Promissory estoppel is a controversial exception Essay Example

Promissory estoppel is a controversial exception Essay Example Promissory estoppel is a controversial exception Essay Promissory estoppel is a controversial exception Essay Essay Topic: Controversial There are three exclusions to the regulation inPinnel’s instance. They are composite understanding, payment of debt by 3rd party and promissory estoppel. The regulation inPinnel’s instance ( 1602 ) 5 CoRep117ais that portion payment of debt is non good consideration to waive the balance. Thus the creditor may action for the staying debt unless there is fresh consideration. Promissory estoppel like proprietary estoppel is popular types of just estoppel. The importance of just estoppel was stated inCrabb V. Arun DC ( 1976 ) 1 Ch 179that â€Å"equity comes in †¦Ã¢â‚¬ ¦.. to extenuate the cogency of rigorous jurisprudence †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ . it prevents a individual from take a firm standing on his rigorous legal rights †¦ . when it would be unjust for him to make so holding respects to the traffics which has taken topographic point between the parties† . An illustration of promissory estoppel is where A promises B that he would non implement his legal rights and B acted and relied on it without giving any consideration, equity would non let A to renegue on on his promise to B. The modern construct of promissory estoppel was developed in the instances ofCardinal London Property trust Ltd V. High Tree House Ltd. ( 1974 ) 1 KB 130andEntire Metal Manufacturing Ltd V. Tungsten Electric Co Ltd. ( 1955 ) 1 WLR 761. Promissory estoppel differs from common jurisprudence estoppel because it has less rigorous demands and it may originate from promise of future behavior or purpose. Promissory estoppel is traceable toHughes V. Metropolitan Railway( 1877 ) 2 App Case 439. Here the landlord gave his tenant 6 months to mend the belongings else hazard forfeiture. Within the 6 months, dialogue for the sale of the rental was opened between landlord and renter. The dialogue failed after 6 months and the renter failed to mend. The landlord sought to implement forfeiture. It was held that the landlord had led the renter by his behavior to believe that the landlord would non implement forfeiture. InHigh Tree House Ltd instance,the landlord promised to have from the tenant half of the land rent because of the trouble of happening renters during wartime period. After the war, the flats became occupied and the landlord sued for outstanding arrears during the wartime. The tribunal germinating the rule of promissory estoppel held that the landlord was non entitled to the arrears rent of the wartime period. Promissory estoppel occurs when there is a contractual relationship between parties. Like when there is a legal relationship between the promisee and the promiser. It remains unsettled whether promissory estoppel may originate in pre-contractual relationships. However, Lord Denning inBrinkom Investments Ltd V. Carr ( 1979 ) Calciumwas of the position that promissory estoppel may originate from promise made by parties negociating contracts. Similar positions was expressed in Durham Fancy Goods V. Michael Jackson ( 1969 ) 2 QB 839 where Donaldson J. held that contractual relationship is irrelevant provided that there is â€Å"a preexistent legal relationship which could, in certain fortunes, give rise to liabilities and penalties† . The first demand of promissory estoppel is that the promiser must give clear and unambiguous statement that he does non mean to implement his legal rights. The promise may be express or implied. The 2nd demand is that promisee must hold acted on that promise made by the promiser. Promissory estoppel frequently originate where promisee in trust on that promise suffered hurt as inAjayi V. Briscoe ( 1964 ) 1 WLR 1326; or where he alters his place as a consequence of trusting on that promise when though he suffers no hurt. InAlan Co. Ltd V El Nasr A ; Import Co. ( 1972 ) 2QB 18, Lord Denningheld that hurt is non an indispensable component of promissory estoppel. Therefore, for a supplication of promissory estoppel to win, there must be a alteration in fortunes of the promisee. The 3rd demand of promissory estoppel is that it would be unjust for the promiser to renegue on on his promise and claim his rigorous legal rights after the promisee had relied on it. The 4th demand of promissory estoppel is that it can non non be enforce against the promissor. Thus it can be used merely as a defense mechanism and therefore can non be used as a blade. In Combe V. Combe ( 1951 ) CA, the tribunal held that promissory estoppel does non make a cause of action and as such the demand of consideration in formation of contract is still relevant. Promissory estoppel is a regulation of grounds that prevents the promissor from denying the truth of statement which the promisee had relied. However, this demand seemed changed in visible radiation of the determinations inRe Wyven Developments ( 1974 ) 1 WLR 1097andEvenden V. Guildford City AFC ( 1975 )QB 917, here the tribunals held â€Å"that promissory estoppel can be a cause of action† . The tribunals use an nonsubjective trial to find whether it was sensible to trust on a promise. Thus certain promises like menaces would non amount to promissory estoppel where tribunal decides that trust on it was unequal. Furthermore, if the promisee did non trust on the promise, there would be valid statement that it was non unjust for the promiser to travel back on his promise. Promissory estoppel may for good snuff out the rights of the promissor to claim ball amount after part-payment. InD A ; C Builders v Rees ( 1965 ) 2QB 617,Lord Denningexpressed that the â€Å"promissor would non be allowed to return to his rigorous legal rights and that the promissory estoppel will be concluding if promisee understood the promise to intend concluding extinction of promissors’ rights rigorous legal rights† . However, for periodic payment promissory estoppel simply suspends the right of the promissor to the debt until such clip when it becomes just to claim the balance. Therefore, in periodic payments, promissory estoppel may snuff out the right of the promissor to claim payment for the suspended period but can do claim for subsequent periods after giving sensible notice or when the fortunes that gave rise to the fortunes alterations. InEntire Metal instance, the tribunal held that â€Å"on giving sensible notice to the other party, revert to their legal entitlement to have the compensation payments†

Research approach in the social world Essay Example | Topics and Well Written Essays - 2500 words

Research approach in the social world - Essay Example s, many researches were conducted regarding teenage pregnancy (Colleta, 1981; Barth and Schinke, 1984; Crockenberg, 1987; Whitehead, 1994; Kelly, 1997; Cater and Coleman, 2006). According to Teenage Pregnancy Associates (2011: 1), despite the case that the teenage pregnancy rate in United Kingdom decreased about 18 percent since 1998, England still had the highest rate accumulating a total of 35,966 conceptions under 18 years old in 2009. It is the case that the society in which we live in highly discriminates and stigmatises teenage pregnancy. There are different ‘imaginative measures’ to make teenage motherhood look nasty, disagreeable and immoral, thus ‘uglifying’ teenage pregnancy (Whitehead, 1994: 55 – 81). Girls who have been pregnant at an early age are labelled as sluts, ho, promiscuous, ignorant, incompetent, irresponsible, and so on (Kelly, 1997: 165 – 180). In this case, these young girls are stigmatized for being young moms. However, this concern is not just personal but also with the trend, the society is also alarmed. Different institutions like government, economy, education, church, and most specially, the institution of the family have been upset with the numbers young mothers. Basically, the reason that has pushed me to investigate this research topic regarding teenage pregnancy is because of how our society views these pregnant teens as well as the teenage moms. Thus, the necessity to conduct an exploratory study of the experienced and circumstances contributing to the crisis of teenage pregnancy can be backed – up by the current situation of our society in relation to the issues on teenage pregnancy. However, in this study, instead of looking from the perspective of society, this will examine the perspective of the young moms. The question of who will be the beneficiaries of this academic endeavor is not only the pregnant teens and teenage moms but the society as a whole because as the stories of these girls are told through this

Management in a early years setting Essay Example | Topics and Well Written Essays - 2750 words

Management in a early years setting - Essay Example Introduction Evidently through research, it is clear that in an early setting there are certain guidelines that manager should adhere to in order to enhance correct management. There are diverse guidelines in the setting and so manager’s attitudes shape the form of program. In any given business, management is something which should be done in the right manner possible, and this should be able to integrate all elements of management and functions as well. This becomes a defining application which has the capability of improving performance and ensuring that business goals have been realized within the shortest time possible. For instance, within any strategies of management, it should be appropriate to adopt a number of practices, theories and organizational adoptions which have the capability of improving performance of business. In early year setting, management is considered to be significant since this determines several aspects in the running of the business. With this un derstanding, this paper critically presents a discussion in management in early year settings from a broad point of view. This is enhanced through covering several different topics related to management and responding to different questions succinctly. Critical Analysis of the Management of Provision of the Setting The setting followed through early year’s management stage-offset and the attitudes at the same time as can be set on the subject of specific documents outside the setting. Documents in the settings, it is significant to note down that not every expert that is working in the setting have an identical attitudes and beliefs in place (Harrison, 2003, P. 38). In that sense, they can differ appreciably between individual, and there is no incorrect value, attitude or belief. In this section, the roles of a manager will be highlighted clearly. The Manager’s Roles and Responsibilities Essentially, the main role of a manager is to supervise and ensure that the settin g is been run in accordance to the set guidelines (Laura, 2008, P. 48). The manager therefore, becomes responsible to supervising staff when required and ensuring that the staff is always organized in order to accomplish their tasks. There are innumerable ways through which change in an early management can be achieved. This is through the role played by managers as well as their responsibilities. It is evident that members of staff do not have the accountability to deal with management. Their responsibility in the organization is to do what is most excellent for the benefits of the entire organization (Wang, 2010, P. 18). Therefore, the accountability for dealing with management in early year setting is the role of managers. Managers should cope with the change in a manner that workers can get by it. The role of the manager is to keep up to date with registers and other important data files, for children in their early setting. Managers should play the role to smooth the progress a nd facilitate change, and all this is disguised in that declaration in order to comprehend the circumstances from

Diffused Responsibility Essay Example | Topics and Well Written Essays - 250 words

Diffused Responsibility - Essay Example Rather than any one individual feeling responsible for reporting what was going on, seeking to stop it, or seeking to ascertain whether the action that appeared to be a car being burglarized was indeed as it appeared, everyone in the group, including those passersby that were not related to me or my group of friends felt that they could merely ignore the situation due to the fact that any number of other people could report what was going on. In retrospect, this type of apathy is precisely what the thieves depended on for this type of brazen crime. Looking back on the situation with the knowledge of what motivating emotion and psychological response helped to make everyone feel that it was not their ultimate responsibility does not help to make me feel any better concerning the given situation; rather, it makes me aware that if such a situation occurs again, the response I should seek to control is that of diffused

The Galapagos Islands Essay Example for Free

The Galapagos Islands Essay The Galapagos Islands were first inscribed as a World Heritage site in danger in 1978. This was extended in 2001 and they were again inscribed in June 2007. The islands are found on the Pacific Ocean, 1000 kilometer from the South American continent, they are in Ecuador. They are 19 islands which lie on equator so their seasons vary very little. They have been called a unique â€Å"living museum and showcase of evolution†. (www. whc. unesco/org/en/danger). The islands were formed by seismic and volcanic activities which are still ongoing processes. These together with the extreme isolation of the islands, led to the development of unusual animal life such as the land iguana, giant tortoise and many types of finch. The finch inspired Darwin’s theory of evolution following his visit in 1835. The islands are referred to as an archipelago as they are very isolated from the nearest continent and the islands themselves are separated from one another. This separation and differences in climates favors evolutionary change. As a result, populations that are related follow separate evolution tracks leading to emergence of various species and even further diversification. The species so formed become very susceptible to changes in the environment. ( www. darwinfoundation. org) The uniqueness of the island lies in its marine and land ecosystems, and presence of flora and fauna endemic to the islands and in most cases found nowhere else in the world. The marine ecosystem is composed of both cold and warm water current systems, marine landscapes â€Å"bajos†- these are underwater mountains formed by volcanic activity they rise almost to the oceans surface. Some of the coastal animals found in the Galapagos marine reserve are sea lions, fur seals, albatrosses, several species of booby, frigate bird species, sea turtles marine iguana, penguins and flightless cormorants. (www. darwin. foundation. org) The land habitats of the Galapagos are mainly determined by their vegetation which is in turn determined by the local climate. The vegetation of the area is strongly zoned by altitude. The land ecosystem has such animal species as land iguanas, land snails, rice rats among others. The Galapagos contain a total of 560 native species of flora,180 are endemic (www. darwinfoundation. org). Some of the plant species include scalesia, opuntia cacti and the Galapagos rock-pursane and other lesser known species. Human intrusions threatening the area Threats to this hub of diversity are mainly in the form of fishing and tourism by humans. In the 1990s, fishing led to a big decline in some of the marine species such as sea-cucumbers and sharks. Then, the fishermen would fish the sharks just for their fins and the remainder of the shark’s body would go to waste. Fishing is the second most important economic activity in the region and marine resources were overused by such practices as illegal fishing and over fishing. The dangers presented by the Galapagos fisheries are-: i) Large international vessels fishing around the Galapagos pelagic zones and inside the Galapagos Marine Reserve (GMR) which is illegal. Long-lining and use of large seines are modern high-technology methods with devastating effects of depleting marine species. (www. darwinfoundation. org) ii) There has also been a rapid influx of poor fishermen from the mainland of Ecuador who serve the interests of mainland fishing companies and middlemen buyers. The fishermen are provided with capital in the form of a loan by the fishing companies to buy boats and equipment. The fishermen then sell the catch to the companies; the catch is later sold in the international market especially the Asian market. The influx has led to the human explosion being experienced in the islands and also the immigration brings with it invasive species which compete with the natural species of the islands decreasing their survival chances. ( www-darwinsfoundation. org) Tourism is the leading economic activity in the Galapagos Islands. Tourism has grown economically at 14% per year and this has lead to the Galapagos experiencing drastic, social, economic, cultural and ecological changes. (www. galapagos. org) The dangers that immigration poses include increased pollution, overuse of resources and eventually a charge in climate and introduction of invasive species. A change in climate will lead to loss of some of the species in the island. Invasive species refers to alien plants, diseases, insects and other organisms that people bring inadvertently to the islands. There are now 1,321 introduced species, compared to 112 identified in 1990. These include 748 species of introduced plants compared to 500 species of native plants and at least 490 species of introduced insects. The risk of the arrival of pathogens such as the West Nile virus, insect pests, and new predators is now high-: Dengue-carrying mosquitoes and some avian diseases are new arrivals in the islands. (www. galapagos. org,2007) Existing protection areas The Galapagos Islands have several protection areas. The Galapagos National Park (GNP) is one of this. 97% of the area covered by islands was designated as a national park in 1959. The lands not included were the settlement areas. Later in 1967, a park service Galapagos National Park service (GNPS) was set up to oversee management and administration of the park. The GNP is made up of 13 large islands, 17 small islands and 40 rocks. (www. galapagos. org/). The park authorities educate the visitors and enforce the laws and regulations of the park. The GNPS also oversees the management and administration of the Galapagos Marine Reserve (GMR) which was set up in 1998, another protection area. The GMR’s function is to protect the waters surrounding the archipelago. 3000 species of marine plant and animals are found in the GMR. The necessity of the GMR became apparent when in the 1990s fishing activities around the archipelago increased and almost had devastating effects on the marine species due to the high demand of both sea cucumbers and sharks’ fins. The GNPS also approves itineraries. This ensures that no one place is too frequently visited. This serves to distribute tourism to all the islands, decreasing chances of harm to the environment. The GNPS works together with the Charles Darwin Foundation, now known as the Galapagos Conservancy. The foundation provides the scientific and technical know-how required in maintenance of the natural biodiversity and ecosystems of the islands. Other protected areas include Sangay National Park, Limoncocha Reserve, and Antisana Ecological Reserve which has the Antisana volcano that is 5758 meters high. The reserve was created in 1993. The Cuxabeno Forest Reserve is another protected area, for two thirds of the year the forest is submerged in water and when it is not, it is made up of dry futbol fields (www. ecuador. com/,2007). It was established in 1979. Part of the 6000 square Kilometer rain forest makes up part of the Amazon Rain forest. There are indigenous people found in this forest whose contribution to reservation is through jungle tours and eco-tourism. Existing efforts in Galapagos to protect and preserve the area include:- i) Registration of fishermen to fishermen’s cooperatives. This has enabled the monitoring of fishermen’s activities and from this an estimate of how much fishing is going on can be got. Also, it makes it easier to track illegal fishing. ii) Establishment of the Galapagos Marine Reserve in March 1998. In this area, all fishing is banned. The area covered by the GMR was expanded TO cover 40 miles around the whole archipelago. These are also zones of protection around the islands. All these are patrolled by GNPs park rangers. The sea shepherd conservation society assists with carrying out patrols in the service. iii) Approving the designation of the Galapagos Archipelago as Particularly Sensitive Sea Area (PSSA) by the Marine Environment Protection Committee(MEPC). PSSA is defined by the International Marine Organization (IMO) as â€Å"an area that needs special protection through action by IMO because of its significance for recognized ecological socio economic or scientific reasons and because it may be vulnerable to damage by international shipping activities†. ([IMO,2001]www. dorwinfoundation. org) iv) Introduction of residence controls which decrease immigration and in turn lower the flow of alien species. The aim is to curb population growth. The controls are however difficult to implement because it is difficult to determine genuine residents and those who come and go but have permanent residence elsewhere. (www. law. emory. edu/ ) v) Education of residents, tourists and Galapagos policy makers on how beneficial sound conservation, practices, polity and sustainable economic activities are for example finding alternative viable economic activities for the local fishermen. vi) The success of Project Isabela. This project has seen a large area being freed of feral goats and pigs. Subsequently there has been an increase in Galapagos’s rails. Areas that had been previously degraded have now become resting areas for petrels and re-establishment of vegetation like tree-terns and endemic scalesia has occurred. Also native invertebrates thought to be extinct are now being identified (www. darwinfoundation. org, 2007) vii) Successful breeding programs for tortoise run by the Charles Darwin Foundation and GPNS has led to repopulation of some islands with their native reptile species. The giant tortoise was becoming extinct due to hunting by humans and other animals. (www. galapagos. org) viii) Inclusion of various sectors in the management board of the Galapagos National Park service has been instrumental in bringing about an attitude of conservation and preservation. At first the local people felt that the government was only concerned about plant and animal life. The multisectoral approach involves key players in fishing, tourism and conservation sectors and also the local person. (www. galapagos. online/) Including the local people has helped to enhance the concept of conversation because the local people no longer feel neglected. Should human intrusion go unchecked, the loss will be great. Maintenance of the rich biodiversity of the islands is achievable of the ecosystem can support sustainable economic use where the local people, conservationist and players in tourism and fishing industry feel their needs have been put into consideration. An example of how the biodiversity can lost is seen in the fact that the present tortoise population is very small. Poaching, destruction of habitats and the presence of invasive species are the main dangers to the tortoise population. (www. galapagos. org, 2007). Though the near extinction of the giant tortoise caught the attention of people and the process was reversed the giant tortoise is not out of the woods yet, and the work of repatriation needs support. In the process of poaching the tortoise, various invasive species which trampled on the tortoise’s habitat were limited and multiplied faster than the tortoise would, leading to destruction of the tortoise habit. The mangrove finch is another species being driven towards extinction. Again the greatest threat to be mangrove forests and the finches is the exploding human presence in the Galapagos. (http://www. galapagos. org/about. html). Increased activity among humans increases the risk of disease further especially avian pox, black rats, cats, fire ants the parasitic fly philornis. All threaten the mangrove finch as well as vulnerable species in Galapagos (http://www. galapagos. org/about. html. ) For the mangrove finch to be saved there has to be study of the mangrove finch and its habitat. Activities that would require support in the mangrove finch conservation project include: ? Creating potential captive breeding facilities for the mangrove finch. ? Resting degraded mangrove finch ecosystem, including establishment of new mangrove forest plots. ? Releasing the captive-bred birds to sites on Isabela and Fernandina islands where the mangrove finch once thrived. For the future generations to be able to see and be part of the abundant biodiversity in the Galapagos islands the necessary funds and a coalition of leadership are needed to successfully conserve and preserve the world heritage site. Otherwise, we risk losing not just an area rich in natural biodiversity but a site of origin of human philosophy and in the process part of the human race. Because of ecological interdependence, there can be no climate changes that will affect animals and plants only, whatever adverse effects will affect flora and fauna will also affect the human race. This means that no part of the ecosystem will be spared the price of not doing all that is necessary to protect and preserve the balance of nature. Conclusion Islands are generally smaller than continental areas but are basically more or less the same with similar social, economic and ecologic changes happening. This then means that islands can and should serve as a model to the rest of the world for these changes (www. darwinsoundation. org). In coming up with solutions to the Galapagos problems we are more or less coming up with a prototype to solve problems that will occur in other continents of the world, but if we cannot resolve the issues then it means that we will also fail in achieving a society where there is a balance of nature and social economic sustainability in the rest of the world. References Charles Darwin foundation, Galapagos Risk; Ground Breaking Analysis Produced retrieved July 6 from http://www. org/en/library/pubs/2007/galapagos Galapagos Conservancy, ‘Breaking News: Galapagos in â€Å"Danger† Retrieved July 6 from http://www. galapagos. org/about. html. ‘Protected areas’ Retrieved July 7 from http:www. ecuador. com/protected-areas UNESCO, Galapagos islands, Retrieved July 7 from http://whc. unesco. org/en/danger UNESCO World Heritage in Danger List July 7 from http://whc. unesco. org/en/danger/ .

Oedipus the king the poem

Oedipus the king the poem The poem was written in ancient period and it highly reflects the value and beliefs in the ancient period. The poem starts by Priest of Zeus and his followers appearing to the King Oedipus with tree branches woolen wrapped. This shows cultural belief of appearing before the gods alter when you want your needs attended to by the goods. The priests talks on behalf of his followers and explains to the king about the outbreak of a plague in the society that is killing plants, animals and human as well. However, King Oedipus heard them and explained to them that he had sent his brother in law, Creon, to the oracle which belonged to god Appolo at Delhi so as to get answer for to the solution of the plague. Afterwards Creon arrived and since he was bringing good news he had worn laurel leaves with berries around his head. Appolo said that plague was to end after the killer of Laius is found and killed and Appolo had promised that serious investigations would reveal the murderer. However, this was bad news for the king. Ironically, asked to review the facts. All that was known at the time was the Laius had left for Delphi never to return. There was to be no investigation immediately because of the sphinx problem. There is one of Laiuss men who escaped and ran back to Thebes and on arriving he found Oedipus in the process of being hailed as a king. This made him to keep the secret with him since the killing Oedipus was the master planner for the killing. The witness just said that Laius was killed by robbers who attacked his chariot along the way. The witness because of fear for his life asked for a transfer from Thebes and he went away ever since. However, ordinary people because of desperation said that Apollo ought to come to Thebes and say who the killers were. This is because people never had faith on the investigations of their king and thought that only a foreigner who is powerful than their king who could bring justice to their land. Oedipus to his defense told them that nobody has power to tell gods to do what they do not want to. Later, they suggested that they bring Teiresias who was a blind psychic to carry out the investigations. He was believed that when he was a young man, he ran to magic snakes which changed his gender for seven years and this was to enable him tell which gender enjoyed sex more compared to the other. This was said to have been a secret only known by gods who ended up punishing him with permanent blindness. This explains how people believed in superstitious powers and feared their anger actions. (Lawall,45) In conclusion the poem about Oedipus the king has a thematic meaning that reflects culture and beliefs of the ancient period. First, the ancient period is seen as the era of psyches and superstitious powers. The society believed in prophesies form gods regardless of their morality status and their realization is seen as to never tarnishing someones reputation. In the poem Oedipus feels guilty for his deeds but to the society this has been prophesied that that could have granted him self-defense. Second, the kingdom was dictatorial and highly immune to justice. Poet says that society was turning a blind eye to the faults of the king. Sir Gawain and the Green Knight The poem on Sir Gawain and the Green Knight is romance poem which was written in the middle Ages in late 14th century. This poem represents values and beliefs of middle ages in a big way. The poem illustrates the role of a man in the society. A man was to perform certain things, have a particular look, and act in a particular fashion. Some of behaviors which demonstrated masculinity included battle, sexual activity and pleasing ladies with deeds and words. These demonstrations appeared somehow as Christianized shadows of Gallo-Celtic ideals of heroism and godhood. In the poem Christianity stands strongly against heroic ideals and poet describes its passage in the period. In the testing Fits, the third Fit illustrates how Gawain gets involved in a game with Lord Bertilak who was the castles lord in which stayed awaiting the confrontation between him and the Green knight. They traded for three days he stayed inside the castle, what they gained during the day. He did not realize, though, that that the game was a part of Green Knights tests against him. The first two days, the game proceeded well, with Bertilak being the meat deliverer, and Gawain delivering the kisses Lady Bertilak bestowed upon him faithfully. In the third day, Gawain was trading the Ladys kisses for Bertilaks fox meat, but not girdle she had earlier given him, because he had vowed to her that he would not. This happened to be Gawains only mistake, as we see in the Fourth Fitt. Which concludes his trials when he faced off against the green knight for what he was thinking was the second time, but later discovered it was the third. In Gawains meetings with Green Knight, it is noted that two of the three trials were also the three part trials unto them. These were the three nights which were in the castle, and the three blows with an axe at the end. The sets of the three were considered to be magical in nearly every culture of the world, because they usually were the representatives of a basic family unit. However it was strange that there were to be only two sets of the three sub-trials instead of three, which required that I might have missed something in the first fitt, but I could not have found even a hint that trial of beheading the Green Knight had three divisional parts. In the last trial, Green Knight swung for three times at Gawains neck and finally nicking him during the third swipe. By having given the three blows, Green Knight revealed that he was Bertilak, and explained to Gawain that each blow was representing every night spent in the castle. Gawains only mistake was not that of mentioning the girdle to Bertilak, for which he had been nicked with the axe. Gawain would not accept that he had passed the three tests, and that, in Bertilaks eyes, was even a further proof that he had passed. Gawains perfect honesty and humility rendered him worthy to receiving wisdom that Bertilak had to offer. Nature verses the human society appears as the main conflict in the poem by which Gawain had to deal with during his time. He was had to confront the forces of nature which were against him. These natural forces were in the form of Green Knight, sexual desires, winter landscape, and ultimately, fear of dying. Throughout his life Gawain countered this with faith in God and chivalric values he had. But in the end, fear of death he has overcomes his senses of morality and led him to accepting that green girdle. This poem is enriched with constructs descriptions of human, like architecture, food armor, clothing and the cutting of hunted deer. This implies that there was a ritualistic, overly technical in-depth sense to those descriptions. There are areas where poet seems to be hinting at power of those human constructs. For instance, concept of Courtly Love is one such an elaborate of human construction, but in the third fitt, it is based mainly on the conversation between Gawain and Lady Bertilak. Despite the poems Christian message, it has strong roots to the Celtic myth of paganism. There exist many elements that are common to pre-Christian Celtic mythology; such include the waiting the period which runs for twelve months and a one day, beheading, and temptation game. The Green Knight is himself seen to be a strong pagan, similar to Green Man or Woods Wild Man who symbolized fertility in folklore. Gawains journey cannot be seen as a heros archetypical encounter with the otherworld, which is an essential theme in paganism belief. The pentangle is a pagan symbol; thus Gawains shield, represents pagan and Christian nature of the poem. (Mills,56) In conclusion, thematic meaning of the poem mainly describes the fall of men and loss of innocence. This shows how leaders in the middle age period faced many challenges most of whom lied under human character. Biblical parallels are found in the turning up of Bertilaks castle and role of his wife as a temptress. Accordingly, Gawain lost moral innocence when his chivalric value system is shattered off by the end of poem. An allegory as such seems to be emphasizing more on the poets message of Christianity, and relationship between the divine and mankind. The Paradise lost The poem was written in 16th century. It is about Adam and his wife Eve- how they were created by God, given the Garden of Eden, the Paradise, and how they lost it. The poet, Milton, is seen to have taken the story from the bible in the book of Genesis and expanded on the same. The poem also has the story about the origin of Satan who was originally called Lucifer. Lucifer is seen as an angel in heaven who tries to lead his followers against God and is sent into hell. He plans a revenge attack against God and thirst for revenge made him to cause mans downfall by tempting the wife of Adam. He turned into a serpent and tempted eve to eat the forbidden fruit which angered God and made him through man away from the paradise. The poem starts in hell, here Satan and his angles are recovering from a tragedy defeated they conceded in away they had waged against God. They opted to build a paradise which would serve as a meeting place as they plan to return to the battle. Instead they decided to go to a new world which is said to have been created. This reflects the nature of human in architectural development and innovation since Satan and his angels were eager to go and explore the new world said to have been created. Satan goes to explore the new world. At the exit door of hell is met by Sin and Death who restricts his exit. He uses another tough journey through chaos until he gets into new world. God sees his approach sand foretells the failure of man. His son offers to sacrifice himself for the salvation of man. This reflects the belief of the people of this period where they believed that Gods son offered to sacrifice himself for the salvation of man. Adam and his wife fell into Satans temptations and God sent them away from the Paradise. (Bradford,78) In conclusion, the poet was trying to explain the origin of mans failure to the people of the Renaissance period. This is the period in which art, architectural work and landscaping had started taking course in the world. The poem shoes God as the first creator or builder of objects where Satan told followers that there is anew world which has been created and poet views the world as the den of sins since it is where Satan carried out revenge attack against God.

Potential and Challenges for Carbon Sequestration in Agricultural Soils

Agriculture occupies a larger portion of global land area (about 35%) than any other human activity (Betts and Falloon, 2007). Agriculture soil stocks have been suggested as potential measure to sequester atmospheric CO2 to help stabilize its concentration in atmosphere and has been estimated that 0.4-0.9 Pg C year-1 can be sequestrated within global agricultural soils (Paustian et al., 1998). This has been supported by the fourth assessment made by the Intergovernmental Panel on Climate Change, that identified agriculture as among the economic sectors having the greatest near-term (by 2030) greenhouse gas mitigation potential, largely via soil organic carbon (SOC) sequestration (Smith et al.,2007). However, currently, there is much uncertainty and debate due to uncertainties associated with quantifying the impact of the various crop management practices on green house gas emission ,the spatial and temporal scales involved in quantifying greenhouse gas emissions from, and C sequestration in, agro-ecosystems, uncertainty of future climatic conditions that affect type of crop mana...