events beyond his control. The former person could at least (in theory) have disc overed what the law was. The effect of the Browne-Wilkinson solution is to leave the declaratory theory intact, at the expense of justice and common sense. Lord Goff showed, perhaps, the greatest reverence for the declaratory theory: I can see no good reason why your Lordships' House should take a step which, as I see it, is inconsistent with the declaratory theory of judicial decision as applied in our legal system†¦As a result, he was prepared to allow a person to recover money paid under a decision in law which was correct at the time, and later shown to be false. In his analysis, the claimant was labouring under a mistake of law, but simply did not know it. Lord Goff correctly analysed the effect of the retrospectivity of the declaratory theory, and allowed it to stand despite the odd results it engenders. Lord Hoffman recognised the problems that would follow from finding for the claimant, but decided that they were a price worth paying for doing justice in the particular case: This may suggest that your Lordships should leave the whole question†¦ o the legislature†¦ There is obviously a strong argument for doing so, but I do not think that it should prevail over the desirability of giving in this case what your Lordships consider to be a just and principled decision. Lord Hope decided along much the same lines as Lord Goff. Of the five Law Lords, Lord Lloyd was the only one to criticise the declarative theory: It follows that†¦ the House of lords is doing more than develop the law. It is changing the law, as common sense suggests†¦ If this view of what happens is inconsistent with the declaratory theory of the court's function, then it is time we said so.It always was a fairy tale. And: For myself, I would want to allow the appeal, if I could, [avoiding the effect of retrospectivity]. But as that is not to be, I consider the second best course is to leave the abolition of the mistake of law rule to Parliament. He seems to be sayi ng that a decision for the claimant, coupled with the effect of the declaratory theory, will produce results so bizarre and unpredictable that it ought not to be allowed. In other words, the price of doing justice in this case is too high.Legal retrospectivity is bad enough in the civil law, but in the criminal law it becomes a human rights issue. Article 7(1) of the European Convention on Human Rights specifically forbids criminal sanctions for an act that did not constitute a crime at the time it was committed. In other words, however heinous we might think an act is, it can't be punished unless the offender had a way to know it was illegal. Of course, ‘ignorance of the law is no defence', but the offender has to be able to know the law to be bound by it. Consider the famous House of lords case of R v R (1994).This concerned a man who raped his wife, and based his defence on the fact that for a man to rape his wife was not, in fact, illegal. It may be condemned, it may even be wicked, but it was not – at that time – illegal. If a man had approach a solicitor in 1990 and said ‘Look, I'm thinking of raping my wife, is that illegal? ‘ a competent solicitor may well have said: ‘Well, of course I wouldn't condone it, but the balance of authority is that it isn't actually illegal'. He could have cited authorities going back to the 16th century to back this up.At this time, there was increasing pressure on Parliament and the courts to overturn this unedifying principle of law, but when R was heard, no action had been taken. To cut a long story short, the House of lords decided that marital rape was illegal, reversing a 400-year tradition. Everyone, with the exception of the defendant, heaved a sigh of relief. Later that year, the decision was put on a statutory basis, which appeared to settle the matter once and for all. The fly in the ointment is our old friend retrospectivity. The decision in R was not that marital rape was i llegal, but that it had always been illegal.Again, the court had no power to decide otherwise. And this means that an octogenarian who raped his wife in the 1940's could now be prosecuted. You may feel that this is a just conclusion; you may feel that rapists should get their just deserts. However, the fact remains that we would be punishing a person for something which was not illegal at the time, and which he would have no way of knowing was ever going to be illegal. The social conditions of the time may not even have led our hypothetical defendant to think he was doing anything wrong.But he could still be prosecuted. This may sound far-fetched, but in fact within a year of the decision in R, cases were being heard in the European Court of Human Rights (ECHR). SW v United Kingdom (1995) concerned a man who was prosecuted in 1994 for a rape he had allegedly committed in 1990. If was far from obvious that marital rape was illegal in 1990. The ECHR upheld the criminal conviction, on the basis that when the rapes occurred, the defendants could have reasonably foreseen that the criminalisation of martial rape was likely.The problem with the decision in SW v UK is that it suggests that a person must govern his behaviour, not by what the law is, but by what he predicts it will be when any consequent prosecution is bought. So, not only is ignorance of the law no defence, but ignorance of the future development of the law is also no defence! None of the forgoing is intended to condone the practice of marital rape. Judicial retrospectivity presents the same kind of problem for any criminal offence, of any severity. Lord Diplock has suggested that the retrospectivity of judicial decisions discourages judges from correcting defects in the law.Judges have to be very conservative if they must predict not only the effect of their decisions on new cases, but the effect they would have had if made in the past. To get around this problem, the Supreme Court of the USA has adop ted the device of ‘prospective overruling'; this device allows the court to state that a decision that changes the law is not to have retrospective effect. The problem is that prospective overruling is simply incompatible with the declaratory theory. If the former comes in, the latter must go. However, as Prof.Zander says, the courts can accept that the declaratory, retrospective effect of its decisions is doctrinally ‘correct', while at the same time letting it be known that they will decide cases on the basis of the law as would have been understood when the events occurred, not when the case is heard. This is a fudge, but probably a workable fudge. Why is the declaratory theory so revered? In Albion's Fatal Tree (1975), Douglas Hay argues that the decline in formal religious observance in the 18th century left a power vacuum to be filled by the law.For law to command the respect of society in the way that the church had done, it was necessary that it be seen as someth ing above and beyond its practitioners: The punctilious attention to forms, the dispassionate and legalistic exchanges between counsel and the judge, argued that those administering the laws submitted to its rules†¦ In short, it's very inefficiency, its absurd formalism, was part of its strength as ideology. Such an ideology would be undermined, of course, if it were seen that law were nothing more than the creation of ordinary people.It was the job of the legal profession to form an elite, and thereby shield the ugly reality of lawmaking from public scrutiny. While this argument may have had validity in the 18th century, it is not at all easy to see that it stands up in the 21st century. To respect the law, we don't necessarily need to view it as having supernatural origins. Moreover, since the 18th century the development of the law has increasingly been effected by statute. No-one expects Parliament's legislative programme to be to be guided by anything more than the views o f society as expressed through the ballot box.Nevertheless, while most judges tacitly accept that their activities have the effect of lawmaking, relatively few have been prepared to criticise the declaratory theory in public. Lord Reid is usually credited with first describing the declaratory theory as a ‘fairy tale'; in a 1972 article ‘The judge as law-maker' in JSPTL he described the ‘Aladdin's cave' in which ‘those with a taste for fairy tales' expect the common law to be found. However, he was not the first influential judge to cast doubt on the declaratory theory. For example, Lord Radcliffe wrote in the Law Society Gazette in 1964 †¦ here was never a more sterile controversy than that upon the question whether a judge makes law. Of course he does. How can he help it? Such comments are, to say the least, unusual. Prof. Atiyah is probably the most outspoken critic of the modern judicial attitude to the declaratory theory. In Judges and Policy ([1980] ILR 346) he identified five reasons for its continued existence. First, it is to the advantage of the judge if he can, in a difficult case, deflect any criticism of his own decision onto ‘the law' as a higher principle.As Atiyah says, of course, this can be seen as a ‘shabby attempt to evade responsibility'. Nonetheless, the job of a judge is difficult enough, without having to deal with personal attacks on his decisions. Lord Devlin has suggested that judges will occasionally hint to claimants that they wish they could find otherwise, but are bound by ‘the law'. Second, it is generally accepted as a constitutional principle that it is the role of the legislature to make law, and the role of the judiciary to interpret it in specific cases. Where judges do make law, they should do so within narrow constraints.There is undoubtedly some virtue in this principle. The most famous exponent of judicial creativity in modern times is almost certainly Lord Denning. His view was very much that it was the job of the judge to ‘do justice'; if that meant that principles of law had to be bent to fit, that was a price worth paying. The problem is that his decisions do not generalise. It is often difficult for later judges, reading his reasoning, to determine whether the decisions he made are based on law that ought to be applicable in other cases, or to fact situations particular to the case under consideration.This is evidenced by the fact that many of the principles that he established by doing the right thing in a particular case have come to be misapplied in later cases, and have had to be circumscribed by later judges. For example, his decision in Solle v Butcher (1949) that a contract could be set aside on ‘equitable grounds' when entered under a mutual mistake, did justice in the case itself. This decision was followed in a large number of cases, but it was never entirely clear what would amount to ‘equitable grounds'.Finally, in 20 03 the case of The Great Peace more or less demolished the entire concept of ‘mistake in equity' and put this branch of law back where it was 50 years ago. Even if judicial creativity can do justice in the present case without compromising later decisions, there are other reasons why judicial creativity should be constrained. Judges are only able to deal with cases they hear; it is difficult for them to take a wider view of any issue. Judges are not well-placed to make decisions that involve elements of social policy.In addition, arguably judges are drawn from a much narrower section of society than MPs, and therefore less representative. Third, Atiyah argues that judicial lawmaking is tolerated only because it is not exercised openly. Lord Devlin has argued (Judges and lawmakers [1976] 39 MLR 11) that if the courts are given, or arrogate to themselves, the power to make decisions without retrospective effect (and thereby demolish the declarative theory) this will amount to an approval to engage in judicial law-making in the large.While we accept that development of the law requires an occasional exercise of judicial creativity, the fact that it has to be done on the sly means that it won't be done all that often: Paddling across the Rubicon by individuals in disguise†¦ is better than the bridging of the river by an army in uniform with bands playing. Atiyah's fourth argument is that many judges themselves have a naive and simplistic view of their own lawmaking role.They frequently speak or write as though the only alternative to a slavish devotion to the declaratory theory is the wholesale abandonment of the doctrine of precedent and the separation of powers. Judges frequently invoke Seldon's old chestnut about the law varying with the length of the Lord Chancellor's foot as a reason for their own conservatism. However, there is no reason to assume that a disavowal of the declaratory theory need signal the end of the doctrine of precedent (it has n ot done so in the USA), or the dissolution of the separation of powers.The fifth argument is that public respect for the judiciary depends on their strict and evident impartiality. If the judge was seen to create or change law, the implication is that the judge prefers one view of law to another. But, as Atiyah says, there is no reason to believe that the public will respect a judge that is impartial but unjust, more than one that is partial but fair. Judicial adherence, at least in public, to the declaratory theory may be for the very best of motives.However, in a well-educated, democratic society, it is doubtful whether it is ever appropriate for the governing classes to espouse one point of view in public, and a different one in private. Not only is it intellectually dishonest, it is doubtful whether it is necessary. Moreover, it is a strategy that is unlikely to work for much longer. It seems unlikely that the public will be moved to increased confidence in the judiciary, when i t becomes obvious that the judiciary have practised a paternalistic and patronising form of misinformation for all these years. â€Å"

Nestle-Marketing Oriented Company

Nestle was founded in 1866 by Henri Nestle and is today the world's biggest food and beverage company. Henri Nestle developed the first infant food in 1867 to save the life of a friend's baby who could not be breastfed. (this is a combination of cow’s milk, wheat flour and sugar). Since then, the company has looked to build on a tradition of providing nutritious products. The Nestle Group invests around 1. 5 billions swiss franc in R&D every year. It’s more than any other food company. Every day Nestle sells over a billion products. These individual consumer transactions give the Company total nnual sales of more than 90 billion swiss francs Nestle markets its products in 130 countries across the world. Nestle manufactures around 10,000 different products and employs some 250,000 people; A marketing orientated approach means a business reacts to what customers want. The decisions taken are based around information about customers’ needs and wants, rather than wha t the business thinks is right for the customer. Most successful businesses take a market-orientated approach Since then, the company has looked to build on a tradition of providing nutritious products.It builds its business around: -discovering what customers want -identifying pressures for change e. g. government campaigns, health education initiatives -responding to changes in the market place. Nestle concentrates on their consumers and tries to understand their physical and emotional desires. They have a wide range of products and consumed by all age groups. Nestle try to understand the economic, geographic and social factors which affects the diets of the consumers and try to concentrate on the nutritional and health value of the products.Example Nestle have used their research and technological expertise to their ice cream products to reduce their calories but too keep the same taste. They have also introduced sugar free products and lower sugar products like Kit Kat Light. Ne stle also try to understand the motivations, decision making and purchasing habits of the customers by spending time with the people. Example: Nestle employees spent three days living with people in suburbs of Lima in PERU to understand their everyday aspects of their life, and based on their understanding they sold relevant products in the local markets.A market led company like Nestle is continually monitoring customer attitudes and requirements through market research. This research takes two main forms: Qualitative research. This involves setting up small focus groups of consumers who express their ideas and opinions about their needs and views on different products. Quantitative research. Whereas qualitative research involves only relatively few people, quantitative research involves much bigger numbers. For example, professional market researchers may interview thousands of people through postal or telephone interviewing.Nestle regularly uses both forms of research to gain a c lear idea of consumer opinions and trends. Market research helps the company to keep in touch with an ever changing environment in which social attitudes and buying patterns are continually shifting. The Company's strategy is guided by several fundamental principles. Nestle's existing products grow through innovation and renovation while maintaining a balance in geographic activities and product lines. Long-term potential is never sacrificed for short-term performance.The Company's priority is to bring the best and most relevant products to people, wherever they are, whatever their needs, throughout their lives. Nestle is committed to the following Business objectives in all countries, taking into account local legislation, cultural and religious practices: Nestle continues to maintain its commitment to follow and respect all applicable local laws in each of its markets. Analysis of Market Analyzing the market means getting the information about the current market trends. There are different ways, which are adopted by Nestle to get the information of the market.By Sales Department Sales department is a primary source of getting the information about the market. They actually visit the market and find out that who are the competitors, and what strategies they are adopting. Customer Service Department For Every product there is customer service department.. Nestle knows that regular contact with their consumers is very important. This is why Nestle have a worldwide Nestle Consumer Services network Nestle cares for its consumers because its success depends on meeting their needs and expectations.Through listening and understanding, it can make products that they will want to use all through their lives. Research and Development Department The nestle Research and Development head office is in Switzerland. The customer complaints are forward to the R where research is conducted. Suppliers and distributors To know about the market Nestle has established the close re lationship with their suppliers who provide the raw materials. Conclusion Nestle is one of the world's leading food companies. Its commitment to high quality market research ensures that it remains fully aware of changes in consumer behaviour and consumer tastes.Its excellent product research and development network ensures that it is well placed to meet the challenge of changes in consumer expectations. The company's Wellness strategy is carefully geared to delivering to customers what they want in relation to the foods they eat. Thus it's clear that Nestle is a Market Oriented company because they try to understand the customer or market needs and produce products accordingly to achieve the organizations goals. And they believe that people are the main strength of the company.

Comparing Classic Literature to the Lion King

The first animated film with sound was the 1928 Disney film Steamboat Willie. Since then, animated movies have been cranked out due to the admiration they receive from children. Disney is known world wide for their animated films. People love them because of their feel good story lines, astounding use of animation, and largely, the music incorporated into the movies. My generation especially has grown up watching what could arguably be considered â€Å"Disney classics† such as Beauty and the Beast, Aladdin, and The Lion King. Although most people still consider Disney films to be more than appropriate for children, some take a deeper look into possible underlying plots that reveal material that may no longer be deemed acceptable and â€Å"G-Rate†. Robert Gooding Williams, the author of Disney In Africa And The Inner City: On Race And Space In The Lion King, argues that The Lion King depicts urban decline in the United States. â€Å"The Lion King marks the elephant graveyard as inner city. It uses Whoopi Goldberg's and Cheech Marin's voices to represent the speech of two of the three prominent hyena characters as Black English and Latino slang respectively,† (Gooding-Williams). He views The Lion King to be degrading to some races with inappropriate themes. Matt Roth, another scholar, argues in his article The Lion King A Short History of Disney-Fascism, that Disney supports monarchism and fascist themes due to the story line of The Lion King. The Lion King echoes all of its fascist themes: hatred of gays, communists, and minorities, and the glorification of violent male initiation and feminine domesticity all set in a bucolic suburban environment under the strong leadership of an all-male state,† (Roth). He argues that Mufasa, the King, rules as a communist or monarchist because all animals in the beginning of the movie bow down to him instead of fleeing from a predator as they would in reality (The Lion King). Annalee Ward, author of the article The Lion K ing's Mythic Narrative argues that The Lion King is a biblical narrative that can teach children good moral values. Ward uses the example of Simba, Mufasa’s son, returning home to save the Pride Land from evil, or Scar, Mufasa’s wicked brother, and compares it to the prophecy in the Bible of Jesus returning to save humanity from evil. Although all of these scholars have valid argument that have clear correlations to the movie, an argument that was not presented was how closely The Lion King’s story line matches that of a famous Shakespeare play. I argue that The Lion King does not necessarily have an underlying plot that can only be perceived as our society, but instead is simply based off of Shakespeare’s Hamlet. The overall theme of both Hamlet and The Lion King is about responsibility and revenge. The death of the princes’ fathers leaves both characters extremely downhearted. Hamlet Jr. and Simba both go through a confusing and mournful stage after losing their fathers. At one point in both plots, both Simba and Hamlet Jr. run from their responsibilities although both characters know what they need to do to avenge their fathers deaths. Another key part of the plot is that the two characters both see their father’s spirit, which is a turning point for them to avenge their fathers. Mufasa and Hamlet Sr. lso have striking characteristic resemblance. Both of the kings were killed by their own brothers. As kings, they both ruled their kingdoms with peace and prosperity and were well liked(McElveen). As deceased kings they approach their sons in spirit, but neither tell their son directly to kill their murder (McElveen). Although Hamlet Jr. actually does kill his uncle Claudius, Sca r is killed by the pack of hyenas that at one time served him as their leader and king. Not only do the protagonist allude to each other; the villains in Hamlet and The Lion King can also be compared to each other. Scar and Claudius, brothers of the kings, are both in pursuit to take over the throne. Once they have succeeded in killing off their sibling and taking over the throne, both enjoy the comfortable life of being a king. Claudius holds banquets in his own honor, and marvels at all his materialistic things. Scar allows the hyenas to hunt the Pride Land until every source of food and water has been depleted to almost non-existence while he lounges in his cave eating more than his fair share of food (McElveen). As far as secondary characters goes, The Lion King’s Timon and Pumba allude to Hamlet’s Rosencrantz and Guildenstern. Both pairs of characters act as a relief from the main focus in the story in both works (McElveen). Timon and Pumba introduce a carefree style of living (also famously known as â€Å"Hakuna Mata†) to Simba while Rosencrantz and Guildenstern are friends that Hamlet Jr. enjoys life outside of the royal house (McElveen). A lot of today’s entertainment can be related back to older literature. A lot of today’s literature can also be related to theories on societies, the bible, etc. When experiencing a new piece of literature, music, or film, it is important to keep an open mind. All of these things are considered to be a type of art and art is supposed to be open to interpretation. When interpreting The Lion King and other pieces, there are no wrong answers, just difference in opinions. Works Cited The Lion King. Dir. Roger Allers and Rob Minkoff. Perf. Jonathan Taylor Thomas and Matthew Broderick. Walt Disney Feature Animation, 1994. Videocassette. McElveen, Trey. Hamlet and The Lion King: Shakespearean Influences on Modern Entertainment. Rep. N. p. : n. p. , n. d. 17 Apr. 1998. Web. 19 Apr. 2013.

Choose a federal law Research Paper Example | Topics and Well Written Essays - 3750 words

Choose a federal law - Research Paper Example This policy paper will identify the history of the Act; trace its implementation, its impact on business and society as well as its strengths and weaknesses. Additionally, the paper will provide some recommendations for future policy makers. The legislation which came to force in 2002, has 11 major elements. The key provisions that this paper will analyze their implementation include Sarbanes-Oxley Sections 302, 303, 401, 404, 802, 906 and 1106. Sarbanes- Oxley was named after its sponsors Paul Sarbanes and Michael Oxley who were US Senators and Representative respectively. With the implementation of SOX, it became mandatory for top managements to personally certify the accuracy of the information that is provided by their organizations. Between 2000 and 2002, large corporate frauds occurred in various firms due to variety of complex factors. In addition to Worldcom, and Enron as noted earlier, other frauds included Adelphia, Tyco International, and Peregrine Systems. Apart from the conflict of interest that emanated from the frauds, they also resulted into problems during the incentive compensations practices. Through the analysis of the infamous frauds, the pioneers attained the ground for the introduction of the bill leading to the passage of SOX in 2002. According to Senator Paul Sarbanes, the market had problems that resulted to loss of hundreds and trillions of billions in dollars. Some of the notable issues that led to the mega frauds included lack of independence for the auditors, inadequate accountant’s oversight, conflict of interest on the part of stock analysts, weak corporate government procedures, ineffective disclosure procedures and providing low funds to the Securities and Exchange Commission. Before the introduction of SOX, auditing firms which are noted as watchdogs for the investors did not perform auditing or any consulting

Accounting for corporate accountability Essay Example | Topics and Well Written Essays - 2000 words

Accounting for corporate accountability - Essay Example Post-modern corporate business has become a powerful economic force in the industrialized world.Accounting practices are currently focused on corporate accountability, which involves the understanding of current concerns regarding responsibility and accountability to stakeholders. Post-modern business discourse is focused on the economic and social consequences of corporate practices (Elliott and Elliott, 2006). Transparency, though, must also take into account the subjective nature of gathering, analyzing and presenting data as published accounting information. The fear that corporate managers might act contrary to the interests of shareholders and not be concerned with those with whom the corporation contracts (creditors, workers and consumers) is of primary concern (Benston, 1982; Schreuder and Ramanathan, 2002). Others may be harmed by corporate actions (externalities). The ways in which social responsibility accounting can be used to measure and serve as a means of controlling e xternalities is of research interest.Revenue recognition practice is an ambiguous accounting term, in that there is to date, no internally standard definition. This complicates the process of making comparisons within and across companies. A popular characterization of the concept is that revenue recognition practices are revenues that should not be recognised by a company until it is realised or realisable and earned by the company (Elliott and Elliott, 2006; Turnover, 2001). ... The IASB requires four tests: (a) the amount of revenue can be measured reliably; (b) it is probable that the economic benefits associated with the transaction will flow to the entity: (c) the stage completion of the transaction at the reporting date can be measured reliably; and the costs incurred for the transaction and the costs to complete the transaction can be measured reliably (Leo, Hoggett, Sweeting, & Radford, 2005, p. 75).This paper aims to review the recognition revenue of iSOFT in 2006, which had a revenue recognition adjustment of 174 million due to overstating revenue for long term contracts. A change in accounting policy by the board for future recognition has been implemented in the 2006 Report. And goodwill impairment write-off has resulted in a loss for 2006 financial year. Investigation continues into these issues. A brief background of ISOFT Corporation will first be provided. Secondly, a critical review of the consequences of the change on economic and social dimensions will be presented. Finally a conclusion will synthesise the main points and show support for an internationally standard definition of revenue recognition, and for the adoption of accrual accounting methods. Background of iSOFT.iSOFT is a global leader in the supply of medical software for health care services. Over 8,000 organisations across 27 countries use iSOFT products and services; an innovative company with several target markets specializes in software design, development and solution delivery (iSOFT Annual Report, 2006). During the latter half of the 2006 financial year many changes were taking place for iSOFT, and the January trading statement, together with a related trading update issued on 28 April 2006, had a negative impact on the Group's

Final Essay Example | Topics and Well Written Essays - 1000 words - 2

Final - Essay Example US commission on Civil rights serves as an overall advisor as well as a watchdog and the country’s civil rights division within the department of justice bears the responsibility of enforcing non-discrimination statutes. Nevertheless, the dispersion of responsibilities in agencies with different agendas affected the process of affirmative action implementation. However, all the agencies were concerned with application of non-discriminating policies to the various segments of the US economy despite the rise of various jurisprudence disputes even within their spheres of action; besides administrative actions were related and affected other spheres. By the turn of the twenty-first century, a small number expressed support for racial discrimination after the civil rights movement progressed from obscurity during the civil war to mid-twentieth century activism to the current accepted wisdom. The non-controversial part is the reactive policy that ensures non-discrimination based on race, religion, color, sex and national origin in social, economic and educational affairs. The non-discrimination laws are designed to make sure that individuals are never judged by color of skin, but rather by the content of their character and incase a violation occurs, such individuals are entitled to remedies (Lee, 1999). Positive and Negative Results of Affirmative Action Legislation Affirmative action seems to have a short history though it is a hands-on policy that makes special efforts about employment decisions, entry into college and other public behavior as a means of compensating for past discrimination. Affirmative action bases on the thought that various groups of people even without being discriminated against currently, any individual belonging to such groups are disadvantaged in the workplace and in campuses as a result of the past discrimination aimed at the group. Therefore, affirmative action attempts to level the playing ground for all categories of citizens th ought it emphasizes on disadvantaged groups as opposed to injured individuals. Affirmative action can refer to a court-ordered, remedial programs designed to correct effects of discrimination documented in court. Proponents of affirmative action hold that affirmative action provides long-term cure for discrimination by offering victims chances to show their skills and worth, which eventually changes prejudicial attitudes. Nevertheless, opponents of this controversial program argue that affirmative action never addresses the cause of inequality and the program can create labor market inefficiencies and result in reverse discrimination. Therefore, both sides suggest that effective affirmative action would cause minority employment to increase however; the sides disagree on whether this raise is efficient and on whether it would be sustainable if affirmative action ended (Lee, 1999). Currently there is small opportunity to measure the impact of eradicating affirmative action programs. As Federal, support for enforcement faded and flowed, the Supreme Court ruling in the past decade chipped away at affirmative action making it difficult to confirm whether concurrent changes in minority outcomes are due to affirmative actio

4 Discussions Essay Example | Topics and Well Written Essays - 2000 words

4 Discussions - Essay Example The women were also allowed to read books, but they were restricted to read some books and avoid others. According to the ‘cult of domesticity’, women were given ‘separate but equal’ status. Like men, they were assigned some tasks to perform, but they were of different nature. Women were not allowed to choose their life partners and after their marriage, their lives were designed as per their family needs. Marriages meant chained status for women (Zinn). The cult of domesticity introduced women to their equal status in society that was quite different, but in fact, in this manner women became aware of their subordinate status in the society. They were not allowed to vote and to possess property. In addition, if they were required to work outside their homes, they received one fourth of the wages that men obtained. They were also restricted not to join certain professions such as law and medicine. Therefore, cult of domesticity was not a way of pacifying her with a doctrine of separate but equal, but to inform her about her restrictions and limitations according to which, she should lead her life. She was expected to lead her life as per the proper codes of conduct designed for her. She enjoyed little or no liberty and was to remain passive and submissive to patriarchal system of the society. For becoming a perfect woman, she was to acquire the qualities of submissiveness and domesticity (Zinn). The role of wife and mother in America as well as in other parts of the world still undergoes certain restrictions because there are certain norms and standards, according to which, a wife and a mother are required to act. Male members of out society have always kept certain expectations with women and their roles in the society. A woman is not accepted with everything, as she is required to bring changes in her personality

Levels in a Class Essay Example | Topics and Well Written Essays - 500 words

Levels in a Class - Essay Example That is why it is necessary to provide them with a wide range of opportunities to further improve and develop the previously acquired skills, as well as acquire and perfect new ones. So, first of all, a teacher must ensure that all the classroom students feel comfortable and secure in the given learning environment in order for their learning to be effective and productive. Successful teaching in such a case entails efficient differentiation of instructions, first of all. That is, weaker students should get easier, corresponding to their proficiency level, tasks to complete, so that they don’t loose confidence in own abilities. In such a way, they will feel comfortable with the learning process. Besides, performing tasks corresponding to their level, and based on the knowledge and skills they acquired before, will ensure that there will be no gaps in their learning process, that it is being conducted gradually and consistently. This, of course, is related to the stronger students as well. Differentiated instructions tasks may include large and small group, as well as individual assignments. Successful grouping strategies may become an effective way to solve certain problems: working in mixed groups of different competency levels will, for example, improve weaker students’ skills and abilities as they learn from stronger ones working together with them for achieving a common goal. Working in groups of same competency level will, in its turn, give weaker students an opportunity to fully show one’s potential, while encouraging for achieving better results observing the work of a stronger group. However, no matter what methods a teacher chooses, one should be sure to prepare a variety of learning materials of various levels so that the learning needs of all the students in the classroom are met (DelliCarpini). As a result, performing tasks

Managing Finance Research Proposal Example | Topics and Well Written Essays - 500 words

Managing Finance - Research Proposal Example it mainly emphasizes on the projecting the demands (De-Almeida & William, 2014). Therefore, Wal-Mart mainly use of the flexible and static budgeting process and procedures. It is dependent on the forecasted demands that are based on the past sales and projections of the new products, season, consumer behavior and perception for developing budgeting processes. The management accounting system of Wal-Mart have been constantly changed and upgraded according to the advancement in the information technology and business environment. Currently, the company emphasizes on Just In Time, Inventory management and Economic Quantity Order techniques used in its management accounting system (Anon., 2014). However, these management accounting systems of the company has been amended with the passage of time. Wal-mart is focused on the low costing strategies. Hence, the adoption and changes in the management accounting systems of the company has been taken place time to time. The determinant to prevailing changes in the management accounting system is dependent on the external factors that the company aims to anticipate. The costing processes of Wal-Mart are very well maintained and are done by professional auditors all over the globe. The practices carried out in the factories are analyzed and are further characterized so that better check and balance can be made. The requirement standards of Wal-Mart, Labor policies, the payroll of the workforce, the rules and regulations provided by the Law are being followed within the factory or not? And the health and safety conditions are the essential of the â€Å"Audit Reviews†. After the examination of the practices of the factories Wal-Mart takes the decision to work with the factories or not (Bandy, 2013). The Wal-Mart is working in three major businesses. The priority of the organization is to improve the financial organization; this is due to the drastic changes in the financial sector. The

Should women be allowed in combat(arguing against the issue) Research Paper

Should women be allowed in combat(arguing against the issue) - Research Paper Example The difference between men’s and women’s abilities comes from the difference in organization of their bodies. For example, female pelvis is arranged in a way so that women are able to bear children, and such an arrangement results in an off-angle of the legs making women about 10 percent slower runners than men. Also, women have less upper-body strength than men do. Therefore, they would not be able to carry an 80-pund backpack, drag a casualty, properly throw a grenade etc. Women are more easily injured compared to men because they have weaker muscle structure (Tips). In fact, in accordance with the research conducted within the British army, only 1 in 100 female soldiers had enough physical strength to function in military units (Browne). Overall, women are really the weaker sex and should not be allowed in the frontline combat roles. Secondly, women should not be allowed in combat because of the peculiarities of combat environment (Simons). Placing a scarce resource, such as women, in combat units comprised mostly of men may result in the creation of competition between the latter, and this may lead to conflicts within the unit. In addition, it is obvious that when young women and men work together for extended periods of time, couples form. At a certain point, their interaction can make lives of other soldiers uncomfortable. In this case, it is also important not to forget about pregnancy, which makes women be unable to discharge their duties. Finally, allowing women in combat is anti-survival of any society (Tips). The matter is that women play more important role in repopulation of the society. This does not mean that woman’s role is to give birth to children only. It means that woman’s role in giving birth is more important. Compared to men that can father several children during a year, women can give birth only to one (or two or three in case twins or triplets are born). Woman’s health, commitment and time are more essential to the

Racism and the Value of Justice in To Kill a Mockingbird Movie Review - 4

Racism and the Value of Justice in To Kill a Mockingbird - Movie Review Example Relatively, it is our decisions that shape our intentions in life, regardless of racial and socioeconomic differences. This idea is shown through the characters of Boo Radley, Atticus Finch, Tom Robinson, and Violet Ewell. Specifically, the theme is most noticeable during the courtroom scene wherein Atticus Finch, a White lawyer, defends Robinson, a Negro man, against the accusations of Violet Ewell, a White young lady. Towards the end of the film, Radley emerges as another significant and controversial character, and this is because he killed Bob Ewell, Violet’s father. 2) What were the choices made by the main characters and what were the consequences of those choices? The most interesting characters in the film are Atticus and Radley because their decisions create interesting ideas about what the film really means in relation to Racism, crime and the American justice system. For instance, Atticus’ decision in defending Tom Robinson negates the stereotypical notions a bout the antagonism between Blacks and Whites. Specifically, Atticus’ character signifies the objective American who values facts more than anything else in the courtroom. However, Atticus’ decisions and principles go against the verdict of the jury, who still dwell in their prejudiced notions about Blacks. Radley is another interesting character because of his strange involvement in the Violet Ewell vs. Robinson trial. For instance, one can become curious about Radley’s true intention of killing Violet’s father, who had forcibly pushed Robinson to plead guilty to the rape case. In this case, one can ask â€Å"Is killing an alternative to justice?† In analyzing Radley’s character, one can say that he signifies the persona of a radical American who aspires for change in society, a chance that even a qualified lawyer like Atticus cannot achieve through his legal and formal courtroom rules. Relatively, although Radley emerges only in the last p art of the film, his role in the film is as significant as Atticus’, and this is because of the diversion he brings to the film, which also creates new perceptions about the film, in general. 3) What are three or four sequences most important in the film? Why? Although the story is a narration, the plot of the film follows the chronological order of events wherein viewers sees the sequential interplay of scenes. The three most significant scenes in the film are the projection of the innocent Alabama life, in the first part of the film, the courtroom scene, and the death of Bob Ewell. The first scenes of the film introduce the viewers to the carefree, innocent life of Alabama, particularly with the Finch kids. However, as the narrator said, their carefree life was only the superficial aspect of reality during those times, considering the Depression that struck most people on the American continent. Further, the courtroom drama shows the social and political issues in American during those times, particularly concerning the prejudicial jury and stereotyping of the Negroes as criminals and untrustworthy. Lastly, the death of Bob Ewell signifies another interesting topic in the film, which is about the intentions and motivations in committing a crime.  Ã‚  

A study of the famous Bob Dylan song Mr.Tamborine Man Essay Example for Free

A study of the famous Bob Dylan song Mr.Tamborine Man Essay Why Mr. Tambourine Man is A Modern Classic The most obvious and popular interpretation of Bob DylansMr. Tambourine Man is that the song is about drugs. This makes sense, as it was against the law to write songs about drugs in the 1960s when Mr. Tambourine Man was composed. The metaphors are simple: Mr. Tambourine Man is the drug-dealer. Take me on a trip upon your magic swirling ship is asking the drug-dealer for the drugs, and then the lyrics go on to describe the physical effects on the body after consuming hallucinogens: My senses have been stripped My hands cant feel to grip My toes too numb to step. . . Another obvious reference to drug-taking comes from the fourth verse, Take me disappearing through the smoke rings of my mind The smoke rings relating literally to drugs being smoked, and the last line of the last verse, also if taken literally, relates to escaping from the realities of life by using drugs: Let me forget about today until tomorrow. However, this interpretation does not explain some of the vivid imagery used throughout the song where it is not easy to draw parallels between drugs and the image, for example, The haunted frightened trees. This phrase could be written about the emotional state of the drug user, and by embuing those emotions onto something else the surreal atmosphere already invoked in the earlier passages is heightened. In the second and third verses there are several lines expressing suprise at feeling fatigued: My weariness amazes me and how the body is also tired: my toes too numb to step. Bob Dylan said himself Drugs never played a part in that song disappearing through the smoke rings of my mind., thats not drugs, drugs were never a big thing with me. This leads me to believe that the song is indeed about something other than drugs. Some analysts have written about the song as an expression of freedom. One clear example of a phrase  that expresses a sense of freedom is, To dance beneath the diamond sky with one hand waving free/ Silhouetted by the sea This image strongly evokes the idea of someone living freely, both literally, dancing a beach, and the connotations that the sea and the sky provide here, of openess and liberty. There are several references to escaping, for example, Im ready to go anywhere, but for the sky there are no fences facing which means that the sky is the limit, just escaping on the run and again Let me forget about today until tomorrow. These lines fit with the freedom theme: escaping to achieve freedom. But forgetting about today until tomorrow seems only a temporary escape, bringing the back the idea about drugs. It has also been suggested that Mr. Tambourine Man is a poem about transcendence, or reaching enlightenment. Some people see Bob Dylan himself as Mr. Tambourine Man, and he does Cast [his] dancing spell through the magical and fantastic imagery of swirling ships and trips into ones own mind. I believe that the song could be about all of these ideas, and the importance of one in particular relating only to the mood of the listener. This is an important reason for stating that Mr. Tambourine Man is a classic: The lyrics provide the possibility to understand the song in different contexts by different listeners. The ideas differ between people, some finding freedom in Dylans song, some feeling like they are under a spell when listening to the light repetitive tune and figurative language. The cleverness of the language is that people can read almost anything into it, the most basic example being Mr. Tambourine Man, who can be seen as anything from a drug-dealer to a religious man to Bob Dylan himself. Another reason that the song has such a hallucinogenic feeling is the structure of the song. The verses are made up of what appears to be many individual concepts put together, like a dream, giving a surreal effect. The reference to Ozymandius and crumbling empires furthers the dream-like quality of the words.

French Essays Nineteenth Century French Fiction

French Essays Nineteenth Century French Fiction The Representations of Women in Nineteenth Century French Fiction Discuss the representations of women in La Curee (by Zola),Germinie Lacerteux (by Edmond et Jules de Goncourt), La Dame aux Camelias (n.bthe play, not the novel by Dumas fils) and Le Spleen de Paris (by Baudelaire). This research investigates in depth therepresentations of women in such French fiction as La Curà ©e by Emile Zola,Germinie Lacerteux by Edmond and Jules de Goncourt, La Dame aux Camà ©lias by AlexanderDumas the younger and Le Spleen de Paris by Charles Baudelaire. The receivedfindings suggest that in these literary works the writers maintain the ideas ofrealism and naturalism in regard to female characters, rejecting the romanticportrayal of females and stressing on their freedom and sexuality. Somefindings of the dissertation are consistent with the earlier studies of Frenchliterature in the nineteenth century, while other results provide newinterpretations of a female issue. 1 Statement of the problem The representations of women in Frenchliterature of the nineteenth century reflect the writers attempts to providetheir own vision on females in the era of Libertinage, praising theirprinciples of liberty, but implicitly criticising their sexuality and weakness.Contrary to Romantic writers, such authors as Emile Zola, Charles Baudelaire, AlexanderDumas the younger and the Goncourt brothers adhere to the ideas of realism andnaturalism in their portrayals of women, proving that only the observation of differentsides of a persons essence can provide understanding of the reasons behindfemale degradation and failure. In this regard, these writers represent theirfemale characters through social, cultural and familial contexts. 2 Introduction In France the nineteenthcentury was characterised by various social changes that gave rise to theprinciples of libertinage and equality, but also negatively influenced the mostsubordinate group French females. The pleasure became the principal featureof French style of life. In view of these changes French fiction of thenineteenth century was divided into four literary movements: naturalism,symbolism, romanticism and realism. Although the currents differed from eachother, they stressed on the importance of a person and the rejection of purereason and social standards. Following these movements, French writers started todiscuss a female issue through their female characters, uncovering such negativesocial phenomena as female subjugation, divorce, prostitution, psychologicaldisorders of women and depopulation. In particular, they revealed that, despitefemales attempts to achieve equality with males, society continued to impose certainsocial norms and stereotypes on women, depriving th em of the possibility tofollow their own paths. A woman who worked as a prostitute or a servant wasusually regarded as a subject, a person of secondary importance in patriarchalFrench world, but it was this female who was often portrayed innineteenth-century fiction. The aim of thisdissertation is to discuss the representations of females in La Curà ©e by EmileZola, Germinie Lacerteux by Edmond and Jules de Goncourt, La Dame aux Camà ©liasby Alexander Dumas the younger and Le Spleen de Paris by Charles Baudelaire.The paper is divided into several chapters. Chapter 1 provides a statement ofthe problem that reveals the core of the analysis. Chapter 2 reflects a generaloverview of the issue, observing the social and historical contexts of theperiod when the discussed works are written. Chapter 3 evaluates some criticalanalyses of nineteenth-century French fiction. Chapter 4 demonstrates thetheoretical research methods that are utilised in the research. Chapter 5investigates in depth the representations of women in each novel, focusing onboth principal and secondary female characters. Chapter 6 summarises thereceived results, and Chapter 7 points at the limitations of the dissertation andproposes some suggestions for further research of Zola, Edmon d and Jules deGoncourt, Dumas the younger, and Baudelaire. 3 Review of the literature Nineteenth-century French literatureattracts attentions of various critics who provide rather contradictoryviewpoints on literary works of French writers. This can be explained by thefact that in the period of the French Revolution and Libertinage, Frenchliterature began to move away from the traditional portrayals of characters to themore realistic representations. As Desmarais puts it, all the writers of the19th century are more or less romantic; but none of them could bedescribed as traditional. Introducing innovative elements intotheir literary works, these French writers made attempts to either uncoverdifferent sides of reality or to contrast the nineteenth century with the past.For instance, analysing the literary legacy of Edmond and Jules de Goncourt, ElisabethBadinter cites words of Juliette Adam who claims that the Goncourts so lovedand frequented eighteenth-century women that they despised the women of thenineteenth, consigning them to wickedness, debauchery or imbecility. Charles Baudelairescollection of prose texts La Spleen de Paris was published only after his deathand the critics paid no attention to this literary masterpiece; only at thebeginning of the twentieth century Baudelaires work was acknowledged as one ofthe best prose fiction. In particular, Robert Kopp draws a parallel between LaSpleen de Paris and Baudelaires poetry, pointing at the fact that these prosetexts reflect the themes raised in the majority of Baudelaires poems.Emile Zolas novel La Curà ©e was exposed to censure since its publication, butat the end of the twentieth century it was praised by modern critics as asplendid literary work of naturalism. Contrary to Zola and Baudelaire, the playLa Dame aux Camà ©lias by Dumas the younger was accepted by French audience ofthe nineteenth century with delight, and its principal character Marguerite becamethe prototype of many female characters in films, plays and musicals. One ofthe most famous opera produced on Dumas play was Verdis La Traviata. 4 Research methodology The research in this dissertation isconducted, utilising a social constructionist approach and a feminist approach.Applying to these methods, the paper analyses the representations of women fromdifferent perspectives and interpretations. The social constructionist approachuncovers the impact of society on the formation of women and its attitudetowards those females who reject the existing stereotypes. Thus, this method iscrucial for investigating the portrayal of women in French fiction. Anotherappropriate method is the feminist approach that is aimed at observing genderissues in literature, criticising patriarchal society that specifically createsthe differences between men and women and imposes specific roles on women. Asfemales have been usually conformed to certain stereotypes in literature, thefeminist approach makes an attempt to destroy these stereotypicalrepresentations. In this regard, both approaches analyse the portrayal of femalesin nineteenth-century French fiction throu gh social contexts. 5 Discussion 5.1. Naturalism of La Curà ©e by EmileZola Emile Zola belongs tothose writers who in their literary work present the characters that areclosely connected with their environment. In the novel La Curà ©e Zola reflectsfemale characters through social contexts, demonstrating the impact of theenvironment on them. Thus, the writer is more interested in the temperaments ofhis women rather than in other aspects of their personalities. Zola considersthat female temperaments can explain their emotions and actions, theirrelations with other people and their attitudes to the world, in which theylive. In La Curà ©e female characters are greatly influenced by the events of theSecond Empire and the changes that Baron Haussmann introduced in Paris. As a resultof these changes, Zolas women are in search of pleasure and money. After thedeath of Aristide Rougons wife, the character is left with two children anddecides to marry a wealthy female Renà ©e Beraud de Chatel, transforming his nameinto Aristide Saccard. Their marriageprovides Aristide with financial security, but this marriage of conveniencesproves to be unfortunate for the principal female character that is finallyleft without means of subsistence and a family. Renà ©e looses her childrenduring pregnancy and becomes engaged in various sexual intercourses. At firstshe initiates the relations with Saccards son, until he marries anotherwealthy but very ill woman Louise who dies soon after the marriage. Thus, Zolacreates two male characters a father and a son who marry women withdisabilities for money, because they do not have another way to enrichthemselves. But Zola doesnt consider that these men are responsible for femalesfailure. Renà ©e is portrayed as a woman who constantly suffers from neuroticattacks and devotes her life to balls, talks and sexual pleasures. Renà ©eappears to be a product of French patriarchal society that puts a woman into asubordinate position, destroying her self and making her suffer from ownweakness. According to thefeminist approach, such subjugation results in negative consequences for awoman, because she starts to substitute one extreme for another. Inother words, a woman turns from excessive subordination to uncontrollablefreedom. Before her marriage to Aristide, Renà ©e gets pregnant and is abandonedby one of her lovers, and Aristide appears to be a rescue for womansreputation. This female character is portrayed as a simple sensualist who findsreal pleasure in social life and sexual relations. When she meets Aristidesson Maxime, a young teenager who greatly resembles her, she becomes his lover. Althoughthe writer implicitly criticises Renà ©e, he constantly points at the fact thatit is French society that shapes this female who finally destroys not onlyherself, but also people around her. Renà ©e is against Maximes marriage toLouise, considering her to be a weak and ugly girl. She is not able to realisethe power of money for such people as Maxime and Aristide; she is used to spendmuch money and she regards it only as means that help her exist in Frenchsociety. Renà ©e is emotionally involved into the affairs with Maxime and sheutilises this young person for her own pleasures. This female is amazed bythese forbidden relations and doesnt want to think about the consequences ofher action. In the characterof Renà ©e, the writer embodies the essence of Parisian life; similar to Paris,Renà ©e is obsessed with luxury and pleasures, but behind this gorgeousappearance there are degradation and suffering. This female character reflectsreality of the nineteenth century when people run to certain extremes and werefurther destroyed by these extremes. Renà ©es wrong ideals are a result of herlack of appropriate education and social permissiveness that deprive a youngwoman of creating a normal family with loving husband and children. By the endof the narration Renà ©e is completely destroyed by her obsession with pleasure;but Zola observes her weakness and foolishness through the social pressure thatshe is not able to withstand. As Zola puts it, she had slid down a slipperyslope, yet she had not remained passive the whole way down. Desire had awakenedin her too late to combat it, after the fall had become ineluctable. The same regardsthe secondary female character of the novel Angà ¨le, the first wife ofAristide. She is also portrayed as a weak, passive and unhealthy female who isnot able to endure life in Paris. Contrary to Renà ©e, Angà ¨le is not involvedeither in social life of Paris or in sexual relations because of her povertyand poor health, but her submissiveness is also formed by society, in which shelives. As Zola claims, To be poor in Paris is to be poor twice over. Angà ¨leaccepted misery with the passivity of the anemic woman she was. She spent herdays either in the kitchen or lying on the floor playing with her daughter.Angà ¨le is really devoted to her husband and children and refuses to be isolatedfrom young Clotilde when Aristide decides to move to Paris. However, Paris, thecity of changes in nineteenth century France, requires changes in individualsas well. Those people who fail to adjust to these changes are destroyed, thatis just the case with Angà ¨le. Aristides firstwife appears too kind and weak, the features that do not allow her to survivein the cruel and degrading Parisian world; however, such characters as MmeSidonie, a sister of Aristide, is aware of the role of money in Paris. Zolaportrays this secondary character as a person who eliminates her emotions andinstead applies to pure reason. When Sidonie visits a dying Angà ¨le, shecompletely ignores any morality or decency in her talk with Aristide: She wasa good woman, his sister continued, speaking as though Angà ¨le were alreadydead. You can find women who are wealthier. Zola criticises suchfemale scorn, implicitly demonstrating that Paris destroys the souls of womenand makes them act, like machines, without any emotions and feelings. Thisrealistic portrayal reflects the negative impact of certain social norms onindividuals. Sidonie is used to interfere into the lives of other people anddecide their fates. Therefore, in his representations of women Emile Zolastresses on t he fact that power and wealth deprave females in France, butsimultaneously he contrasts these mean women with such good females as Angà ¨leand Cà ©leste. As the writer describes, Cà ©lestes devotion pleased Renà ©e all themore because she knew her to be honest and thrifty, a woman without a lover anduntouched by vice. 5.2. Misogyny in Germinie Lacerteux Similar to Zola, Edmondand Jules de Goncourt in their literary work Germinie Lacerteux create thefemale characters that reflect the ideals of femininity existed in Frenchsociety in the nineteenth century. Although their women reveal certain liberty,they are too preoccupied with their own sexuality. Through their femalecharacters the Goncourt brothers reflect their misogynistic vision of femaleswho are not able to suppress their sexual desires and who become the slaves oftheir natural instincts. Throughout the narration Edmond and Jules de Goncourtexpress their longing for eighteenth-century females with their refinedappearances, exquisite manners and flirtation; they long for the period ofstrong aesthetic values and cultivated morality. Thus, their female charactersare usually portrayed as depraved females who end tragically because of theirweakness, poor education and lack of intelligence. GerminieLacerteux, the principal female character, is a woman who is sexually abused inearly years and who is not able to marry when she comes to Paris. However, hermotherly instincts are too powerful and she starts to look after a niece andanother child Jupillon. But when Jupillon is transformed into a man, Germinieexperiences a sudden passion towards him, and it is this passion that destroysher reputation and turns into poverty, because the love had been for theJupillon young person only the satisfaction of a certain curiosity of the evil,seeking in the knowledge and in the possession of a woman the right and thepleasure of scorning it. When Jupillon abandons Germinie, shestarts drinking and is involved in numerous sexual intercourses that bring herto death, similar to Dumas Marguerite and Zolas Renà ©e. In this regard, Edmondand Jules de Goncourt uncover female passion that can gradually destroy a womanand depreciate her, criticising Germinies uncontrollable sexual desires andins tead maintaining the ideas of female virginity. As Jupillon tells Germinieduring one of their talks, you appear yourself well still, you are not myheart, you are not my life, you are only my pleasure. Contrary toother French writers of the nineteenth century that mainly portray females fromthe upper-class society, the principal female characters of Edmond and Jules deGoncourt belong to the middle-class. Such shift from aristocratic females topoor females reflects great realism of the narration, eliminating romanticismthat is usually utilised in French novels. The Goncourts naturalism explainsthe reasons of female sexuality and their further failure. According to the writers,it is really difficult for such a woman as Germinie to suppress her naturalinstincts and adhere to social morality that rejects any powerful emotions.Such females make attempts to change their conditions of living, but finallythey appear in the similar conditions as at the initial stage of life. TheGoncourts present this viewpoint not only on the example of Germinie, but alsoon the example of a secondary character Miss de Varandeuil, an old kindspinster who hires Germinie as a servant to her and who becomes ful ly attachedto a young girl. As Edmond and Jules de Goncourt put it, This old womanisolated and forgotten by death, only at the end of her life, trailing heraffections of tomb in tomb, had found her last friend in her servant. However, suchclose relations between a master and a servant are not unusual fornineteenth-century French literature that usually reflects female servants asdevoted and hardworking people who gradually occupy the principal place in thenarration. Despite their different social positions, Germinie and Miss deVarandeuil finish their lives in loneliness, with the only difference thatGerminie doesnt suppress her sexual desires, while Miss de Varandeuil isolatesherself from the rest of the world, as well as from her powerful emotions.According to the social constructionist approach, a woman is created bysociety, in which she lives; thus, her sexual behaviour is also formed by theenvironment. In this regard, the differences in sexual desires ofGerminie and Miss de Varandeuil can be explained by their different backgroundsand upbringing. Miss de Varandeuil is the representative of a brokenaristocratic family that loses its fortune during the French Revolution, whileGerminie comes from a middl e-class society that adheres to easier manners. 5.3. Realism of La Dame aux Camà ©lias The play of Dumas theyounger La Dame aux Camà ©lias portrays a beautiful prostitute Marguerite Gautierwho breaks the relations with her lover, Armand Duval, to improve hisreputation and soon dies of her incurable illness. In this female character thewriter embodies his lover Marie Duplessis who died at the age of twenty-three. Dumaspresents Marguerite as a romantic woman, despite the fact that her real lifewas not so romanticised. At the end of the play Marguerite claims that she haslived for love and she doesnt hesitate to die for love. By applying to suchtragic end, Dumas uncovers the social system of his times, when a woman fromthe middle-class couldnt be engaged in the relations with a male of the upper-class,or otherwise she could destroy his life and reputation. On the exampleof this character Dumas the younger reflects womans degradation, but Margueritesdeath as a result of illness evokes sympathy towards her. Marguerite saves notonly Armand, but also his sister who at last receives an opportunity to occupyan appropriate position in upper-class society. In this regard, a life of onefemale is sacrificed for the sake of another woman, although Marguerite ispresented as an unusual female with many virtues. She is not only beautiful,but is also intelligent and noble. In the play Dumas the younger portraysMarguerite as a person with a slender figure, white face and dark hair. She hasamazingly bright eyes, full lips and unusually white teeth. She possesses agood taste in her dresses, in music, in art and behaves in a noble way. But,above all, this courtesan has a big heart, expressing sympathy andunderstanding towards other people. As Dumas describes her, There was a kindof candour in this woman. You could see she was still in the virginity of vi ce.No wonder that Armand falls in love with Marguerite from the first sight;however, this popular French prostitute has never loved before she meetsArmand. As Armand tells the truth about his feelings towards her, Margueritelaughs at him, but he gradually persuades her in his love, and she returns hisaffection. When Armand speaks with his father, he says, Perhaps I am in thewrong, but I can only be happy as long as I am the lover of this woman. However, whenMarguerite finds out that she is ill, she realises that her past has deprivedher of future. Although noble people in nineteenth-century France were usuallyengaged in sexual relations with prostitutes, and these relations were regardedas natural, the situation was different in regard to love. The relations basedon love were fully prohibited by upper-class society, and an aristocratcouldnt love or marry a prostitute, because such action would destroy him.Marguerite has no choice, but to destroy the relations with her lover in themost complex period of her life. Dumas the younger reveals that Frencharistocratic society creates certain social norms; those persons who try tooppose to them, are excluded from society. Thus, Marguerite appears to be avictim of these social norms, as she is engaged in illicit sexual relationswith men. As these relations are concealed, they are ignored by society, butwhen they are exposed, they destroy the reputation of a person who belongs tothe upper-class. Marguerite realises that her bad reputation threatens not onlyArmand, but his family as well, and she decides to break her relations with theonly person she truly loves. Such actiondemonstrates that Marguerite is better than females of the upper-class, becauseshe understands her responsibility. Marguerite creates her own existence, but,as the writer puts it, Do not let us despise the woman who is neither mother,sister, maid, nor wife. Although this female character has neverbelieved in love and has utilised males for her own benefits, the relationswith Armand change her. Marguerite doesnt want to destroy Armands life, as shehas destroyed her own. As she tells him, your family would cast you off if youwere to live with a woman like me. Let us be friends, good friends, but nomore. Despite the fact that Marguerite takes this seriousdecision because of her sincere love to Armand, Dumas the youngersimultaneously shows that she adheres to the demands of French society.Marguerite is used to act independently, but in this particular case shedecides to reveal her subjection to society. In this regard, the writer provesthat the principles of Libertinage that w ere established in France in theeighteenth century were attributed only to males, while females were punishedfor any display of independence. In the case ofMarguerite, this female is first punished for her illegal sexual intercoursesand further for her love to Armand, the representative of the upper-class. Throughouther life Marguerite has collided with many obstacles and has successfullyovercome them. But she fails to defend her love against social prejudices.Contrasting Marguerite with females of the upper-class, Dumas the younguncovers the degradation of French society that rejects emotions and insteadadheres to the failed morality. When Marguerite abandons Armand without anyexplanation, he constantly humiliates her during their meetings. As Margueritefeels that her illness progresses, she comes to Armand one more time and she cantsuppress her desires. But Marguerite understands that she has to leave Armandwho is unaware of true reasons behind her escape. As a result, Armand destroysMarguerite during the ball by publicly giving money to her. After suchhumiliation Marguerite looses her friends and clients and dies in po verty andloneliness. In prologue Marguerites lover receives her letter and realises thetrue virtues of this beautiful and intelligent female. As Dumas claims, Margueritewas a pretty woman; but though the life of such women makes sensation enough,their death makes very little. In real lifeMarie Duplessie greatly influenced Dumas the younger, but it is he whoabandoned her, realising that he didnt have enough money to support this richcourtesan. However, as Dumas became more involved into the life of Frenchsociety, he began to observe the social attitude towards courtesans and decidedto reflect this attitude in his play La Dame aux Camà ©lias. Through the characterof Marguerite the writer reveals his own opinion of a female. He portrays abeautiful and intelligent woman, providing her with many virtues and love, butsimultaneously depriving her of the possibility to marry a person she lovesbecause of her bad reputation. When after their prolonged parting Armand asksMarguerite, whether she is happy, she answers: Have I the face of a happywoman, Armand? Do not mock my sorrow, you, who know better than any one whatits cause and its depth are. Thus, Dumas the younger implicitlydemonstrates that ideal love relations can be established only between a virginand a ma n with sexual experience. At the same timeDumas regards close relations between opposite sexes as a battle. AlthoughMarguerite has a kind heart and sincerely falls in love with Armand, she is nota virgin and is not able to fully belong to one man, with all her heart, bodyand soul. On the one hand, Dumas the younger reveals that a prostitute may be abetter woman than a virgin, but, on the other hand, he rises againstprostitution that transforms women into the subjects and deprives them of thepossibility to become good mothers and wives. According to the socialconstructionist approach, it was natural for a man of the nineteenth century toestablish sexual relations with different women, but women had to adhere tostrict social norms. In the play Dumas shows that the marriage with aprostitute is equated with a crime, but Marguerite redeems her reputation. Butsuch prostitutes, with a heart, were infrequent in Dumas time, although someof his secondary female characters are also beautiful and intelligent. Forinstance , he introduces M de N. into his narration, a prostitute and anacquaintance of Marguerite. As the writer characterises her, the man who wasthe lover of such a woman might well be as proud as M. de N., and she wasbeautiful enough to inspire a passion. When Armand utilises herto revenge Marguerite, she reveals an unusual intelligence when she claims,you love Marguerite, and you want to have revenge upon her by becoming mylover. You dont deceive a woman like me, my dear friend. 5.4. Ambiguity of Le Spleen deParis by Baudelaire Similar to Emile Zola,Baudelaire reveals his female characters through social environment; this isespecially obvious in his collection of prose texts Le Spleen de Paris, wherehe shows an impact of Paris on women. When Baudelaire arrived to Paris, he hadto live in various parts of the city, observing the life of women in theseplaces. In the text The Despair of the Old Woman, the writer reflects hissympathy to an aged female who experiences great despair, as she sees a childand wants to smile at him, but the child is afraid of this old woman who doesnthave hair and teeth. This lonely woman is horrified by such attitude and shecries: Ah! For us, unhappy female old women, the age passed to like, even withthe innocent ones, and we make horror with the little children that we want tolike. Baudelaireregards such women as victims of life who symbolise loneliness and misery. Applyingto such horror portrayals, the poet implicitly criticises those women who areobsessed with their material well-being, ignoring the reality and the beauty ofthe world around them. In Le Spleen de Paris Baudelaire draws a parallelbetween one woman and another, as well as between a man and a woman. In thetext The Wild Woman and the Small Mistress the poet presents a dialogue betweentwo females, uncovering their views on life. Though both persons belong to onesex, they are different, as the wild woman describes a mistress, you whichrest only on fabrics as soft as your skin, which eat only cooked meat, and forwhich a skilful servant takes care to cut out the pieces. Suchportrayal reveals the poets double vision, his attempts to evaluate varioussides of peoples consciousness. But Baudelaireis especially sympathetic to widows and old females who are forgotten andneglected by society. In his text Widows the poet provides a detailed portrayalof widows in the parks, claiming that it is easy to recognize them,because each widow reflects loneliness, pain and isolation. Baudelaireintensifies their misery by contrasting these lonely and poor widows withwealthy and idle people who walk in the park: It is always somethinginteresting that this reflection of the joy of the rich person at the retina ofpoor. These reflections show the ability of Baudelaire forobservations and his understanding of a female essence. In his text BeautifulDorothà ©e the poet describes a beautiful Dorothà ©e strong and proud like thesun who walks along the street, bare-footed, and smiles. Perhaps,Baudelaire ponders, she goes to a young officer to talk with him, thats whyshe is so delighted. Such is the image that the girl creates for the rest ofthe world, but no one knows that she gathers each piaster to redeem her littlesister. In another prose poem Which is the true one Baudelaire reveals thestory of a beautiful and unusual girl Bà ©nà ©dicta who is portrayed by the poet asideal. But as he claims, this miraculous girl was too beautiful to live a longtime and she dies very young. Baudelaire realises that femalebeauty and youth are temporary, and many good women die at an early age. In the textPortraits of Mistresses the poet describes four males who talk about theirmistresses, implicitly uncovering their inability to accept femaleindependence. According to the feminist approach, female characters are usuallyportrayed from two different perspectives: either as chaste wives, if theyadhere to the standards of patriarchal society, or as mistresses, if theyreject social rules and stereotypes. However, in La Spleen deParis Baudelaire reveals that such attitude is also aggravated by class andeconomic differences. 6 Conclusions The dissertation has analysed therepresentations of women in La Curà ©e by Zola, Germinie Lacerteux by Edmond and Julesde Goncourt, La Dame aux Camà ©lias by Dumas and Le Spleen de Paris byBaudelaire. In these works the portrayal of females reflects complex socialstereotypes and norms existed in French society. In the play La Dame aux Camà ©liasDumas the younger reveals that French aristocracy was engaged in sexualrelations with courtesans, but, as these relations became a threat to theirreputation, they destroyed any intercourse with their lovers. On the example ofthe principal female character the prostitute Marguerite Gautier the writerdemonstrates that a woman of a low social position with a reputation of aprostitute has no chances for better future, even if she possesses many virtuesand beauty. Although Marguerite sincerely falls in love with Armand Duval, sherealises that their relations destroy not only Armand, but his family as well.Suffering from an incurable illness, M arguerite nevertheless decides to abandonher lover for his sake. Thus, Dumas the younger proves that independent andintelligent females collide with many restrictions and stereotypes inpatriarchal world. The libertine ideas that were proclaimed throughout Francein the eighteenth century were mainly maintained by males, while womencontinued to occupy inferior position to men. Such female oppression wasaggravated by social biases of the upper-class towards people of themiddle-class, the biases that were mainly based on economical differencesbetween two classes. In GerminieLacerteux Edmond and Jules de Goncourt provide a misogynistic vision onfemales, trying to prove that women are too preoccupied with sexuality andsocial position. Similar to Dumas Marguerite, the Goncourts principal femalecharacter also belongs to the middle-class society and who is destroyed by herpassion to a young male. Following the principles of naturalism, the Goncourtsobserve a female from biological and social perspectives. Emile Zola goesfurther; in his novel La Curà ©e the writer reveals that social environmentshapes

E Coli On Bathroom Surfaces

E Coli On Bathroom Surfaces In this experiment, we aimed to test the common statement that Pine- O- Cleen kills 99.9 of E.Coli on bathroom surfaces .To test this myth we used sterile swabs, sterile physiological saline sterile pipettes. Tile was used to represent bathroom surface and E .coli culture to represent unclean or contaminated surface. E coli culture was spread on the tile with sterile glass spreader evenly and then Pine-O-Cleen was sprayed on it. Therefore in this experiment, the independent variable is the length of time E coli was on the surface of the tile used and the dependent variable is the number of E coli forming units (cfu) or the Percentage of E.coli cells remaining on the Nutrient Agar Plate and Malt extract plate after being cleaned using Pine-O-Clean and controlled variables were length of time E.coli was left on tile, type of bacteria onto the tiles (E.coli), the surface area that bacterial growth is tested on number of bacteria initially present on tiles By using sterile pipettes, sterile glass spreader and using a known concentration of e .coli culture (1 ml) and pine- o-cleen (1 ml) on both of the tiles used, other variables were controlled such as incubation temperature incubation time. Null Hypothesis: There is no difference in number of E. coli cells surviving on bathroom surfaces with or without treated with Pine -O-Cleen. The effect of pine o clean in removal of bacteria from a contaminated surface was tested in weeks 12 and 13. Basically we tested the effect of Pine-O-Cleen on E. coli cells on bathroom surfaces. The results of the experiment in week 12 identified that the number of cfu on each plate were too low to be accurate and dilutions did not had decreasing number of colonies and some plates had 0 colonies and even control had colonies in it , so calculations were not done that week. Results in week 13 we obtained approximated cfu were transferred from the bathroom tiles and after it was treated with pine -o- cleen. This was determined by counting cfu on pour plates of the undiluted solution from week 13. Table 1: Pour plate counts of serial dilutions and total number of colony forming units (cfu) transferred from the bathroom tile contaminated with E.coli culture to a swab and the ones treated with pine -o -cleen. * The values were accurate for wk 13 since they were in the range of 25-250 cfu/plate for 10-4, 10-5 dilutions and plates were having decreasing number of colonies as dilution factor was increasing. Interpretation and conclusion: As mentioned above, total number of bacteria transferred from the tile with E.coli which was contaminated and after it was treated with Pine Oà ¢Ãƒ ¢Ã¢â‚¬Å¡Ã‚ ¬Ãƒ ¢Ã¢â‚¬Å¾Ã‚ ¢ Cleen. Based on the results, it can be concluded that the pine O cleen has some effect on number of bacteria on the tile. Plates had decreasing number of colonies as dilution factor increased. There was roughly a 10 fold difference between successive dilutions. Although some bacteria survived the cleaning process, pine o cleen still kills germs on bathroom surfaces. Pine -O -Cleen possess antimicrobial substances and that surface bacteria die within minutes but it doesnà ¢Ãƒ ¢Ã¢â‚¬Å¡Ã‚ ¬Ãƒ ¢Ã¢â‚¬Å¾Ã‚ ¢t kill 99.9 of E .coli cells. In agreement with our results, previous studies have shown very little amount of pine o cleen is needed to kill a particular species of bacteria (Fidalgo, 2002). Other variables to consider is that length of time E.coli was left on tile, type of bacteria onto the tiles (E.coli), the surface area that bacterial growth is tested on number of bacteria initially present on tiles. Decontamination reagents used for flucloxacillin wipe sampling and degradation/stability tests included: isopropanol 50 and 70, ethanol 60 and 100, benzalkonium chloride 0.1 (Pine O Cleen), sodium hypochlorite 0.5 (Chloroclens), sodium hydroxide 0.03M and distilled water Previous studies have shown that Pine O cleen is very effective against bacteria and only 0.001 of bacteria was left behind after using Pine-O- Cleen . ( Fidalgo,2002). Based on our preliminary results, together with the results reported on other recent studies, which all suggest that pine -O-Cleen is effective against bacteria, we reject Null hypothesis since pine- o -cleen does have an effect on number of E.coli cells since in treatment we got 0 colonies. Critical evaluation of experimental design In week 12, we set out to evaluate the number of E. coli cells transferred from the surface of the bathroom tile with E .coli culture to a moistened swab. A dilution series was set up and spread plates of each dilution were performed. Unfortunately the number of CFU was too low to be accurate. Therefore the experimental design was modified in the second experiment in wk 13 to compensate for this problem. Due to limitation of the number of plates and bottles, the experiment was designed such that test in wk 12 were duplicated. We used 10-4, 10-5, 10-6 instead of 10-5, 10-6, 10-7.This introduced the possibility of variables due to potential differences in techniques and in concentration of E coli culture use. Therefore, the experiment could be improved by performing the duplicates at the same time, choosing treatments that altered the minimum of confounding variables, incorporating as many effective controls as possible, keeping number of replicates as high as feasible, Since total number of replicates available for the experiment were limited by resources, compromised between number of treatment and number of replicates per treatment, accounting for the time taken to apply treatments and then recording results, ensuring same number of replicates is present in each treatment, finding out the limitation on resources. If more materials were ordered like more bottles, tiles, NA plates it would have been ideal to increase the number of replicates for each test in order to make the results more statistically relevant. A recent study has demonstrated that the transfer of bacteria to food increased when cells were applied to the surface n the presence of growth media compared with dilution buffer (Moore et al, 2007). This additional variable could also be tested in future studies.