Council of Graduate Students Assignment Example | Topics and Well Written Essays - 500 words

Council of Graduate Students - Assignment Example There is no additional hierarchy amongst the general members. The group is egalitarian in its scope and all the members do have an important role in it. Each general member is expected to selflessly serve the new arrivals at the college and to acquaint them with the institution’s culture and values. In the case of any ambiguity or doubt, the general members can approach any of the five members of the governing body to seek help and advice. Under special circumstances, the governing body may assign special roles and responsibilities to a select group of general members. However, such groups happen to be task oriented and usually temporary and membership of such a group does in no way makes any general member superior to other members. As the membership of this group is open to all the college students and is voluntary in its scope and perspective, hence this group is very close-knit, bound by the common altruistic aspirations to help, guide and inform the new arrivals at the college. No specific norms tend to govern the group activities. However, the group members are strictly expected to not to succumb to any racial, ethnic, religious, or political considerations while serving the new students. In case it is found that any member has gone contrary to such aspirations, strict action is immediately taken, which usually comprises of a strong warning. A repetitive breach of the group policy may invite a tough action like a suspension from the group membership.

Sparknotes Extremely Loud and Incredibly Close Essay Example for Free

Sparknotes Extremely Loud and Incredibly Close Essay This chapter introduces one of the primary motifs of Into the Wild, that of documents. Because the books subject, Christopher McCandless, has died before author Jon Krakauer can meet him, Krakauer must rely on the testimony of the people McCandless encountered in order to stitch together the story of the young mans journey — and especially on the documents McCandless left behind. The first of these documents is McCandlesss S.O.S. note. Others will include his journals, the notes he made in the books he read, graffiti he scratched into various surfaces, and photos he took of himself. To these Krakauer will add maps of the places McCandless visited, relevant quotations from a wide variety of authors, and even a brief memoir of the authors own young manhood, inserted near the end of Into the Wild. All of these enrich our understanding of McCandless and help us to believe that the amazing story we read in Into the Wild really happened. The fact that someone as articulate and effective at communicating as McCandless died alone, having written a kind of letter (the S.O.S. note) that went unread until it was too late, is an example of irony. Also ironic: McCandless, who encountered no one during the four months between his entrance into the bush and his death there of starvation, is discovered not by one fellow trekker but by five — all within days of McCandlesss death. Chapter 3 This chapter begins to explore the character of Christopher McCandless in depth. Far from being a stereotypical slacker, he was hard-working, according to Wayne Westerberg. The fact that he had read the long and difficult War and Peace indicates that McCandless was intelligent and studious. (Indeed, we learn as well in this chapter that he was a success at selective Emory University.) Most indicative of all with respect to McCandlesss character are the things he renounced: $24,000 and his very name. In doing so, he seems to have been rejecting his family and what he saw as their materialistic values. This information doesnt fully explain why Christopher McCandless would forge alone into the Alaskan wilderness, but it begins to address the motivation for this bizarre act. The fact that McCandless never told his parents what he planned to do could indicate a lack of resolve on his part, or even cowardice. It also shows that the young man thoughtful enough to present Wayne Westerberg with an inscribed copy of one of his favorite books was callous enough regarding his parents feelings to leave them in the dark regarding their sons whereabouts. Considering that he eventually would die of starvation, McCandlesss gift of $24,000 to OXFAM, an organization dedicated to fighting hunger, is an example of irony. Chapter 4 This chapter unearths additional motivation for McCandlesss irrational Alaska trek to come. During his time in Mexico, he lived on nothing more than five pounds of rice and what marine life he could pull from the sea, and Krakauer points out that this may have accounted for the young mans belief that he could live off the land in the Alaskan wilderness. (Undeniably, McCandless proves himself remarkably capable in this chapter, canoeing through hundreds of miles of hostile landscape and even crossing an international border undetected.) And yet other questions remain unanswered. His mother says that Chris was very much of the school that you should own nothing except what you can carry on your back at a dead run. She doesnt say why this is so, however. The motif of friendship emerges further in these pages, as McCandless, who earlier struck up a friendship with Wayne Westerberg, befriends Jan Burres and her boyfriend Bob. One of Into the Wilds many ironies: a young man compelled toward a solitary life, who eventually will die alone, was quite gregarious and made friends easily. Another irony: McCandless abandons a car, the only problem with which is a wet battery, and burns his cash — but quits a job when it becomes clear that he wont be paid for his hard work. He has a complicated relationship with money and possessions, to say the least. Chapter 5 In this chapter, a theme introduced when McCandless presented a copy of War and Peace to Wayne Westerberg reappears: the young mans abiding love of literature. Since childhood, he was obsessed with the novels and stories of Jack London, who condemned capitalism and glorified nature. According to Krakauer, however, McCandless forgot he was reading fiction and conveniently overlooked the fact that London himself had spent just a single winter in the North and that hed died by his own hand on his California estate at the age of forty, a fatuous drunk, obese and pathetic. Krakauer characterizes his protagonist more deeply by means of contrast with those who surround him: Note that even at the Slabs, where snowbirds, rubber tramps, and other antiestablishment types congregated, McCandless was an anomaly: an individual who wanted life to be not easier (as most of the habituà ©s of the Slabs presumably do) but more difficult. Thus he prepares at the Slabs for a life in the harsh wilderness of Alaska. Notice as well the extent to which author Krakauer relies on documents left behind by McCandless to tell the young mans story. During this part of his journey, he ceases regularly keeping a journal, and Into the Wild becomes sketchier, more reliant on authorial inference. Chapter 6 The theme of this chapter is the astonishing ability of Christopher McCandless to win friends and influence people. Not only did he befriend the octogenarian Ronald Franz, but he convinced the old man to change his ways fundamentally at a time in life when most people have settled down for good. It is important to understand that McCandless fled society not because he couldnt get along with others, but because he chose to be alone. The fact that McCandless achieved this effect by means of a letter speaks to the power of the written word. Remember that he was inspired to head into the wild by books he read (Tolstoys, Jack Londons, and others) — and that it is a magazine article which informs the hitchhiker Franz picks up at chapters end that McCandless has died, thus inspiring the old man to give up on life. Chapter 7 Regarding McCandlesss character, it is interesting — and of course believable — that he can be intelligent, hardworking, and resilient, yet lack mechanical dexterity and perhaps even common sense. While the former characteristic, his awkwardness with machines, is consequential in ways that he manages to recover from (as in the abandonment of his car), the latter, his difficulty being just plain sensible, will have a greater impact. McCandlesss rage toward his parents, and particularly his father, is something that many of those who meet him pick up on. It seems to be their lifestyle more than anything else that McCandless is rejecting when he flees the conventional middle-class American way of life, though why it so repels him is never made completely clear by Into the Wild. It is not uncommon for men and women of Christopher McCandlesss age to flee their parents particular ways of doing things (psychology even has a term for this dynamic: reaction formation), but rarely is the response so extreme, so complete. The degree of McCandlesss renunciation of his familys values is a large part of what makes Krakauers book so fascinating. Finally, there is something admirable about McCandlesss utter devotion to what he believes in. It is easy to be inspired by books and the ideas they espouse, but not so easy to live the kind of life envisioned by thinkers like Tolstoy and London. McCandless talks the talk in a way that alienates fewer listeners than one would predict, but he walks the walk, too — which may account for the fact that so many of those he encountered continued to listen. Chapter 8 This chapter offers context for, and thus perspective on, McCandlesss situation. By quoting from some of the many outraged responses to his article, Krakauer shares with the reader the typical reaction to McCandlesss story: smug superiority laced with disbelief that anyone could be so foolhardy. And yet, as the examples of Rosselini, Waterman, and McCunn demonstrate, McCandless is hardly the only individual impelled to live off the land in the Alaskan wilderness. At the same time, these others provide Krakauer with an opportunity to highlight McCandlesss uniqueness; the author characterizes him by contrast with his predecessors. Similar to Rosselini and Waterman, Christopher McCandless was a seeker and had an impractical fascination with the harsh side of nature, the author writes. Like Waterman and McCunn, he lacked common sense. McCandless was unlike Waterman in that he was mentally stable. And in contrast to McCunn, McCandless didnt expect to be saved. Although he was rash, Krakauer summarizes, McCandless wasnt incompetent — he wouldnt have lasted 113 days if he were. And he wasnt a nutcase, he wasnt a sociopath, he wasnt an outcast. McCandless was something else. . . . A pilgrim perhaps. Chapter 9 This is a second consecutive chapter in which the author attempts to illuminate McCandlesss character by comparing and contrasting it to those of his predecessors. In doing so, Krakauer further convinces the reader that although McCandless was unique, the impulses that drove him were not unprecedented. Nor are these impulses an exclusively American phenomenon. In fact, although rare, the drive toward solitude crosses continents and millennia, as the example of the Irish monks demonstrates. Chapter 10 By flashing forward to McCandlesss death, Krakauer intensifies the drama of his story. He reminds us that McCandlesss adventure ends tragically. In addition, the author emphasizes the young mans connections to those whose lives he touched: friends Gallien and Westerberg, as well as MCandlesss relatives. The prior two chapters have emphasized McCandlesss commonalities with others who have sought adventure and solitude in the wild. This short chapter reminds us that, although it was not unique, McCandlesss story was noteworthy, newsworthy — it was covered not only in Alaska but in the national press. Chapter 11 This chapter asks more questions than it answers — and understandably, since the riddles it poses cannot be solved definitively. Are Christopher McCandlesss parents responsible for their sons death? Was his personality shaped by, or even inherited from, them? Could his parents have interceded and altered his behavior, thereby changing his fate? For that matter, what exactly was McCandless rebelling against, aside from middle class ennui? Also, wouldnt it have been more productive for him to have resumed his work on behalf of the homeless, hungry, or disenfranchised after college, instead of indulging his whimsical notions of (his own) survival? Chapter 12 Two factors emerge in this chapter that clearly contributed to McCandlesss flight into the wilderness — and his eventual death. First, Walt McCandless comments that Chris was good at almost everything he ever tried . . . which made him supremely overconfident. This bit of characterization goes a long way toward explaining McCandlesss bewildering lack of preparation for his Alaskan adventure. There is no evidence that he failed at much, if anything, during his childhood and adolescence, which may have exacerbated the hubris naturally felt by many young adults. As to why McCandlesss overconfidence found its outlet in a radical rejection of his parents bourgeois values — and his family altogether — the information that emerges in this chapter about his fathers double life could well have offered the motivation. Krakauer doesnt linger on this episode, but if nothing else, it seems to have provided the match that lit McCandlesss short fuse. Chapter 13 During the plane ride home with Chriss remains, his sister Carine eats every scrap of food the cabin attendants set in front of her. Soon afterward, however, she discovers she has no appetite and loses so much weight that friends think she has become anorectic. Chriss mother also stops eating, losing eight pounds. His father, Walt, responds the opposite way, putting on eight pounds. Though both compulsive eating and loss of appetite are not uncommon responses to stress and grief, it is hard not to see the McCandless familys food-related behaviors as connected to Chriss demise. It is as if Billie and Carine are identifying with him, feeling Chriss pain, while Walt is compensating for what killed his son — though none of them are doing what they do intentionally, or even consciously. Chapter 14 Up to this point in Into the Wild, author Jon Krakauer has maintained journalistic objectivity, or at least the appearance of objectivity. In this chapter he abandons that perspective. Note, however, that Krakauers integrity as a journalist is not compromised, since he is entirely up-front about the experiences he shares in common with his subject, McCandless. In fact, it would be more ethically suspect if Krakauer did not divulge that he had his own into the wild experience as a young man. Because of his candor, readers are able to take this into account when the author views McCandlesss activities with some sympathy. And as a result of reading this chapter and the one that follows, the reader moves closer to McCandless and his perspective. Not only Rosselini, Waterman, McCunn, and Reuss (as well as the Irish monks described) have shared McCandlesss impulses, but the author himself. Behavior that seemed utterly bizarre, at the start of Into the Wild, is becoming easier to conceive of with every successive chapter. Chapter 15 his chapter further develops the motif of fathers and sons, suggesting explicitly that sons often rebel against their fathers at the same time that they are powerless to resist paternal traits they have inherited. Clearly Krakauer believes that McCandless was driven to do what he did in large measure by his relationship with father Walt. And this is only part of what Krakauer believes he shared with McCandless. They also shared hubris. It is easy, when you are young, he writes, to believe that what you desire is no less than what you deserve, to assume that if you want something badly enough, it is your God-given right to have it. When I decided to go to Alaska that April, like Chris McCandless, I was a raw youth who mistook passion for insight and acted according to an obscure, gap-ridden logic. Which is not to say that Jon Krakauer believes his younger self to have been identical to Christopher McCandless in every respect. Krakauer says he wasnt as intelligent as McCandless and didnt possess his lofty ideals — but young Krakauer was also, crucially, a superior outdoorsman. Chapter 16 This chapter, the heart of Into the Wild, reconstructs McCandlesss climactic Alaska adventure, following him into the bush and observing his admirable survival skills. Although Krakauers book is an adventure story, Into the Wild is also a study in character, and Chapter Sixteen is no exception. McCandless is revealed in the moose episode to be highly ethical and deeply sympathetic; the reader cannot help being moved by the enormity of the young mans despair over wasting his kill. By the same token, McCandlesss lack of foresight and his hubris, apparent in a low-level way prior to this time, now yield consequences that will be fatal. He did not anticipate that melting snow would swell the bodies of water he crossed on his way into the bush. And his arrogant refusal to bring a map prevents McCandless from learning that, despite its increased size, the river is fordable upstream — another in a series of ironies that punctuate this book Chapter 17 The ironies multiply in this, the books penultimate chapter. The basket that Krakauer and his companions discover at the U.S.G.S. station has been secured by hunters to the side of the river on which McCandless camped so as to make crossing the Teklanika harder for outsiders. If hed known about it, the author writes, crossing the Teklanika to safety would have been a trivial matter. Because he had no topographic map, however, he had no way of conceiving that salvation was so close at hand. In another irony, McCandless was close to not only the abandoned gauging station but three empty hunting cabins, as well. Did he really go into the wild after all? Undoubtedly he was living in a hostile environment during the months he spent in Alaska, but some wouldnt call the area he inhabited the wilderness at all. Chapter 18 Did McCandless finally come to forgive his family, as evinced by the HAPPINESS ONLY REAL WHEN SHARED inscription he wrote toward the end of his life? Perhaps — but note that in all of his writings, there is nothing that explicitly reaches out to his parents or his sister, Carine. McCandless never acknowledges them, even to say goodbye. Note, too, that Krakauers theory on McCandlesss death, that it was caused by mold on wild potato seeds, is just that: a theory. It is not definitive. To some degree it is beside the point anyway, since one could argue that it wasnt so much starvation that killed McCandless as arrogance and shortsightedness.

Fetal Brain Tissue Transplantation in Parkinsons Disease Patients Essa

Fetal Brain Tissue Transplantation in Parkinson's Disease Patients Parkinson's disease is a neurological disorder characterized initially by muscular rigidity and slowing of voluntary movements (1). Ultimately, the characteristics are tremor, mask-like faces, decreased spontaneous blinking, flexion posture and sometimes cognitive impairment. The neuropathology of Parkinson's disease generally involves loss of cell bodies in all melanin-containing brain regions and invariably a loss of substantia nigra dopamine-containing neurons (DA). The principal target for dopaminergic neurons located in the substantia nigra is the striatum and the loss of dopaminergic tone in the striatum is thought to produce most of the symptoms of Parkinson's disease. Since Parkinson's disease is a dopamine deficiency, treatment with L-Dopa, the precursor of dopamine, was successful in treating Parkinson's patients (1). However, these patients taking L-Dopa often develop side effects and in about 50% of the patients, the drug effectiveness is lost. As an alternative to drug therapy, the possibility of grafting dopamine-containing tissue into the brains was proposed. From the proposal, there have been a vast amount of experiments to test transplantation effectiveness. Work in amphibians and fish were the first to demonstrate the possibilities for neuronal replacement after damage in the central nervous system (2). In these species, especially in the visual system, grafted neurons were substituted both structurally and functionally for damaged axonal connections, and afferent and efferent connections were established with a high degree of specificity between the grafted neurons and the host. Evidence in adult sub-mammalian vertebrates has shown c... ...a, S., Brundin, P. and Gustavii, B., 1989, Human fetal dopamine neurons grafted into the striatum in two patients with severe Parkinson's disease. A detailed account of methodology and a 6-month follow-up. Archives of Neurology 46: 615-631. 6. Freed, C.R., Breeze, R.E., Rosenberg, N.L. and Schneck, S.A., 1990, Transplantation of human fetal dopamine cells for Parkinson's disease. Results at 1 year. 47: 505-512. 7. Jankovic, J., Grossman, R., Goodman, C. and Pirozzolo, F., 1989, Clinical, biochemical and neuropathologic findings following transplantation of adrenal medulla to the caudate nucleus for treatment of Parkinson's disease. Neurology 39: 1227-1234. 8. Allen G.S., Burns, R.S., Tulipan, N.B. and Parker, R.A., 1989, Adrenal medullary transplantation to the caudate nucleus in Parkinson's disease. Initial clinical results in 18 patients. 46: 487-491.

PETA Campaigns Look to Turn Carnivores Green Essay -- Animal Rights

Vegetarianism, PETA touts it as a cure-all for obesity in their ad campaigns calling for folks to ditch meat and eat plant-based meals. This series has been going on for well over a decade but really seems be picking up speed these past few years when they began pairing US celebrities with vegetables be it in fancy dress made of different vegetables or bare naked amongst bushels of their favorite edible plant. Along with the fit bodied celebrity and their vegetables, there is a message included, an offer of free vegetarian recipes if you visit their website. The message is clear PETA wants us to stop eating animal meat and they are willing to use fit body celebs and free recipes to do it. I think these ads are effective strategies for swaying consumer who is always looking for the next big thing to be a part of that involves a celebrity spokes model. The latest print ad to come from PETA is the provocative Angela Simmons print ad, in which she can only be described as being Eve of Eden in all her nude glory. The ad stating that eating Meat is a Sin, this may be more tuned toward religious carnivores but the visual is definitely aimed toward those who enjoy a teasing naked woman, because the ad is nothing less than sexy. Her dark hair spilling forth loose and wavy over her shoulders hiding bare breasts, her right hit turned out a chain of ivy laid along it; most prominent is her smooth, young face almost a reflection of the beautiful red apple she holds just beneath her chin in her right palm, while the heel of her left hand rests gently against her cheek. Her arm is raised and slightly twists, winding its way up through her hair, reminding me of a serpent, I believe this to be an intentional subliminal bit withi... ...ebsites to bash companies who mistreat their livestock. These methods are directed toward the consumers who, without this type of advertising would ever realize there was a problem or even what PETA was. So in the end PETA’s envelope is pushed by the consumer because the consumer thinks and is influenced by advertising; and the more attention getting the advertising is, the more likely the consumer is to pay attention and be swayed to your side of the table if it is an ad campaign they (the consumer) can relate to and quite frankly nearly every consumer can relate to sexy. Works Cited n.d. PETA.org. Vegetarian 101. n.d. . —. Veggie Love. N/A November 2011. . n.d. PETA.org. Veggie Love. N/A November 2011. .

Hills like White Elephants Essay

â€Å"Hills like White Elephants† is a very short story by Ernest Hemingway telling of the conversation between a man and a woman regarding the pregnancy of the woman. The point of view or the voice employed in the short story is a third person point of view where there is a narrator separate from the main characters in the story. This point of view or voice is very effective in the story because such requires that the narrator is a distant observer so as not to intercede in the intimacy of the conversation between the two characters. This is effectively achieved because both characters, albeit having a choppy and seemingly disjointed conversation, reconcile in their views at certain points which totally disregards the need for the intrusion of a material narrator who is necessarily part of the story or one of the characters. The story is set in a bar in a train station where the couple waits before bounding the train. Such a setting allows exploration of the other, more important elements of the story, which serve as potent symbols for the central theme of abortion, so for instance, in the lines, â€Å"â€Å"The hills across the valley of the Ebro were long and white.† (Hemingway); and the lines where the girl continues to describe the barren landscape, â€Å"They look like white elephants†. (Hemingway), the setting where both couples are offer an unobstructed view of these hills, which, in the story, are used to imply the perception of the female protagonist who is struggling with a pregnancy that is unwanted by her partner, the male protagonist. So, in effect, these lines, while illustrating the view from the train station offers the female’s perspective of the pregnancy as something that is not supported by her partner, hence the almost indifferent description of the scenery. The bar setting also works well in infusing the tale with symbolic meanings, for instance, when the girl says, â€Å"â€Å"Everything tastes like licorice. Especially the things you’ve waited so long for, like absinthe. † (Hemingway) she is actually referring to the pregnancy, which, perhaps, she had wanted for so long, but was not supported by her partner. So, in effect, this line would not have been as effective had it been said in the bedroom or an office, so the setting works quite effectively in making the symbols more adequate for the central theme. The characters in the story, Jig, the female, and her male partner are in a situation where they are arguing whether to have the baby that Jig was currently pregnant with. The ways the characters are characterized in the story contribute a lot to how the story turns out to be. The female, protagonist, who is initially adamant about having the baby later shows some evidence of softening up because perhaps of her love for her partner and the desire to make things right again, hence, the lines, â€Å"â€Å"But if I do it, then it will be nice again if I say things are like white elephants, and you’ll like it?† (Hemingway) where the girl seems to be testing the reaction of the male character to whatever decision she makes. The male character, on the other hand is quite insistent that his mate get an abortion, and as is quite clear in the conversations, does not seem to care about what his partner feels. This indifference of the male character is very clear in the rapidly successive dialogue in the lines, â€Å"†I said we could have everything. /We can have everything. /No, we can’t.  /We can have the whole world. /No, we can’t. /We can go everywhere. /No, we can’t. It isn’t ours any more. /It’s ours. /No, it isn’t. And once they take it away, you never get it back. † (Hemingway) Here, it is quite clear that the male character seems to be avoiding the matter presented by the male character and his responses are all in the negative because he seems to be focused on one objective and one goal alone which is to have the baby being carried by the female character aborted. In this particular story the dynamics between the setting, the characters, and the point of view all work together in support of the central theme. Such a story succeeds in conveying the desired emotions to the reader while at the same time paying much attention to conventions and literary standards, hence, making the story very successful in its execution.

Free Essays on Music Support

Billions and billions of dollars later â€Å"Houston, we have lift off.† America has come along way in its developments thanks to the funds donated by the government, but how much are they doing to preserve our educational history? Everyday American’s find their society getting dumber and dumber. The government has slowly begun backing away from any involvement in the continuing downfall of American intelligence, not realizing that their lack of financial support is at fault. The government needs to start providing more schools, museums, and performing art centers with the education, funds, and support that they deserve. Music is the perfect art. It has movement, because it progresses over a set period of time. All musical works have a beginning and an end. However, music does not restrict the audience in the way that movies or graphic art does. The listener can create whatever image she or he wants to when listening to music. It is an art that appeals to the conscious mind, but the best music also appeals to the subconscious. No thought is required to enjoy good music, though it is often thought inspiring. The melodic sounds of certain types of music were proven to have a profound effect on the human brain. In 1998, a research team from the University of Wisconsin, headed by psychologist Dr. Frances Rauscher, had their incredible findings published in the Neurological Research magazine. Although their studies were performed on rats, according to that magazine issue â€Å"Their studies indicate that music training generates the neural connections used for abstract reasoning, including those necessary for understanding mathematical concepts†¦the work has strong implications for education and enrichment programs.† If the government provided funds to run such an experiment it would only make sense that they would finish it out and provide people with places to get such musical exposure. Would it not also make sense to aid the people re... Free Essays on Music Support Free Essays on Music Support Billions and billions of dollars later â€Å"Houston, we have lift off.† America has come along way in its developments thanks to the funds donated by the government, but how much are they doing to preserve our educational history? Everyday American’s find their society getting dumber and dumber. The government has slowly begun backing away from any involvement in the continuing downfall of American intelligence, not realizing that their lack of financial support is at fault. The government needs to start providing more schools, museums, and performing art centers with the education, funds, and support that they deserve. Music is the perfect art. It has movement, because it progresses over a set period of time. All musical works have a beginning and an end. However, music does not restrict the audience in the way that movies or graphic art does. The listener can create whatever image she or he wants to when listening to music. It is an art that appeals to the conscious mind, but the best music also appeals to the subconscious. No thought is required to enjoy good music, though it is often thought inspiring. The melodic sounds of certain types of music were proven to have a profound effect on the human brain. In 1998, a research team from the University of Wisconsin, headed by psychologist Dr. Frances Rauscher, had their incredible findings published in the Neurological Research magazine. Although their studies were performed on rats, according to that magazine issue â€Å"Their studies indicate that music training generates the neural connections used for abstract reasoning, including those necessary for understanding mathematical concepts†¦the work has strong implications for education and enrichment programs.† If the government provided funds to run such an experiment it would only make sense that they would finish it out and provide people with places to get such musical exposure. Would it not also make sense to aid the people re...

Funny Quotes About Life

Funny Quotes About Life People have been pondering, debating, and writing about life for millennia. Sometimes, no matter the circumstances, humor can help with healing or understanding- and sometimes you just have to laugh. Its all about perspective. Alan Bennett Life is rather like a tin of sardines- were all of us looking for the key. Carl Sandburg Life is like an onion: You peel it off one layer at a time, and sometimes you weep. Charles Schulz My life has no purpose, no direction, no aim, no meaning, and yet Im happy. I cant figure it out. What am I doing right? Charlotte Bronte Life is so constructed that an event does not, cannot, will not, match the expectation. Elbert Hubbard Do not take life too seriously. You will never get out of it alive. Douglas Adams Life...is like a grapefruit. Its orange and squishy and has a few pips in it, and some folks have half a one for breakfast. Friedrich Nietzsche He who has a why to live can bear almost any how. Alice Roosevelt Longworth I have a simple philosophy: Fill whats empty. Empty whats full. Scratch where it itches. George Bernard Shaw Life does not cease to be funny when people die any more than it ceases to be serious when people laugh. Anatole French The average man does not know what to do with his life yet wants another one which will last forever. J.P. Getty â€Å"My formula for success is rise early, work late and strike oil.† T.S. Eliot â€Å"The journey, not the arrival, matters.† Ralph Waldo Emerson â€Å"Do not follow where the path may lead, go instead where there is no path and leave a trail.† Winston Churchill If you are going through hell, keep going. Douglas Adams â€Å"There is a theory which states that if ever anyone discovers exactly what the Universe is for and why it is here, it will instantly disappear and be replaced by something even more bizarre and inexplicable. There is another theory which states that this has already happened.† Mark Twain Age is an issue of mind over matter. If you dont mind, it doesnt matter. Ray Kroc Luck is a dividend of sweat. The more you sweat, the luckier you get. Mahatma Gandhi   There is more to life than increasing its speed.   Maya Angelou   Ive learned that you can tell a lot about a person by the way (s)he handles these three things: a rainy day, lost luggage, and tangled Christmas tree lights.   Abraham Lincoln   Everyone desires to live long, but no one would be old. Mother Teresa   I know God will not give me anything I cant handle. I just wish He didnt trust me so much. Robert Louis Stevenson Dont judge each day by the harvest you reap, but by the seed that you plant. W. Somerset Maugham Its a funny thing about life; if you refuse to accept anything but the best, you very often get it.  Ã‚   Mark Twain â€Å"All you need in this life is  ignorance and confidence, and then  success is sure.† Voltaire â€Å"Life is a shipwreck but we must not forget tossing in the lifeboats.† Sydney Harris â€Å"When I hear somebody sigh,  Life is hard, I am always tempted to ask, ‘Compared to what?† Terry Pratchett â€Å"Wisdom comes from experience. Experience is often a result of lack of wisdom.† Jim Harrison â€Å"The simple act of opening a bottle of wine has brought more happiness to the human race than all the collective governments in the history of earth.† W.H. Auden â€Å"We are all here on earth to help others; what on earth the others are here for I don’t know.† Abraham Lincoln â€Å"The best thing about the future is that it comes one day at a time.† Bernard Baruch â€Å"Be who you are and say what you feel, because those who mind don’t matter and those who matter don’t mind.† Dalai Lama â€Å"If you think you are too small to make a difference, try sleeping with a mosquito.† Dorothy Parker â€Å"The cure for boredom is curiosity. There is no cure for curiosity.† Douglas Adams â€Å"Human beings, who are almost unique in having the ability to learn from the experience of others, are also remarkable for their apparent disinclination to do so.† George W. Bush â€Å"To those of you who received honors, awards, and distinctions, I say, Well done. And to the C students, I say you, too, can be president of the United States.†

The Facts and History of Cinco de Mayo

The Facts and History of Cinco de Mayo Cinco de Mayo is probably one of the most celebrated and least understood holidays in the world.  What is the meaning behind it? How is it celebrated and what does it mean to Mexicans? There are many misconceptions about Cinco de Mayo and it is more than an excuse to have some nachos and a margarita or two. Its also not a celebration of Mexicos independence as many people think. It is an important day in Mexican history and the holiday has true meaning and importance. Lets get the facts straight about Cinco de Mayo. Cinco de Mayo Meaning and History Literally meaning The Fifth of May, Cinco de Mayo is a Mexican Holiday celebrating the Battle of Puebla, which took place on May 5, 1862. It was one of the few Mexican victories during Frances attempt to penetrate Mexico. Contrary to popular belief, this was not the first time that France attacked Mexico.  Back in 1838 and 1839, Mexico and France had fought what was known as  the Pastry War.  During that conflict, France invaded and occupied the city of Veracruz.   In 1861, France sent a massive army to invade Mexico once again. As was the case 20 years earlier, the intent was to collect on debts incurred during and after Mexicos war of independence from Spain. The French army was much larger and better trained and equipped than the Mexicans struggling to defend the road to Mexico City. It rolled through Mexico until it reached Puebla, where the Mexicans made a valiant stand. Against all logic, they won a huge victory. The triumph was short-lived, however. The French army regrouped and continued on, eventually taking Mexico City.   In 1864, the French brought in  Maximilian of Austria. The man who would become Emperor of Mexico was a young European nobleman who barely spoke Spanish. Maximilians heart was in the right place, but most Mexicans did not want him. In 1867, he was overthrown and executed by forces loyal to President Benito Juarez. Despite this turn of events, the euphoria of the unlikely victory at the Battle of Puebla against overwhelming odds is remembered every May 5th. Cinco de Mayo Led to a Dictator During the Battle of Puebla, a young officer named  Porfirio Diaz  distinguished himself. Diaz subsequently rose rapidly through the military ranks as an officer and then as a politician. He even aiding Juarez in the fight against Maximillian. In 1876, Diaz reached the presidency and did not leave until the  Mexican Revolution  kicked him out in 1911 after a  rule of 35 years.  Diaz remains one of the most important presidents in the history of Mexico, and he got his start on the original  Cinco de Mayo. Isn’t It Mexico’s Independence Day? Another common misconception is that Cinco de Mayo is Mexicos Independence Day. In actuality, Mexico celebrates its independence from Spain on September 16. It  is a very important holiday in the country and not to be confused with Cinco de Mayo. It was on September 16, 1810, that  Father Miguel Hidalgo took to his pulpit in the village church of the town of Dolores. He  invited his flock to take up arms and join him in overthrowing Spanish tyranny. This famous speech would be celebrated as the  Grito de Dolores, or The Cry of Dolores, from then on. How Big ofa Deal Is Cinco de Mayo? Cinco de Mayo is a big deal in Puebla, where the famous battle took place. However, it really isnt as important as most people think. Independence Day on September 16 has much more significance in Mexico. For some reason, Cinco de Mayo is celebrated more in the United States- by Mexicans and Americans alike- than it is in Mexico. There is one theory for why this is true. At one time, Cinco de Mayo was widely celebrated in all of Mexico and by Mexicans living in former Mexican territories such as Texas and California. After a while, it was ignored in Mexico but the celebrations continued north of the border where people never got out of the habit of remembering the famous battle. Its interesting to note that the largest Cinco de Mayo party takes place in Los Angeles, California.  Every year, the people of Los Angeles celebrate â€Å"Festival de Fiesta Broadway† on May 5th (or on the closest Sunday). It’s a large, raucous party with parades, food, dancing, music, and more. Hundreds of thousands attend annually.  It’s even bigger than the festivities in Puebla. Cinco de Mayo Celebration In Puebla and in many U.S. cities with large Mexican populations, there are parades, dancing, and festivals. Traditional Mexican food is served or sold. Mariachi bands fill town squares and a lot of Dos Equis and Corona beers are served. It’s a fun holiday, really more about celebrating the Mexican way of life than about remembering a battle which happened over 150 years ago. It is sometimes referred to as a â€Å"Mexican St. Patrick’s Day.† In the U.S., schoolchildren do units on the holiday, decorate their classrooms, and try their hand at cooking some basic Mexican foods. All over the world, Mexican restaurants bring in Mariachi bands and offer specials for what’s almost certain to be a packed house.​ It’s easy to host a Cinco de Mayo party. Making basic Mexican food like salsa and burritos is not too complicated. Add some decorations and mix up a few margaritas and you’re good to go.

Can ethical behavior really exist in business Research Paper

Can ethical behavior really exist in business - Research Paper Example This paper is an attempt to analyse the concept of ethical behaviour and focus on the possibilities for ethical behaviour to exist in a business. The meaning of business ethics An attempt to answer the following question could help us to understand the meaning of business ethics: What is the relationship between ethics and morality? According to Archie B. Carroll and Ann K. Buchholtz â€Å"ethics is the discipline that deals with what is good and bad and with moral duty and obligation. Ethics can also be regarded as a set of moral principles or values. Morality is a doctrine or system of moral conduct† (Carroll & Buchholtz 242). It is obvious from the definitions that ethics and morality are more or less similar concepts and both these terminologies can be used as substitutes for each other to analyse the right and wrong behaviour in business. Business ethics could thus be observed as linked with the right and wrong behaviour and practices which take place in a business setup. The existence of a business is dependant on the nature of relationship between customers, employees, investors, shareholders, managers and directors. It is the responsibility of director board of a company to ensure the functioning of the organisation in a legal and ethical manner. ... Recent interpretations of right and wrong comprise questions of equity and fairness. There are two important branches of ethics; descriptive ethics and normative ethics. These branches observe the concept of ethics from different angles. As Archie B. Carroll and Ann K. Buchholtz puts in â€Å"descriptive ethics is concerned with describing, characterizing and studying the morality the people, an organisation, a culture or a society. It also compares and contrasts different moral codes, systems, practices, beliefs and values† (Carroll & Buchholtz 242). The focus of descriptive business ethics is primarily on what is taking place in specific areas such as behaviour, action, decisions and practices of organisations. It considers the present happenings in a business establishment and therefore there are possibilities for the development of an attitude among some people to follow the activities of a majority even if the action is unfair. At this point one could recognise the import ance of normative business ethics as it focus on ‘what aught to be’ instead of ‘what is’ the ethical conditions of an organisation. According to Archie B. Carroll and Ann K. Buchholtz â€Å"normative ethics, by contrast, is concerned with supplying and justifying a coherent moral system of thinking and judging. It seeks to uncover, develop and justify basic moral principles that are indented to guide behaviour, actions and decisions† (Carroll & Buchholtz 242). Therefore normative ethics provides a clear cut idea regarding what is ethical and what is unethical in a business. It is more concerned with the do’s and don’ts and with setting up of standards for providing guidelines for a business establishment to ensure its ethical functioning which is

BUSINESS PROBLEM-SOLVING CASE Does Big Data Bring Big Rewards Essay

BUSINESS PROBLEM-SOLVING CASE Does Big Data Bring Big Rewards - Essay Example The factors include-identifying and managing the complexity of the business operations, placing emphasis on the adoption of the information system on a company-wide platform, analyzing potential tangible benefits that are to arise from adopting the system, prioritizing the benefits of the system in accordance with the company’s goals and business needs, ensuring that the system is supported by the top level management and that they take an active role in its implementation and use. Additional factors include- communicating effectively with all the employees and giving them responsibilities in order to mitigate risks. A lot of interesting points have been raised regarding the benefits of a big data system. It is quite clear that the financial goals of such a system are boundless if big corporations like Hertz and Vestas are anything to go by. I additionally agree that when these systems are adopted appropriately, they improve customer relations between companies and their customer bases (Ohlhorst 2013). The example of Sears is a primary case showing how by adopting Hadoop, it has been able to make strides in customizing their retail products to match the specific needs of an individual customer, which is very impressive. However, I am of the opinion that the use of big data systems is not just limited to these benefits. I believe that companies are adopting these systems as a management strategy aimed at promoting their brand on a global level, while also acquiring a competitive advantage over the other players in the industry (Mullins 2013). Many companies have identified the benefits accrued by big data systems on a wider scale. Companies like Walmart provide a good example of companies that have benefitted immensely by extensively incorporating global information management systems in their long term plans. I think that is why Walmart is

Summary and Conclusion to executive audience Essay

Summary and Conclusion to executive audience - Essay Example The company expects to meet all the database application and reporting requirements by development of policies, guidelines, standards, and practices in connection to the project. If all the stages of implementation are followed to the latter, then Riordan Manufacturing will successfully implement the database project for use in the finance and accounting department of the company. The diagrams used in the implementation of the project should be easily understandable and it is recommended that the users should add proper notes that would assist and aid in terms of understanding all the diagrams completely. Design is the important stage of the implementation of the project and should be done with a close coordination with all other aspects of the physical information system design. Design should be followed by documentation to guide the users. Database application will then be met if all the stages of implementation are followed to the

Juvenile Justice Research Paper Example | Topics and Well Written Essays - 750 words

Juvenile Justice - Research Paper Example This would involve merging punishment and welfare in contributing to the rehabilitative reformatory. Since Mrs. I does not want her son to go to jail for his crime, the question would be; †should we punish,† or â€Å"should we treat the situation â€Å" (Reader, 1996). Therefore the best approach to the case considering Mrs. I’s concerns would be to talk to the teen and understand why he had to commit the crime, introduce treating mechanisms, which would make the youth to pay for the crime such. Such treatment would include recommending he should never touch a vehicle until he improves his behaviors, and threatening to take him to jail any time such a case is reported in the future. Such an approach as Markman (2007) notes would be in accordance to parens patriae doctrine in protecting, rehabilitating and healing process. There are three steps that have to be used to protect Mrs I’s teenager. The first step would be accountability. This would involve takin g responsibility for one’s behavior, take the necessary action to repair any harm caused and be ready to change (NCJRS, 2000). In this case, the teenager has to understand how his behavior affected others, accept, and acknowledge that the behavior involved a choice that could be made differently, and make changes to avoid such behavior in the future. The teenager has also to have support from his parents to ensure he realizes his mistakes and is ready to change for the better. This focuses on repairing the harm done by such a teenager, and not so much on punishment (Little 2010). The second stage would be competency development. Competency would be explained as the capacity to do something well to be valued by others (Pranis, 1998). The juvenile offender has to have a chance to perform meaningful and important tasks in the community and contribute to the wellbeing of others. Such would involve learning to make meaningful choices, belong to a community, and contribute positive ly in developing decision making, reasoning and problem solving skills (NCJRS, 2000). The third step would involve community protection. In a balanced and restorative justice framework, youths with strong connections to their communities and care about people in their community are less likely to offend. This would involve initiatives that would foster positive relationship with the family and the community at large (Pranis, 1998). To help the teen, it would be important to facilitate a cordial relationship between the youth, the family, and community, which would indicate the extent of reforming the teen has undergone. To ensure this is achieved, it would be important supervise the youth for sometime, where he has to report regularly on his day to day activities, use house arrests for some time to ensure he realizes his mistakes by denying the freedom he treasures, and ensure he is involved in some communal undertakings to understand how best to live in a community, which would in turn help in his reforming process by understanding his responsibilities, and having a sense of belonging (NCJRS, 2000). As a judge, there would be several factors to consider. For example, prototypical of the current psychological discourse related to youth and the hormonal imbalance issue, criminologists view youths as subjects to a number

Functional Systems Case Study Example | Topics and Well Written Essays - 500 words

Functional Systems - Case Study Example Basically, the Lynx Company is using the sales information system. In this scenario, this system collects sales data to help the company monitor sale transactions and to help the management understand the status of their organizations, whether their business is running in profit or in loss (Shah, 2009; Beaubien, 2013). The system has been a great success for the company and some of the reasons behind this success are outlined below: 1. The system is designed for a particular purpose (e.g. Sales system). So it specifically deals with sales functions and minimizes confusions with other departments. It is easy for the sales department to understand the functions and carry put tasks effectively using this system. 2. As discussed above, this system is an isolated system. In this scenario, it is not connected to any other system such as human resource system or decision support system. So it is much easier for staff members to operate it independently without requiring the data from other departments. 1. In view of the fact that this functional system is based on a particular function (e.g. sales system) so the flow of work and information between other departments can suffer. For instance, it can be difficult to connect this system with other systems such as decision support system or human resource systems. Or in some cases there can emerge various data integration issues (Beaubien, 2013). 2. Since this functional system operates over the Internet so information security can be a serious challenge. The system can face security attacks from hackers. In addition, the system can also face virus attacks which can destroy the entire data (Henderson, 2013). 4. In order to perform accurate working there would be need to train the staff members. Since this system deals with money matters so a small error can cause serious loss for the company. In this scenario, they must train their staff members so it is an extra burden on the company (Henderson,

Juvenile Justice Research Paper Example | Topics and Well Written Essays - 750 words

Juvenile Justice - Research Paper Example This would involve merging punishment and welfare in contributing to the rehabilitative reformatory. Since Mrs. I does not want her son to go to jail for his crime, the question would be; †should we punish,† or â€Å"should we treat the situation â€Å" (Reader, 1996). Therefore the best approach to the case considering Mrs. I’s concerns would be to talk to the teen and understand why he had to commit the crime, introduce treating mechanisms, which would make the youth to pay for the crime such. Such treatment would include recommending he should never touch a vehicle until he improves his behaviors, and threatening to take him to jail any time such a case is reported in the future. Such an approach as Markman (2007) notes would be in accordance to parens patriae doctrine in protecting, rehabilitating and healing process. There are three steps that have to be used to protect Mrs I’s teenager. The first step would be accountability. This would involve takin g responsibility for one’s behavior, take the necessary action to repair any harm caused and be ready to change (NCJRS, 2000). In this case, the teenager has to understand how his behavior affected others, accept, and acknowledge that the behavior involved a choice that could be made differently, and make changes to avoid such behavior in the future. The teenager has also to have support from his parents to ensure he realizes his mistakes and is ready to change for the better. This focuses on repairing the harm done by such a teenager, and not so much on punishment (Little 2010). The second stage would be competency development. Competency would be explained as the capacity to do something well to be valued by others (Pranis, 1998). The juvenile offender has to have a chance to perform meaningful and important tasks in the community and contribute to the wellbeing of others. Such would involve learning to make meaningful choices, belong to a community, and contribute positive ly in developing decision making, reasoning and problem solving skills (NCJRS, 2000). The third step would involve community protection. In a balanced and restorative justice framework, youths with strong connections to their communities and care about people in their community are less likely to offend. This would involve initiatives that would foster positive relationship with the family and the community at large (Pranis, 1998). To help the teen, it would be important to facilitate a cordial relationship between the youth, the family, and community, which would indicate the extent of reforming the teen has undergone. To ensure this is achieved, it would be important supervise the youth for sometime, where he has to report regularly on his day to day activities, use house arrests for some time to ensure he realizes his mistakes by denying the freedom he treasures, and ensure he is involved in some communal undertakings to understand how best to live in a community, which would in turn help in his reforming process by understanding his responsibilities, and having a sense of belonging (NCJRS, 2000). As a judge, there would be several factors to consider. For example, prototypical of the current psychological discourse related to youth and the hormonal imbalance issue, criminologists view youths as subjects to a number

We dont choose a life, we live one. Discuss this statement in the Essay

We dont choose a life, we live one. Discuss this statement in the context of tourism and yourself as a tourist - Essay Example As such, it is important to reveal the reasons which contribute to one choosing certain destinations while discriminating others, which in the context of tourism are understood as the place and space factors. To elaborate on this, the following text will evaluate two popular tourist destinations, Kuala Lumpur and Singapore and using the place-space factors distinguish between which of the two would be more suitable as a tourist destination. One of the crucial determining factors for a whether a destination will attract large numbers of tourists is the environment and natural resources available. These include the landscape and climate of a place. As is the obvious, tourism is all about changing the norms of daily life and escaping from the hustles of everyday. As such, people will prefer to travel to distant away places which have a climate or appearance totally different from theirs. This is to say that if one is accustomed to living in the western chilly countries and they wanted to relax, the most suitable place for them to find their calm or change of atmosphere would be finding warm or sunny destinations. On the other hand, people accustomed to the hot climates would opt for chilly mountainous destinations such as those which have snow-capped mountains or experience snowy weather. The other determining factor which many may consider is the condition of the built environment. The built environment here refers to everything created by the hands of people. Apart from just visiting interesting destinations, tourists require amongst other things the ease of travelling, the comfort of living, security, shopping bases, and entertainment areas to mention but a few. In fact, these facilities can themselves become tourist attractions when they offer mega supplies of rare items and services. The best example is the festivals of visual and performing arts hosted by mostly the Asian

Difference between active and passive forms Essay Example for Free

Difference between active and passive forms Essay Difference between active and passive forms Introduction Active forms            Inactive forms of the sentence, the doer or the thing that is doing the action is the subject of the sentence while the one that is receiving the action is the subject of the sentence. Most of the sentences in the real world are in the active forms. It is always in the form; (Action Doer or the subject)+(Verb)+( The action receiver or the object) Example John wrote the essay Here; John is the subject, wrote is the verb and essay is the object. Passive Form            In the passive form, the things that are doing the action are the subject of the sentences while the thing that is doing the action is the object and it is placed at the end of the sentence after the word â€Å"by†. The passive form is always used when one thinks that the object or the receiver of the action is to be emphasized or is deemed to be more important. This form is also used to exercise courtesy where one doesn’t want to mention the action’s doer or the doer of the action is not known. It is always in the form; (Action receiver)+(past participle of the verb in question)+(by)+(action doer) Example The essay was written by john Essay is the action receiver, written is the past participle of wrote, by precedes the doer, John References Courtland L. Bovee John V. Thill, July 21, 2013. Business Communication Today (12th Edition. Source document

Parliamentary Sovereignty in the UK in the Wake of Brexit

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