William D. Ruckelshaus and the EPA

Introduction The case under discussion, William R. Ruckelshaus and Environment Protection Agency, is really important as it raises the problems of government and management, leadership and decision making in the organization.Advertising We will write a custom essay sample on William D. Ruckelshaus and the EPA specifically for you for only $16.05 $11/page Learn More Environment Protection Agency (EPA) under Anne McGill Burford’s ruling was convicted of perjury. The image and the work of the whole organization became so bad, that the employees were ashamed of the place they worked at. Sarcasm at the direction of the company director was too much. William Ruckelshaus, the first administrator of EPA, was invited to his previous positions to organize the work in the department and raise the prestige of the organization. The problems stated in the case study are really relevant as much attention is paid to the organization of work of human resources, le adership and decision making. The incorrect organization in one of those issues lead to the problems the company faced (Lipshitz Mann, 2005). Moreover, being the part of the government, the lack of public value could lead to the distrust to the whole government. Background The main idea of the case is to represent the activities which may be taken in the image recovering direction. William Ruckelshaus was invited for the temporary position in the EPA. The organization was ruined even inside as the employees of the organization were ashamed of the fact that they worked in the EPA, without mentioning about the public attitude. The previous administrator has created a bad image of the organization and a new one faced a lot of different issues, like: (1) there were too many vacancies which had to be fulfilled, (2) ruining of a block on legislative priorities about giving the companies more authority about pollution control installation, (3) encourage all the companies to clean up pollu tion they cause, (4) meet the international standards about the emissions which cause acid rain, (5) settle financial regulations with the government, (6) some political issues had to be solved. Linkage of the case to Public Administration issues The case under discussion is closely connected with the public administration and the issues it has to solve. It underlines the specific issues the government arises when makes legal regulations and enforces them. Before getting down to the discussion of the issues the case refers to within the public administration responsibilities, it is important to state what a public administration is. Public administration may be considered as â€Å"all processes, organizations, and individuals associated with carrying out laws and other rules adopted or issued by legislature, executives and courts† (Milakovich Gordon, 2008, p. 11).Advertising Looking for essay on business economics? Let's see if we can help you! Get your first paper wit h 15% OFF Learn More The case refers to the court procedures where the organizations should be given more power devoted to making decisions about when the expensive pollution controls should be installed. Moreover, the international regulations should be settled which are usually considered by public administration. Public administration executes the law (Beckett Koenig, 2005) and the main issues Ruckelshaus has to face in the study are to follow the law and execute its demands. Furthermore, public administration presupposes work with people, their organization and following. Ruckelshaus has created specific rules which have to be followed by the employees. He may be considered as the administrator who has implemented the way and waits when people are going to subject to it. To make proper decisions, to direct necessary people to the appropriate direction and to make them follow those rules are the main executive responsibilities a new administrator had to bear. Willliam D .Ruckelshaus and the EPA case study Was there a difference between Ruckelshaus’s external environment and that of business executive? The external environmental Ruckelshaus had to exist in was rather aggressive and negatively prejudiced. Ruckelshaus was surrounded by different organizations which expected from him specific actions. He had tried to make all possible to meet the expectations of the organizations and society. So, it may be completed that there was no difference between the external environment and the business executives provided by the administrator. He did all possible to meet the requirements of the congress and to appease congressional critics, he provided consultations with citizens to increase their participation in the environmental affairs and to make them understand that the EPA has the only goal, to restore its image and make all possible to return human trust. One of the first actions Ruckelshaus did was the revision of the policies and legislative do cuments used by the EPA. This action was directed at the consideration of the standards the organization followed and checking whether these standards were met. The reports devoted to this information helped structure the future work, organize the relationships with the department and other organizations which expected some actions from the EPA. Thus, internally, Ruckelshaus provide the actions which were aimed at restoring the industry, organize a proper work of human resources and to establish relations with the departments in the government which are useful for the successful organization function. In the relation to the external environment, the same actions have been provided but on the other level. Everybody expected actions and changes from a new appointment, and Ruckelshaus justified the expectations of the whole society. Ruckelshaus’s eight â€Å"rules of thumb† Turning to the discussion of eight â€Å"rules of thumb† Ruckelshaus has used as the recover y strategy, the following logic basis may be considered. To improve the public opinion about the organization and the restore its positive image, Ruckelshaus pays much attention to what the employees say to people about the organization, even to the colleagues.Advertising We will write a custom essay sample on William D. Ruckelshaus and the EPA specifically for you for only $16.05 $11/page Learn More Much attention is paid to the government and the leadership in particular. People should have someone who they can respect and follow. To solve the legislation and political issues, Ruckelshaus uses the strategy of minimizing political miscalculations as these problems may be strong barriers on the way of achieving success. Ruckelshaus has decided to search for people who are not connected to the industry, because he is afraid to facing those who dealt with Anne McGill Burford and continue unfair activities inside the organization. To return organizationsâ €™ good name and positive image, Ruckelshaus had to set new goals of the administration. Having analyzed the changes conducted by Anne in this case, William understood that they were directed not at the improving the impact on the environment, but on making the responsibilities of EPA fewer. The change of the goals and their announcement to the society may help in improving the attitude of the citizens to the organization. Ruckelshaus wants to show people that working on the environmental problems, EPA is unable to solve some of them in a number of reasons. To reduce the prejudiced attitude to the society to EPA, the educational courses are created. To increase the public image and to fill vacant slots, Ruckelshaus tries to address the public policies in the light of the social goals. To minimize the costs in the future, Ruckelshaus uses the research to identify the environmental threats and to assess the risks which may appear in the future. Highly paid business executives and the reasons for a large pay cut When Ruckelshaus was invited to his previous position, he was encouraged to do much work, solve numerous problems are make all possible to return the organization on the previous high position and form positive attitude in society. Even though much and complicated work had to be completed, Ruckelshaus agreed on large a pay cut. Such decision may be explained by a number of reasons. First of all, Ruckelshaus was the first administrator of EPA. It seems that when he saw what was done with the organization which he had created, he could even agree to work for the lowest salary. This was an affair of honor for him to return the EPA to the previous condition. He just liked the job he had done before and he wanted to return to his previous responsibilities. The second reason for agreeing on pay cut was the understanding that too much costs had to be put in the recovery strategies. Ruckelshaus understood that the organization budget may fail to cope with the high costs. Anyway ethical responsibility before the society is the main reasons why such costly word was done for less payment.Advertising Looking for essay on business economics? Let's see if we can help you! Get your first paper with 15% OFF Learn More Such actions may be also considered as the first step on the way to the company recovery. To show that he works for free might show the society that he was going to be responsible in his actions and decisions, not to his personal benefit but for the benefit of the whole society, environmentally protected. The third reasons might have been the understanding that money is nothing in the comparison with the pleasure he gets from doing the things he likes. It is really important to be satisfied from being a leader, from making the decisions which carry great responsibility but at the same time prove that the experience and knowledge he had got during his life were not spent in vain, and from managing people in such a way that they want to work in the company, that they want to perform the tasks they are assigned to. Conclusion In conclusion, it should be mentioned that Ruckelshaus is a professional. He took a position when the company was almost destroyed, when employees were ashamed th at they worked there, when the standards were not met and the legislative and political problems overwhelmed. Having faced a number of issues and applied specific strategies, the organization had managed to return its image due to the specific â€Å"rules of thumb† which have been dictated by the situation and the problems which had to be solved. I have learnt that leadership and proper decisions making are the main issues for successful business running. The correct human resource management and appropriate goals are also important to meet the society expectations. A wise administrator who can do his/her job in a proper way is a guarantee to the company successful development. Reference List Beckett, J. Koenig, H. O. (2005). Public Administration and Law. Armonk, NY: M.E. Sharpe. Lipshitz, R. Mann, L. (2005). Leadership and Decision Making: William R. Ruckelshaus and the Environmental Protection Agency. Journal of Leadership Organizational Studies, 11(4), 41-53. Milakovic h, M. E. Gordon, G. J. (2008). Public Administration in America. Stamford: Cengage Learning. This essay on William D. Ruckelshaus and the EPA was written and submitted by user Camilla Oliver to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.

Storing Record Data in a BLOB Field in Delphi

Storing Record Data in a BLOB Field in Delphi In Delphi, a record data type is a special kind of user-defined data type. A record is a container for a mixture of related variables of diverse types, referred to as fields, collected into one type. In database applications, data is stored in fields of various types: integer, string, bit (boolean), etc. While most data can be represented with simple data types, there are situations when you need to store images, rich documents or custom data types in a database. When this is the case you will use the BLOB (Binary Large Object) data type (memo, ntext, image, etc. - the name of the data type depends on the database you work with). Record as Blob Heres how to store (and retrieve) a record (structure) value into a blob field in a database. TUser record ...Suppose you have defined your custom record type as: TUser packed record   Ã‚   Name : string[50];   Ã‚   CanAsk : boolean;   Ã‚   NumberOfQuestions : integer; end; Record.SaveAsBlobTo insert a new row (database record) in a database table with a BLOB field named data, use the following code: var   Ã‚   User : TUser;   Ã‚   blobF : TBlobField;   Ã‚   bs : TStream; begin   Ã‚   User.Name : edName.Text;   Ã‚   User.NumberOfQuestions : StrToInt(edNOQ.Text) ;   Ã‚   User.CanAsk : chkCanAsk.Checked;   Ã‚   myTable.Insert;   Ã‚   blobF : myTable.FieldByName(data) as TBlobField;   Ã‚   bs : myTable.CreateBlobStream(blobF, bmWrite) ;   Ã‚   try   Ã‚  Ã‚  Ã‚   bs.Write(User,SizeOf(User)) ;   Ã‚   finally   Ã‚  Ã‚  Ã‚   bs.Free;   Ã‚   end; end; In the code above: myTable is the name of the TDataSet component you are using (TTable, TQuery, ADOTable, TClientDataSet, etc).The name of the blob field is data.The User variable (TUser record) is filled using 2 edit boxes (edName and edNOQ)and a check box (chkCanAsk)The CreateBlobStream method creates a TStream object for writing to the blob field. Record.ReadFromBlobOnce you have saved the record (TUser) data to a blob type field, heres how to transform binary data to a TUser value: var   Ã‚   User : TUser;   Ã‚   blobF : TBlobField;   Ã‚   bs : TStream; begin   Ã‚   if myTable.FieldByName(data).IsBlob then   Ã‚   begin   Ã‚  Ã‚  Ã‚   blobF : DataSet.FieldByName(data) as TBlobField;   Ã‚  Ã‚  Ã‚   bs : myTable.CreateBlobStream(blobF, bmRead) ;   Ã‚  Ã‚  Ã‚   try   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   bs.Read(user,sizeof(TUser)) ;   Ã‚  Ã‚  Ã‚   finally   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   bs.Free;   Ã‚  Ã‚  Ã‚   end;   Ã‚   end;   Ã‚   edName.Text : User.Name;   Ã‚   edNOQ.Text : IntToStr(User.NumberOfQuestions) ;   Ã‚   chkCanAsk.Checked : User.CanAsk; end; Note: the code above should go inside the OnAfterScroll event handler of the myTable dataset. Thats it. Make sure you download the sample Record2Blob code.

Although the foetus has no right to life, its interests are adequately protected by English law.

There is currently no direct right to life that is provided to a foetus, yet the law in the UK does make some attempt to protect its interests. This essay will focus on the interests that are provided to foetus’ in order to consider whether adequate protection is in place. In doing so, it will be examined whether every woman should have a right to abortion on demand or whether the interests of the foetus should be given due consideration. Accordingly, it will be shown that because there are arguments for and against the interests of the foetus, it is necessary for the law to strike a balance between the two competing interests. This does appear to have been achieved to a certain degree since the interests of the mother are being preserved, whilst also providing some protection to the foetus. The right to life The right to life is provided to all individuals under Article 2 of the European Convention of Human Rights (ECHR) 1951, as incorporated by the Human Rights Act (HRA) 1998. Whether or not a foetus has a right to life, however, is a highly contested topic because although the foetus does not have a right to life per se, it appears as though its interests are still being protected by the law to a certain extent.[1] On the one hand, it is believed that all women should have the right to do as they wish with their own bodies and that they should therefore have a right to abortion, yet on the other it is believed that the interests of a foetus should be provided with adequate protection.[2] The law in England does seem to have attempted to strike a balance between these two competing interests by permitting abortion, whilst at the same time imposing some restrictions. Under English law (Human Fertilisation and Embryology Act 1990) abortion is permitted until the 24th week of a pregnancy. Whilst this provides women with the right to choose what to do with their own bodies, it prevents them from having abortions in the later stages of pregnancy. Because abortion is not legally available at the request of the woman, it has been argued by the Abortion Rights Campaign that; â€Å"women’s access to abortion can be and is still threatened.†[3] This is because, once a woman has decided that she wants to have an abortion, she will first be required to persuade two doctors to agree to her decision taking into consideration certain restrictive legal criteria.[4] Therefore, even though women are capable of having an abortion up until the 24th week of pregnancy, it will be the doctors that make the final decision. And, if they do not agree that the relevant criterion has been satisfied, they will not have to carry out the abortion. This protection is in place to enable the rights of the unborn child to be ascertained in circumstances which would render an abortion unlawful. However, the extent to which such rights are being adequately protected is in fact arguable. Confliction continues to arise in this area because of the difficultly in striking a balance between the rights of the foetus and the rights of the mother. It cannot be said that this balance is currently being achieved as there remains strong opposition of both viewpoints. As pointed out by Mason and Laurie; â€Å"attitudes to abortion depend almost entirely on where the holder stands in respect of, on the one hand, the foetal interests in life and, on the other, a woman’s right to control her own body.†[5] Consequently, because the difference in opinions is based upon moral values rather than empirical facts, it is unlikely that such confliction will ever be resolved.[6] In effect, it is unlikely that a solid understanding of the rights in this area will ever be made as the controversy surrounding abortion will continue to exist. The Foetus’ Right to Life It is believed that the Abortion Act 1967 violates Article 2 of the Convention on the Rights of the Child on the basis that a child’s rights are not being adequately protected if women are able end their pregnancy if they so wish.[7] Section 1 of the 1967 Act provides that; â€Å"a person shall not be guilty of an offence under the law relating to abortion when a pregnancy is terminated by a registered medical practitioner.† In effect, women will not be found guilty of an offence is they decide to have an abortion. Whilst this section does appear to undermine the rights of the foetus, the fact that the termination must be conducted by a registered medical practitioner acting in good faith suggests that some form of protection will still be in place. Furthermore, as put by Herring; â€Å"for an abortion to be lawful, the abortion must comply with the requirements of the 1967 Abortion Act.†[8] Section 1 will therefore only apply if certain provisions can also be sa tisfied. Nevertheless, because abortions are rarely ever refused, it could be said that the provisions under Article 2 are being undermined and that the interests of the foetus are not, in reality, being adequately protected. In view of this, it has therefore been argued by Foster that the 1967 Act is not being used in the way that Parliament intended and that abortion are instead being used as another form of contraception.[9] This demonstrates how abortion is easily accessible to women, which limits the protection that is currently being provided to the foetus. It is likely that doctors will only refuse to conduct an abortion if the woman’s pregnancy has gone past the 24 week threshold or if the circumstances are exceptional. This signifies how the rights of unborn children are not being preserved, yet it is debatable whether further protections ought to be in place. The right to life is an extremely sensitive subject since it basically provides a right to every human being not be killed.[10] However, much complexity exists when considering the right to life in the context of unborn children. It is difficult to determine whether the mother’s rights should prevail over the rights of the unborn child or vice versa. However, it has been said that the right to life is a human right that is â€Å"inviolable and must be protected at all costs.†[11] If this statement was to be taken strictly, every abortion would be considered a violation of one’s human rights and would not be permitted. However, in order to ensure that the rights of the mother are also being protected it is necessary that abortions are permitted in certain circumstances. This would ensure that a balance is attained between the two competing interests by allowing abortions to take place only if it is deemed necessary. Consequently, abortions should not be used carelessly as another form of contraception and this would means that the rights of the mother are being given greater consideration than the rights of the foetus. Abortions should therefore not be as accessible as they currently are and should only be permitted in limited situations. It is unclear what extent the interests of the foetus are actually being considered and it seems as though the right to life is being violated by the abortion process and so further protections may need to be provided to the foetus so that the rights of unborn children are given the same considerations as the mother. At present, it appears as though the rights of the mother prevail over the rights of the foetus, despite the restrictions that are in place. In order to ensure that the foetus right to life is being protected, it is necessary to impose further restrictions upon the mother’s ability to have an abortion. At present, a mother is capable of aborting a foetus for various reasons including the fact that the child will suffer from a disability. Many people do not agree that this should be a reason to end the life of a foetus, though it is legal in the UK for a woman to abort a baby on grounds of disability up to birth. As a result of this many parents opt for an abortion if pre-natal screening reveals that their baby is suffering from a disability. Moreover, it has also been suggested that the parents are even put under pressure to do so.†[12] The Society for the Protection of Unborn Children strongly disagrees with this approach and believes that; â€Å"a person with a disab ility has the right to life along with every other member of society: aborting a baby because he or she has, or even might have, a disability, is the ultimate form of discrimination.†[13] It cannot be said that the foetus’ right to life is being upheld as a result of this since they can be terminated at any point if they are found to have a disability. Not only does this undermined their right to life but it also discriminates against them on the grounds of their disability. As such, the provisions under the Disability Discrimination Act 1995 are too not being complied with. In Vo v France,[14] however, it was made clear that Article 2 of the Convention is â€Å"silent as to the temporal limitations of the right to life, and in particular does not define ‘everyone’ whose life is protected by the Convention.† Effectively, it is clear that because Article 2 does not provide a definition as to who shall be protected, it is likely that the rights of the foetus will continue to be restricted. Jackson does not believe that the moral status of the foetus should be sufficiently wide enough to make abortion unlawful,[15] however, and it seems as though the European Court of Justice is also reluctant as identified in Open Door and Dublin Well Woman v Ireland.[16] Furthermore, in the case of X v United Kingdom[17] the ECJ also stated that the right to life would be subject to an implied limitation in order to respect the mother’s life even if this was at the expense of the foetus’ right to life under Article 2. Furthermore, it was also expressed in Paton v United Kingdom[18] that; â€Å"the life of the foetus is intimately connected with, and cannot be regarded in isolation from, the life of the pregnant woman.† This limited the rights of the foetus even further as it was demo nstrated that the right to life under Article 2 was not available even though the abortion was not considered necessary to protect the life of the mother. This was also identified in H v Norway,[19] which illustrates that even if an abortion occurred as a result of the mother’s choice and there lacked any specific reason for terminating the pregnancy, Article 2 will still not be capable of providing protection to a foetus if this is at the expense of the mothers rights. This seems to indicate that unborn children are not actually provided with any rights despite the fact that Article 2 initially seemed to protect such interests. The termination of a pregnancy will continue to be a morally and ethically complex issue, particularly if the reason for aborting relates to a foetal abnormality.[20] It has been pointed out that a clear legal framework is needed because of the complexities that exist in this area, though it was noted that this continues to prove extremely difficult to create.[21] The Rights of the Mother Whilst it is believed by many that the rights of the foetus should be given due consideration, it is equally argued that the rights of women should be considered foremost when deciding whether an abortion is lawful or not. This was shown in Roe v Wade[22] where it was made clear by the Court that a person has a right to abortion unless the foetus has become viable. This means that the foetus does not become a human being until it is capable of living outside the mother’s womb without any artificial aid.[23] Although this decision was made by a Court in the US, it sparked a significant amount of debate. It was argued on the one hand that a foetus becomes a child whilst it is still in the womb and that the decision whether or not to allow abortion to take effect should not be based upon whether a foetus has the capacity to enjoy life as a person.[24] It has been said that the decision in this case effectively allows an abortion on demand to take place.[25] On the other hand, how ever, it has been expressed by Loveland that; â€Å"the judgment neither produced abortion on demand nor allowed states to prevent late-stage terminations.†[26] The decision in Planned Parenthood v Casey[27] imposed further limitations on the rights of the mother when it was found that the viability period would be reduced from 24 weeks to 22 weeks. It is questionable whether this was sufficient in ensuring that the right to life of the foetus under Article 2 was being provided with greater protection since the rights of the mother will continue to prevail in the majority of situations. It could be said that it is necessary for the mother’s rights to be ascertained over the rights of the unborn child because women should be regarded as individuals as opposed to being merely containers for the foetus. In accordance with this, greater consideration should be given to the rights of the mother, though some protections should also be available for the unborn.[28] Arguably, it is important that both the rights of the mother and the unborn child shall be considered, though much more weight ought to be given to the mother’s interests as she is already considered a viable person. It has been contended by Herring that; â€Å"women who want an abortion should not be required to continue with the pregnancy.†[29] Therefore, although Article 2 expressly states that the right to life is to apply to â€Å"everyone†, the extent to which this applies to the foetus is arguable in view of the confliction that exists between the rights of the mother and the rights of the foetus. In A-G’s Reference (No 3 of 119)[30] it was noted that a foetus is not regarded as a â€Å"person† and will therefore not be directly protected by Article 2 of the Convention. It was further added that the only right to life in which a foetus has is implicitly limited by the mother’s rights and interests. This suggests that a foetus will only be provided with the right to life indirectly from the mothers right under Article 2. It is unclear whether this completely undermines a foetus’ right to life, though it seems likely given that that Article 2 will not be violated if a pregnancy is terminated. The Courts have expressed great reluctance to elucidate on this matter, by assessing whether Article 2 will provide rights to the foetus or not, because of the existing moral and ethical considerations. As a result, great complexity continues to exist within this area of the law and unless Article 2 is more clearly defined, complexity will continue to ensue. Yet, because of the moral issues that are prevalent throughout, it seems as though a single approach would not be workable. Therefore, the decision as to whether an abortion should be permitted or not will continue to be decided on a case by case basis. As such, it will depend primarily upon the circumstances of each case. This allows a certain degree of flexibility to exist which is necessary given that each case will differ from the next. However, it is likely that the rights of the mother will continue to be favoured over the rights of the unborn child. Nevertheless, because of the politics that surround abortion, the European Court of Human Rights has been said to be â€Å"wary of making a general rule concerning the legal status of the foetus, preferring to leave this question to the margin of appreciation.†[31] It cannot be said that this is acceptable given the ambiguity that arises within this area. But because there is no right or wrong answer as to whether the rights of the mother should prevail over the rights of the foetus the legal status of the foetus could not be defined by the Courts without attracting opposition. It could be said that the UK has made some attempt to identify the rights of the foetus despite the fact that no right to life exists, yet the extent to which these interests are being protected will be likely to remain debated. When the case of Vo was brought before the ECHR they appeared to focus more on the question as to when life begins as well the nature and characteristics of the foetus, as opposed to focusing on the relationship between the mother and her potential child and the others right to reproductive freedom and autonomy.[32] Therefore, the approach taken by the ECHR should have been based upon the recognition of foetal interests as well as the loss of a mother’s relationship. Whilst this would not have addressed all of the difficulties that arise in this area, it would have provided some recognition as to the interests of the foetus. Much more needs to be done if foetal interests are to be provided with greater protected, whilst at the same time maintaining the rights of the mother. The rights of the mother appear to be protected in favour of the rights of the foetus, yet it has been said that this ensure the human dignity of the mother is being preserved.[33] This is because if a mother was not provided with the choice to terminate a pregnancy, it is likely that their human dignity would be violated. Whilst this this may be at the expense of the rights enshrined in Article 2, it is deemed necessary in protecting the mother’s interests. Balancing the Rights It is doubtful that the rights of the foetus and the rights of the mother are being balanced since the rights of the foetus continue to be undermined. Whilst there are some protections in place to preserve the interests of the foetus, these do not appear sufficient and so it seems as though tighter restrictions ought to be implemented to ensure that abortion is not easily accessible. This would allow for a more acceptable balance to be attained because at present it seems to be largely one-sided. If abortion was only permitted in extreme circumstances, it would not be capable of being used as another form of contraception and the interests of the foetus would be better recognised. On the contrary, it is argued that further limitations would limit the mothers freedom to choose and their own rights would be undermined if Article 2 was to provide express rights to unborn children. Therefore, whilst abortion should still be permitted, limitations should be imposed so that the rights of the foetus are given better protection. It is unclear whether judges should be left to make a decision on whether an abortion is lawful or not since opinions will differ significantly on this subject. Thus, it cannot be said that judges should be left to decide upon moral issues. Whilst one judge may agree with abortion, another judge may not as individuals have different perceptions on what is and what is not morally right. This is why the courts have been quite reluctant to use a single approach when deciding upon the interests of a foetus and it seems that the matter is better left undefined. This was identified by Sandel when it was argued that there are differences of opinions as to whether abortion is morally reprehensible and therefore worthy of prohibition, whilst many avoid passing judgment on the morality of these practices.[34] The ECHR appears to have adopted the latter approach, by failing to provide a decision on the legal status of foetus’. This lack of definition may actually be in the interests of the foetus since rights are capable of being provided that may not have been had a definition been in place. The determination as to whether abortion should be a mother’s choice or not will be capable of being assessed differently in all cases. This is necessary given the diverging opinions that exist since it will continue to be argued by many that Article 2 should provide a right to â€Å"anyone† including unborn children, whilst others will continue to be of the view that the decision should be left with the freedom of choice as protected u nder Article 13 of the Convention. The current practice that is being adopted in striking a balance between the two competing interests does appear to be the most plausible approach to take since each case will be determined by its facts. This could, however, lead to judicial activism occurring, which appears to have happened in the Roe case above which was described by Thielen as â€Å"an incredible reach of judicial activism.†[35] Judicial activism occurs when a ruling is said to be based upon political or personal considerations as opposed to being based upon existing law.[36] Therefore, if when Courts are provided with the ability to decide upon matters concerning abortion, judicial activism is likely to emerge which undermines social policy and, in some instances, human rights. Still, as put forward by Ewing and Gearty; â€Å"English judges have shown a powerful engagement with the rights of the unborn in the past,†[37] yet whether violations of one’s huma n rights are arising out of this is likely and it seems quite difficult for a balance to be achieved between the rights of the unborn with the rights of the mother. Conclusion This area is extremely controversial and because of this it is difficult for legislators as well as the judiciary to make a decision as to whether a foetus does have rights. Many people are of the view that every woman should have the right to choose whether or not to have an abortion, yet not all agree with this. Instead, it is argued that women are capable of using abortion as a form of contraception because of how easily accessible it is. Whilst there are some restraints in place to prevent this from happening, such as the requirement to obtain permission from two doctors, it cannot be said that such measures are effective. This is because it is highly unlikely that an abortion would be refused unless the stages of pregnancy have gone past the 24 week threshold. Furthermore, because women are permitted to have an abortion past this stage if the unborn child is suffering from a disability, the rights of the foetus are being undermined even further. It is therefore questionable whet her the current law is effective in preserving the interests of the foetus since the law has not made it difficult for abortions to be performed. Therefore, it could be said that further restrictions are needed so as to balance the rights of the mother with the rights of the unborn child. Conversely, because there is a limit on the number of weeks a person can abort a foetus, it could be said that their interests are being adequately protected to a certain degree. Whether this is sufficient, however, is likely to remain a contestable subject for many years to come as there will continue to be differing opinions as to whether abortion should be so easily available. In effect, there are both strengths and weaknesses for right to abortion, yet it is questionable whether the strengths do in fact outweigh the weaknesses. BIBLIOGRAPHY Cases: A-G’s Reference (No 3 of 119) [1998] AC 245 H v Norway (1992) 73 D R 155 Open Door and Dublin Well Woman v Ireland (1992) 14 EHRR 244 Paton v United Kingdom (1980) 3 EHRR 408 Planned Parenthood v Casey (1992) 404 U.S. 833 Roe v Wade (1973) 410 U.S. 113 Vo v France Judgement of 8 July 2004 40 EHRR 12 X v United Kingdom (1980) 19 D R 244 Legislation: Abortion Act 1967 Disability Discrimination Act 1995 European Convention of Human Rights 1951 Human Fertilisation and Embryology Act 1990 Human Rights Act 1998 Textbooks: Herring, J. Law Express: Medical Law (Revision Guide), Longman, 2nd Edition, (2009). Herring, J. Medical Law and Ethics, OUP Oxford, 3rd Edition, (2010). Hope, T., Savulescu, J. and Hendrick, J. Medical Ethics and Law: The Core Curriculum, Churchill Livingstone, 2nd Edition, (2008). Kaczor, C., The Ethics of Abortion: Women’s Rights, Human Life, and the Question of Justice, (Routledge: London, 2013). Kennedy, I., Grubb, A., Laing, J. and McHale, J. Principles of Medical Law, OUP Oxford, 3rd Edition, (2010). Jackson, E. Medical Law: Text, Cases and Materials (Text, Cases and Materials), OUP Oxford, 2nd Edition, (2009). Mason, K. and Laurie, G. Mason and McCall Smith’s Law and Medical Ethics, OUP Oxford, 8th Edition, (2010). Articles: Abortion Rights Campaign, Why women need a modern abortion, law and better services, Available [Online] at: http://www.abortionrights.org.uk/content/view/180/121/ BBC, Women’s Rights Arguments in Favour of Abortion, Ethics Guide, (1992), Available [Online] at: http://www.bbc.co.uk/ethics/abortion/mother/for_1.shtml K.D and Gearty. CA, Terminating Abortion RightsNew Law Journal, 142 NLJ 1969, Issue 6579, (04 December, 1992). C, Forty Years On, New Law Journal, 157 NLJ 1517, Issue 7295, (02 November, 2007). Frankenburg, G., ‘Human Rights and the Belief in a Just World’ International Journal of Constitutional Law, Volume 12, Issue 1. Holetzky, S. What is Judicial Activism(04 February, 2010), Available [Online] at: http://www.wisegeek.com/what-is-judicial-activism.htm Human Rights, Right to Life: Not just an abortion issue, Available [Online] at: http://www.abouthumanrights.co.uk/right-life-not-just-abortion-issue.html I, A Vacancy in the Supreme Court, New Law Journal, 144 NLJ 537, Issue 6644, (22 April, 1994). McCrudden, C. Human Dignity and Judicial Interpretation of Human Rights, European Journal of International Law, EJIL 2008 19 (655), Issue 4, (01 September, 2008). O’Donovan, K. Commentary, Medical Law Review, Med Law Rev 2006 14 (115), (01 March, 2006). Sandel, M. J. Symposium: Law, Community, and Moral Reasoning Moral Argument and Liberal Toleration: Abortion and Homosexuality, California Law Review, 77 Calif. L. Rev. 521, (May, 1989). The Society for the Protection of Unborn Children, SPUC, Abortion and disability or eugenic abortion, Available [Online] at: http://www.spuc.org.uk/students/abortion/disability Thielen, D. Overturn Roe v Wade, Liberal and Loving It, (2005), Available [Online] at: http://www.davidthielen.info/politics/2005/08/overturn_roe_vs.html Wicks, E., Wyldes, M. and Kilby, M. Late Termination of Pregnancy for Foetal Abnormality: Medical and Legal Perspectives, Medical Law Review, Med Law Rev 2004.12 (285), (01 September, 2004). Although the foetus has no right to life, its interests are adequately protected by English law. There is currently no direct right to life that is provided to a foetus, yet the law in the UK does make some attempt to protect its interests. This essay will focus on the interests that are provided to foetus’ in order to consider whether adequate protection is in place. In doing so, it will be examined whether every woman should have a right to abortion on demand or whether the interests of the foetus should be given due consideration. Accordingly, it will be shown that because there are arguments for and against the interests of the foetus, it is necessary for the law to strike a balance between the two competing interests. This does appear to have been achieved to a certain degree since the interests of the mother are being preserved, whilst also providing some protection to the foetus. The right to life The right to life is provided to all individuals under Article 2 of the European Convention of Human Rights (ECHR) 1951, as incorporated by the Human Rights Act (HRA) 1998. Whether or not a foetus has a right to life, however, is a highly contested topic because although the foetus does not have a right to life per se, it appears as though its interests are still being protected by the law to a certain extent.[1] On the one hand, it is believed that all women should have the right to do as they wish with their own bodies and that they should therefore have a right to abortion, yet on the other it is believed that the interests of a foetus should be provided with adequate protection.[2] The law in England does seem to have attempted to strike a balance between these two competing interests by permitting abortion, whilst at the same time imposing some restrictions. Under English law (Human Fertilisation and Embryology Act 1990) abortion is permitted until the 24th week of a pregnancy. Whilst this provides women with the right to choose what to do with their own bodies, it prevents them from having abortions in the later stages of pregnancy. Because abortion is not legally available at the request of the woman, it has been argued by the Abortion Rights Campaign that; â€Å"women’s access to abortion can be and is still threatened.†[3] This is because, once a woman has decided that she wants to have an abortion, she will first be required to persuade two doctors to agree to her decision taking into consideration certain restrictive legal criteria.[4] Therefore, even though women are capable of having an abortion up until the 24th week of pregnancy, it will be the doctors that make the final decision. And, if they do not agree that the relevant criterion has been satisfied, they will not have to carry out the abortion. This protection is in place to enable the rights of the unborn child to be ascertained in circumstances which would render an abortion unlawful. However, the extent to which such rights are being adequately protected is in fact arguable. Confliction continues to arise in this area because of the difficultly in striking a balance between the rights of the foetus and the rights of the mother. It cannot be said that this balance is currently being achieved as there remains strong opposition of both viewpoints. As pointed out by Mason and Laurie; â€Å"attitudes to abortion depend almost entirely on where the holder stands in respect of, on the one hand, the foetal interests in life and, on the other, a woman’s right to control her own body.†[5] Consequently, because the difference in opinions is based upon moral values rather than empirical facts, it is unlikely that such confliction will ever be resolved.[6] In effect, it is unlikely that a solid understanding of the rights in this area will ever be made as the controversy surrounding abortion will continue to exist. The Foetus’ Right to Life It is believed that the Abortion Act 1967 violates Article 2 of the Convention on the Rights of the Child on the basis that a child’s rights are not being adequately protected if women are able end their pregnancy if they so wish.[7] Section 1 of the 1967 Act provides that; â€Å"a person shall not be guilty of an offence under the law relating to abortion when a pregnancy is terminated by a registered medical practitioner.† In effect, women will not be found guilty of an offence is they decide to have an abortion. Whilst this section does appear to undermine the rights of the foetus, the fact that the termination must be conducted by a registered medical practitioner acting in good faith suggests that some form of protection will still be in place. Furthermore, as put by Herring; â€Å"for an abortion to be lawful, the abortion must comply with the requirements of the 1967 Abortion Act.†[8] Section 1 will therefore only apply if certain provisions can also be sa tisfied. Nevertheless, because abortions are rarely ever refused, it could be said that the provisions under Article 2 are being undermined and that the interests of the foetus are not, in reality, being adequately protected. In view of this, it has therefore been argued by Foster that the 1967 Act is not being used in the way that Parliament intended and that abortion are instead being used as another form of contraception.[9] This demonstrates how abortion is easily accessible to women, which limits the protection that is currently being provided to the foetus. It is likely that doctors will only refuse to conduct an abortion if the woman’s pregnancy has gone past the 24 week threshold or if the circumstances are exceptional. This signifies how the rights of unborn children are not being preserved, yet it is debatable whether further protections ought to be in place. The right to life is an extremely sensitive subject since it basically provides a right to every human being not be killed.[10] However, much complexity exists when considering the right to life in the context of unborn children. It is difficult to determine whether the mother’s rights should prevail over the rights of the unborn child or vice versa. However, it has been said that the right to life is a human right that is â€Å"inviolable and must be protected at all costs.†[11] If this statement was to be taken strictly, every abortion would be considered a violation of one’s human rights and would not be permitted. However, in order to ensure that the rights of the mother are also being protected it is necessary that abortions are permitted in certain circumstances. This would ensure that a balance is attained between the two competing interests by allowing abortions to take place only if it is deemed necessary. Consequently, abortions should not be used carelessly as another form of contraception and this would means that the rights of the mother are being given greater consideration than the rights of the foetus. Abortions should therefore not be as accessible as they currently are and should only be permitted in limited situations. It is unclear what extent the interests of the foetus are actually being considered and it seems as though the right to life is being violated by the abortion process and so further protections may need to be provided to the foetus so that the rights of unborn children are given the same considerations as the mother. At present, it appears as though the rights of the mother prevail over the rights of the foetus, despite the restrictions that are in place. In order to ensure that the foetus right to life is being protected, it is necessary to impose further restrictions upon the mother’s ability to have an abortion. At present, a mother is capable of aborting a foetus for various reasons including the fact that the child will suffer from a disability. Many people do not agree that this should be a reason to end the life of a foetus, though it is legal in the UK for a woman to abort a baby on grounds of disability up to birth. As a result of this many parents opt for an abortion if pre-natal screening reveals that their baby is suffering from a disability. Moreover, it has also been suggested that the parents are even put under pressure to do so.†[12] The Society for the Protection of Unborn Children strongly disagrees with this approach and believes that; â€Å"a person with a disab ility has the right to life along with every other member of society: aborting a baby because he or she has, or even might have, a disability, is the ultimate form of discrimination.†[13] It cannot be said that the foetus’ right to life is being upheld as a result of this since they can be terminated at any point if they are found to have a disability. Not only does this undermined their right to life but it also discriminates against them on the grounds of their disability. As such, the provisions under the Disability Discrimination Act 1995 are too not being complied with. In Vo v France,[14] however, it was made clear that Article 2 of the Convention is â€Å"silent as to the temporal limitations of the right to life, and in particular does not define ‘everyone’ whose life is protected by the Convention.† Effectively, it is clear that because Article 2 does not provide a definition as to who shall be protected, it is likely that the rights of the foetus will continue to be restricted. Jackson does not believe that the moral status of the foetus should be sufficiently wide enough to make abortion unlawful,[15] however, and it seems as though the European Court of Justice is also reluctant as identified in Open Door and Dublin Well Woman v Ireland.[16] Furthermore, in the case of X v United Kingdom[17] the ECJ also stated that the right to life would be subject to an implied limitation in order to respect the mother’s life even if this was at the expense of the foetus’ right to life under Article 2. Furthermore, it was also expressed in Paton v United Kingdom[18] that; â€Å"the life of the foetus is intimately connected with, and cannot be regarded in isolation from, the life of the pregnant woman.† This limited the rights of the foetus even further as it was demo nstrated that the right to life under Article 2 was not available even though the abortion was not considered necessary to protect the life of the mother. This was also identified in H v Norway,[19] which illustrates that even if an abortion occurred as a result of the mother’s choice and there lacked any specific reason for terminating the pregnancy, Article 2 will still not be capable of providing protection to a foetus if this is at the expense of the mothers rights. This seems to indicate that unborn children are not actually provided with any rights despite the fact that Article 2 initially seemed to protect such interests. The termination of a pregnancy will continue to be a morally and ethically complex issue, particularly if the reason for aborting relates to a foetal abnormality.[20] It has been pointed out that a clear legal framework is needed because of the complexities that exist in this area, though it was noted that this continues to prove extremely difficult to create.[21] The Rights of the Mother Whilst it is believed by many that the rights of the foetus should be given due consideration, it is equally argued that the rights of women should be considered foremost when deciding whether an abortion is lawful or not. This was shown in Roe v Wade[22] where it was made clear by the Court that a person has a right to abortion unless the foetus has become viable. This means that the foetus does not become a human being until it is capable of living outside the mother’s womb without any artificial aid.[23] Although this decision was made by a Court in the US, it sparked a significant amount of debate. It was argued on the one hand that a foetus becomes a child whilst it is still in the womb and that the decision whether or not to allow abortion to take effect should not be based upon whether a foetus has the capacity to enjoy life as a person.[24] It has been said that the decision in this case effectively allows an abortion on demand to take place.[25] On the other hand, how ever, it has been expressed by Loveland that; â€Å"the judgment neither produced abortion on demand nor allowed states to prevent late-stage terminations.†[26] The decision in Planned Parenthood v Casey[27] imposed further limitations on the rights of the mother when it was found that the viability period would be reduced from 24 weeks to 22 weeks. It is questionable whether this was sufficient in ensuring that the right to life of the foetus under Article 2 was being provided with greater protection since the rights of the mother will continue to prevail in the majority of situations. It could be said that it is necessary for the mother’s rights to be ascertained over the rights of the unborn child because women should be regarded as individuals as opposed to being merely containers for the foetus. In accordance with this, greater consideration should be given to the rights of the mother, though some protections should also be available for the unborn.[28] Arguably, it is important that both the rights of the mother and the unborn child shall be considered, though much more weight ought to be given to the mother’s interests as she is already considered a viable person. It has been contended by Herring that; â€Å"women who want an abortion should not be required to continue with the pregnancy.†[29] Therefore, although Article 2 expressly states that the right to life is to apply to â€Å"everyone†, the extent to which this applies to the foetus is arguable in view of the confliction that exists between the rights of the mother and the rights of the foetus. In A-G’s Reference (No 3 of 119)[30] it was noted that a foetus is not regarded as a â€Å"person† and will therefore not be directly protected by Article 2 of the Convention. It was further added that the only right to life in which a foetus has is implicitly limited by the mother’s rights and interests. This suggests that a foetus will only be provided with the right to life indirectly from the mothers right under Article 2. It is unclear whether this completely undermines a foetus’ right to life, though it seems likely given that that Article 2 will not be violated if a pregnancy is terminated. The Courts have expressed great reluctance to elucidate on this matter, by assessing whether Article 2 will provide rights to the foetus or not, because of the existing moral and ethical considerations. As a result, great complexity continues to exist within this area of the law and unless Article 2 is more clearly defined, complexity will continue to ensue. Yet, because of the moral issues that are prevalent throughout, it seems as though a single approach would not be workable. Therefore, the decision as to whether an abortion should be permitted or not will continue to be decided on a case by case basis. As such, it will depend primarily upon the circumstances of each case. This allows a certain degree of flexibility to exist which is necessary given that each case will differ from the next. However, it is likely that the rights of the mother will continue to be favoured over the rights of the unborn child. Nevertheless, because of the politics that surround abortion, the European Court of Human Rights has been said to be â€Å"wary of making a general rule concerning the legal status of the foetus, preferring to leave this question to the margin of appreciation.†[31] It cannot be said that this is acceptable given the ambiguity that arises within this area. But because there is no right or wrong answer as to whether the rights of the mother should prevail over the rights of the foetus the legal status of the foetus could not be defined by the Courts without attracting opposition. It could be said that the UK has made some attempt to identify the rights of the foetus despite the fact that no right to life exists, yet the extent to which these interests are being protected will be likely to remain debated. When the case of Vo was brought before the ECHR they appeared to focus more on the question as to when life begins as well the nature and characteristics of the foetus, as opposed to focusing on the relationship between the mother and her potential child and the others right to reproductive freedom and autonomy.[32] Therefore, the approach taken by the ECHR should have been based upon the recognition of foetal interests as well as the loss of a mother’s relationship. Whilst this would not have addressed all of the difficulties that arise in this area, it would have provided some recognition as to the interests of the foetus. Much more needs to be done if foetal interests are to be provided with greater protected, whilst at the same time maintaining the rights of the mother. The rights of the mother appear to be protected in favour of the rights of the foetus, yet it has been said that this ensure the human dignity of the mother is being preserved.[33] This is because if a mother was not provided with the choice to terminate a pregnancy, it is likely that their human dignity would be violated. Whilst this this may be at the expense of the rights enshrined in Article 2, it is deemed necessary in protecting the mother’s interests. Balancing the Rights It is doubtful that the rights of the foetus and the rights of the mother are being balanced since the rights of the foetus continue to be undermined. Whilst there are some protections in place to preserve the interests of the foetus, these do not appear sufficient and so it seems as though tighter restrictions ought to be implemented to ensure that abortion is not easily accessible. This would allow for a more acceptable balance to be attained because at present it seems to be largely one-sided. If abortion was only permitted in extreme circumstances, it would not be capable of being used as another form of contraception and the interests of the foetus would be better recognised. On the contrary, it is argued that further limitations would limit the mothers freedom to choose and their own rights would be undermined if Article 2 was to provide express rights to unborn children. Therefore, whilst abortion should still be permitted, limitations should be imposed so that the rights of the foetus are given better protection. It is unclear whether judges should be left to make a decision on whether an abortion is lawful or not since opinions will differ significantly on this subject. Thus, it cannot be said that judges should be left to decide upon moral issues. Whilst one judge may agree with abortion, another judge may not as individuals have different perceptions on what is and what is not morally right. This is why the courts have been quite reluctant to use a single approach when deciding upon the interests of a foetus and it seems that the matter is better left undefined. This was identified by Sandel when it was argued that there are differences of opinions as to whether abortion is morally reprehensible and therefore worthy of prohibition, whilst many avoid passing judgment on the morality of these practices.[34] The ECHR appears to have adopted the latter approach, by failing to provide a decision on the legal status of foetus’. This lack of definition may actually be in the interests of the foetus since rights are capable of being provided that may not have been had a definition been in place. The determination as to whether abortion should be a mother’s choice or not will be capable of being assessed differently in all cases. This is necessary given the diverging opinions that exist since it will continue to be argued by many that Article 2 should provide a right to â€Å"anyone† including unborn children, whilst others will continue to be of the view that the decision should be left with the freedom of choice as protected u nder Article 13 of the Convention. The current practice that is being adopted in striking a balance between the two competing interests does appear to be the most plausible approach to take since each case will be determined by its facts. This could, however, lead to judicial activism occurring, which appears to have happened in the Roe case above which was described by Thielen as â€Å"an incredible reach of judicial activism.†[35] Judicial activism occurs when a ruling is said to be based upon political or personal considerations as opposed to being based upon existing law.[36] Therefore, if when Courts are provided with the ability to decide upon matters concerning abortion, judicial activism is likely to emerge which undermines social policy and, in some instances, human rights. Still, as put forward by Ewing and Gearty; â€Å"English judges have shown a powerful engagement with the rights of the unborn in the past,†[37] yet whether violations of one’s huma n rights are arising out of this is likely and it seems quite difficult for a balance to be achieved between the rights of the unborn with the rights of the mother. Conclusion This area is extremely controversial and because of this it is difficult for legislators as well as the judiciary to make a decision as to whether a foetus does have rights. Many people are of the view that every woman should have the right to choose whether or not to have an abortion, yet not all agree with this. Instead, it is argued that women are capable of using abortion as a form of contraception because of how easily accessible it is. Whilst there are some restraints in place to prevent this from happening, such as the requirement to obtain permission from two doctors, it cannot be said that such measures are effective. This is because it is highly unlikely that an abortion would be refused unless the stages of pregnancy have gone past the 24 week threshold. Furthermore, because women are permitted to have an abortion past this stage if the unborn child is suffering from a disability, the rights of the foetus are being undermined even further. It is therefore questionable whet her the current law is effective in preserving the interests of the foetus since the law has not made it difficult for abortions to be performed. Therefore, it could be said that further restrictions are needed so as to balance the rights of the mother with the rights of the unborn child. Conversely, because there is a limit on the number of weeks a person can abort a foetus, it could be said that their interests are being adequately protected to a certain degree. Whether this is sufficient, however, is likely to remain a contestable subject for many years to come as there will continue to be differing opinions as to whether abortion should be so easily available. In effect, there are both strengths and weaknesses for right to abortion, yet it is questionable whether the strengths do in fact outweigh the weaknesses. BIBLIOGRAPHY Cases: A-G’s Reference (No 3 of 119) [1998] AC 245 H v Norway (1992) 73 D R 155 Open Door and Dublin Well Woman v Ireland (1992) 14 EHRR 244 Paton v United Kingdom (1980) 3 EHRR 408 Planned Parenthood v Casey (1992) 404 U.S. 833 Roe v Wade (1973) 410 U.S. 113 Vo v France Judgement of 8 July 2004 40 EHRR 12 X v United Kingdom (1980) 19 D R 244 Legislation: Abortion Act 1967 Disability Discrimination Act 1995 European Convention of Human Rights 1951 Human Fertilisation and Embryology Act 1990 Human Rights Act 1998 Textbooks: Herring, J. Law Express: Medical Law (Revision Guide), Longman, 2nd Edition, (2009). Herring, J. Medical Law and Ethics, OUP Oxford, 3rd Edition, (2010). Hope, T., Savulescu, J. and Hendrick, J. Medical Ethics and Law: The Core Curriculum, Churchill Livingstone, 2nd Edition, (2008). Kaczor, C., The Ethics of Abortion: Women’s Rights, Human Life, and the Question of Justice, (Routledge: London, 2013). Kennedy, I., Grubb, A., Laing, J. and McHale, J. Principles of Medical Law, OUP Oxford, 3rd Edition, (2010). Jackson, E. Medical Law: Text, Cases and Materials (Text, Cases and Materials), OUP Oxford, 2nd Edition, (2009). Mason, K. and Laurie, G. Mason and McCall Smith’s Law and Medical Ethics, OUP Oxford, 8th Edition, (2010). Articles: Abortion Rights Campaign, Why women need a modern abortion, law and better services, Available [Online] at: http://www.abortionrights.org.uk/content/view/180/121/ BBC, Women’s Rights Arguments in Favour of Abortion, Ethics Guide, (1992), Available [Online] at: http://www.bbc.co.uk/ethics/abortion/mother/for_1.shtml K.D and Gearty. CA, Terminating Abortion RightsNew Law Journal, 142 NLJ 1969, Issue 6579, (04 December, 1992). C, Forty Years On, New Law Journal, 157 NLJ 1517, Issue 7295, (02 November, 2007). Frankenburg, G., ‘Human Rights and the Belief in a Just World’ International Journal of Constitutional Law, Volume 12, Issue 1. Holetzky, S. What is Judicial Activism(04 February, 2010), Available [Online] at: http://www.wisegeek.com/what-is-judicial-activism.htm Human Rights, Right to Life: Not just an abortion issue, Available [Online] at: http://www.abouthumanrights.co.uk/right-life-not-just-abortion-issue.html I, A Vacancy in the Supreme Court, New Law Journal, 144 NLJ 537, Issue 6644, (22 April, 1994). McCrudden, C. Human Dignity and Judicial Interpretation of Human Rights, European Journal of International Law, EJIL 2008 19 (655), Issue 4, (01 September, 2008). O’Donovan, K. Commentary, Medical Law Review, Med Law Rev 2006 14 (115), (01 March, 2006). Sandel, M. J. Symposium: Law, Community, and Moral Reasoning Moral Argument and Liberal Toleration: Abortion and Homosexuality, California Law Review, 77 Calif. L. Rev. 521, (May, 1989). The Society for the Protection of Unborn Children, SPUC, Abortion and disability or eugenic abortion, Available [Online] at: http://www.spuc.org.uk/students/abortion/disability Thielen, D. Overturn Roe v Wade, Liberal and Loving It, (2005), Available [Online] at: http://www.davidthielen.info/politics/2005/08/overturn_roe_vs.html Wicks, E., Wyldes, M. and Kilby, M. Late Termination of Pregnancy for Foetal Abnormality: Medical and Legal Perspectives, Medical Law Review, Med Law Rev 2004.12 (285), (01 September, 2004).

Transformation of work Assignment Example | Topics and Well Written Essays - 1000 words

Transformation of work - Assignment Example Focus groups in both hotels were interviewed and, using the results of the survey, for each hotel there was made a conclusion concerning soft skill environment. Notwithstanding the awaited expectations, the results appeared to be completely different. All in all, the authors of the article agree that the traditional conception of â€Å"skill† has somehow changed and it is now associated not only with technical knowledge, but also with interpersonal communication abilities. They have brought a new notion and â€Å"strengthened the conceptual understanding of soft skills† (2013: 176) by showing how these skills perform in two cases. This is a considerable contribution to traditional sociology, service economy and even trade industry. The issue of skill nature is the subject of ongoing discussions in sociology of work in particular. This phenomenon was investigated and studied by a number of scientists. Traditional notion of skill was with the course of time complemented with additional shades, thus social or soft skills become recognized (Grugulis et al., 2004). They are treated in different ways. For instance, Bolton (2004) argues that emotion work can be skilled. According to her, soft skilled workers have enough scope for discretion and are able to deal with a variety of tasks. However, there is another point of view. Lloyd and Payne (2009) consider the idea of promoting soft skills inadequate and even dangerous. They argue that it is impossible to train the skills of social interaction, so soft skills cannot be regarded equal to technical ones. It is worthy of note that both aforementioned approaches have their drawbacks. The first, positive view has its exceptions. Being emotional or communicative is not enough for a work to be regarded as skilled. And on the other hand, the negative approach has its weak point. Technical skills which imply specific knowledge are simply

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Learning from the past - Essay Example Global warming seems to be one of the biggest threats to humanity in today’s world, because if we allow it to continue without taking any measures, the consequences can be catastrophic. Global Warming Global warming phenomenon has been around for a considerable period of time. Its history can be dated back to the 1880s. People in that period, had come to realize that burning fossil fuels such as coal, results in the emission of Carbon dioxide gas and other harmful gases, which can damage the earth’s atmosphere. The concept of greenhouse effect was initiated during that period; the greenhouse gases such as carbon dioxide when released into the earth’s atmosphere aid in the depletion of the ozone layer which can increase the earth’s temperature, thus causing major climatic changes. During the early 1900s, increase in the temperature of the earth was even recorded by the scientists and considerable thought was given to this phenomenon that was global warming. (Richard Courtney) The swift industrialization that started in the 1800s contributed a lot to the warming of the planet. It was the first time that people had started to burn fossil fuels in such large quantity to produce energy, which led to the emission of various harmful gases and waste into the atmosphere, and damaged the ozone layer surrounding the earth. This was the one major drawback of industrialization, which although had changed the situation around the world. Rapid deforestation and burning of coal and gases has led to the fast reduction in non-renewable sources of energy, as well as contributed greatly to global warming. During the start of industrialization, many people did not really understand the amount of damage that was being done to the atmosphere, until the scientists actually started to carry out tests and investigations, which showed them they are indeed endangering the planet with their activities. The concept was derived that the people were beginning to pu sh the earth’s resources to the maximum limit. Trees were, and still are, being cut down at a rapid rate to produce energy, and so were coal and other fossil fuels. Nature had been patient for some time with the continuous damage being done to the environment, but for some time now it has started to show signs of impatience. This had to happen because constant meddling with the earth’s natural cycle had to have negative consequences, which have resulted in global warming. This is basically a rise in the temperature of the earth, leading to climatic changes such as melting of ice caps in the northern regions. This can result in massive floods, plus the colder regions will get colder, while warmer regions will get warmer. The balance has been disturbed and it will be really difficult to put it back. Average temperature readings of the earth, taken every once in a while, have showed that the temperature of the earth is spiking; though at a small rate, it is still dangerou s. (How it began?) Though global warming has been on the go since the 1800s, measures have been taken continuously to reduce it, without being so harsh on the world’s economy. In 1987, an act was passed by Montreal Protocol of the Vienna Convention, which banned the releasing of the harmful gases into the atmosphere, which can damage the earth’

Judaism - Meaning of life Essay Example for Free

Judaism Meaning of life Essay The meaning of life is a philosophical question concerning the significance of life or existence in general. It can also be expressed in different forms, such as Why are we here? , What is life all about? , and What is the purpose of existence? It has been the subject of much philosophical, scientific, and theological speculation throughout history. There have been a large number of proposed answers to these questions from many different cultural and ideological backgrounds. The meaning of life is in the philosophical and religious conceptions of existence, social ties, consciousness, and happiness, and borders on many other issues, such as symbolic meaning, ontology, value, purpose, ethics, good and evil, free will, the existence of one or multiple Gods, conceptions of God, the soul, and the afterlife. Scientific contributions focus primarily on describing related empirical facts about the universe, exploring the context and parameters concerning the how of life. Science also studies and can provide recommendations for the pursuit of well-being and a related conception of morality. An alternative, humanistic approach poses the question What is the meaning of my life? The value of the question pertaining to the purpose of life may coincide with the achievement of ultimate reality, or a feeling of oneness, or even a feeling of sacredness. governs the universe. Closeness with the God of Israel is through study of His Torah, and adherence to its mitzvot (divine laws). In traditional Judaism, God established a special covenant with a people, the people of Israel, at Mount Sinai, giving the Jewish commandments. Torah comprises the written Pentateuch and the transcribed oral tradition, further developed through the generations. The Jewish people are intended as a kingdom of priests and a holy nation[69] and a light to the Nations, influencing the other peoples to keep their own religio-ethical Seven Laws of Noah. The messianic era is seen as the perfection of this dual path to God. Jewish observances involve ethical and ritual, affirmative and prohibative injunctions. Modern Jewish denominations differ over the nature, relevance and emphases of mitzvot. Jewish philosophy emphasises that God is not affected or benefited, but the individual and society benefit by drawing close to God. The rationalist Maimonides sees the ethical and ritual divine commandments as a necessary, but insufficient preparation for philosophical understanding of God, with its love and awe. [70] Among fundamental values in the Torah are pursuit of justice, compassion, peace, kindness, hard work, prosperity, humility, and education. [71][72] The world to come,[73] prepared in the present, elevates man to an everlasting connection with God. [74] Simeon the Righteous says, the world stands on three things: on Torah, on worship, and on acts of loving kindness. The prayer book relates, blessed is our God who created us for his honor and planted within us everlasting life. Of this context, the Talmud states, everything that God does is for the good, including suffering. The Jewish mystical Kabbalah gives complimentary esoteric meanings of life. As well as Judaism providing an immanent relationship with God (personal theism), in Kabbalah the spiritual and physical creation is a paradoxical manifestation of the immanent aspects of Gods Being (panentheism), related to the Shekhinah (Divine feminine). Jewish observance unites the sephirot (Divine attributes) on high, restoring harmony to creation. In Lurianic Kabbalah, the meaning of life is the messianic rectification of the shattered sparks of Gods persona, exiled in physical existence (the Kelipot shells), through the actions of Jewish observance. [75] Through this, in Hasidic Judaism the ultimate essential desire of God is the revelation of the Omnipresent Divine essence through materiality, achieved by man from within his limited physical realm, when the body will give life to the soul. Zoroastrianism Zoroastrianism is the religion and philosophy named after its prophet Zoroaster, which is believed to have influenced the beliefs of Judaism and its descendant religions. [77] Zoroastrians believe in a universe created by a transcendental God, Ahura Mazda, to whom all worship is ultimately directed. Ahura Mazdas creation is asha, truth and order, and it is in conflict with its antithesis, druj, falsehood and disorder. (See also Zoroastrian eschatology). Since humanity possesses free will, people must be responsible for their moral choices. By using free will, people must take an active role in the universal conflict, with good thoughts, good words and good deeds to ensure happiness and to keep chaos at bay.

Sexism in the Workplace :: GCSE Business Marketing Coursework Essays

Sexism in the Workplace Gender Roles Children learn from their parents and society the conception of "feminine" and "masculine." Much about these conceptions is not biological at all but cultural. The way we tend to think about men and women and their gender roles in society constitute the prevailing paradigm that influences out thinking. Riane Eisler points out that the prevailing paradigm makes it difficult for us to analyze properly the roles of men and women in prehistory "we have a cultural bias that we bring to the effort and that colors our decision-making processes." Sexism is the result of that bias imposed by our process of acculturation. Gender roles in Western societies have been changing rapidly in recent years, with the changes created both by evolutionary changes in society, including economic shifts which have altered the way people work and indeed which people work as more and more women enter the workforce, and by perhaps pressure brought to make changes because of the perception that the traditional social structure was inequitable. Gender relations are a part of the socialization process, the initiation given the young by society, teaching them certain values and creating in them certain behavior patterns acceptable to their social roles. These roles have been in a state of flux in American society in recent years, and men and women today can be seen as having expanded their roles in society, with women entering formerly male dominions and men finding new ways to relate to and function in the family unit. When I was growing up a woman was never heard of having a job other than a school teacher or seamstress. Our(women's)job was to take care of the house. We had a big garden out back from which we got most of our vegetables?A garden is a lot of work you know?We also had to make clothes when there were none to be had(hand-me- downs) Gender can be defined as a social identity consisting of the role a person is to play because of his or her sex. There is a diversity in male and female roles, making it impossible to define gender in terms of narrow male and female roles. Gender is culturally defined, with significant differences from culture to culture. These differences are studied by anthropologists to ascertain the range of behaviors that have developed to define gender and on the forces at work in the creation of these roles.

Should Animal Rights Activists Be Held Accountable for Abuse Videos? Essay

The animal rights discourse is one of the structural characteristics of modern rational pluralism as well as one of the ironically legitimate discourses of post-modern civilization. From a sympathetic understanding point of view, we should elucidate Tom Reagan’s strong point of view and Mary Anne Warren’s weak point of view regarding animal rights. It is in our nature to uncover the limits as well as legitimize the value appeals of animals and indicate that we can clarify our duties by taking the discussion of animal rights seriously. Therefore, indeed, animals have rights so along as they live, breath and walk among us. There is much debate as to whether non-human animals should be awarded rights and to what extent these rights reach. However, there is much less disagreement in accepting that indeed animals do have rights, as opposed to the opposite. The line between animal and human rights is not unclear like most simple minds tend to reason. A line is drawn and it includes factors that cannot be ignored at all. Simple minds do not understand that the very essence of animals living and breathing as well as walking among us is that we are just like them, only that we are more evolved. Quite strangely, sometimes in this life you will find individuals who are no better than the creatures they deny rights. Although the idea for animal rights dates back to the 18th century, it has only become something more or less of a cause caliber among several well-placed intellectuals and philosophers. Jeremy Bentham seems to have put animal rights on the legal map by requiring the humane treatment of animals. It is important to note that Jeremy in his arguments does not support animal rights per se. In the book â€Å"the case for animal rights† (UC press, 1983), the idea of animal rights is found to be intellectually congenial but the idea extends to placing animals close to humans in the evolutionary cycle. Times that are more recent have brought to light a different tradition, namely, the utilitarianism. The emergence of animal liberation emerged with a big bang. The concept is the same but the argument has been tweaked a little bit to cover the idea of animal rights in general. The scope does not propose animal domination, but rather the animals are well off in their lives. The essay will maintain that animals have rights and have a need to be liberated. We will argue that another point of view from this is a mistake. Philosophers have avoided arguing that not all non-human animals should have rights for two major reasons. The first is because the consequences of doing so are limiting for humanity. The second reason is that the granting of such rights to creatures so simple makes the idea of granting them such rights seem to lack sense. One such leading author restricts such rights to mentally healthy animals, which are then referred to as ‘adult animals’ (Pallota, 20). Therefore, the argument is presented in three simple facts. The first is that human beings have rights; the second fact is that there is no moral difference between humans and adult animals and the third one indicates that the adult animals should have rights, as well. The main argument for this is that both human beings and adult mammals are subject of life. This means that there are several factors that liken all mammals without putting one on a pedestal. The factors include; both are similar in terms of biological complexity, they are both aware of their existence. In addition, they know what’s happening to them, they prefer some things to others, they make conscious choices, they try to plan their lives, and finally that the length of their life matters to them. Just like human beings, being the subject of a life means that we are of inherent value. Inherent value is not measured in how useful we are in the world and as well, it does not diminish if they are a burden to others. Therefore, adult animals should be afforded rights just as humans. In this lifetime, we cannot all agree on the same thing no matter how irrefutable your facts are. In the case of animal rights, there are more than a few arguments put forward. Some of these reasons include said facts such as; they do not think they are not conscious; they were put on this earth to serve man. In addition, they have no souls, they do not behave morally, they are not members of a moral community, they lack the capacity of free judgment and finally, they do not think. For instance, St. Thomas Aquinas records that animals respond to instinct while humans engage in rational thought. This is oddly debatable because there are some humans who do not listen nor react to reason. An article in the New York Times dated 5th April 2012 states that providing animals with rights is c categorical mistake in the philosophy. It also states, â€Å"Eagerness to treat animals kindly does not justify imposing one’s hopes and dreams for them on humans† (Tibor, 12). Religion, on the other hand, teaches that it is only human beings with souls should deserve ethical considerations. Since non-human animals have no soul, then they are not entitled to having any moral rights. This argument is not useful because there are many controversies in the concept of a soul. It is not humanly possible to establish the existence of a soul in human beings or animals in a definitive experimental manner. In conclusion, it is only sane and morally right to remember that it is in the nature of man to uncover the limits and at the same time legitimize the value appeals of non- human animals. It is only morally right to take animal rights seriously so long as we walk breath and live on this earth with the animals. Animals deserve the decency of clean habitats, food, water and medication. It is their right as dictated by nature, long before man made up his own rules that seeks to make him superior to any other being on this planet. Animals used to roam the earth long before man became civilized and they had their own rules. Man and animal might have had a few run-ins, but we lived together. Unlike the simple minds who might think that we are referring to constitutional rights, animals deserve to live comfortably like nature intended for man and animal to co-exist. What matters is that we understand and treat the animals with humanity, after all, only humans can show humanity. As they say, we are all insane, what differentiates us is the level of insanity. In the same respect, we are all animals, what separates us is the level of evolution. References â€Å"Animal Rights Debate.† BBC News. BBC, n.d. Web. 30 Mar. 2014. . â€Å"Animals do not have Rights.† The NY Times. N.p., n.d. Web. 1 Apr. 2014. . Cody, Shyann. â€Å"Concern for the Animals.† Countryside & Small Stock Journal 1 Nov. 2012: 45-57. Print. â€Å"Should Animal Rights Activists Be Held Accountable for Abuse Videos?.† BEEF 26 Nov. 2013: 67-105. Print. Source document

Burger King and Its Advertising Campaigns Essay

Burger King is a reliable burger company which has had its ups and downs. In 1974, it came out with a slogan of â€Å"Have it your way† and at this time it also had a 4 % market share. Burger King’s idea was to have the customer have their burger done their way rather than a standard burger. In the early 80’s Burger King was trying to keep sales growing so they had to keep changing their advertising. In 1982 â€Å"Battle of the burgers† and â€Å"Aren’t you hungry for a Burger king now? † were the slogans used. In 1983 â€Å"Broiling vs. frying† and 1985 â€Å"The big switch†. All these ads throughout the years helped increase market shares from 7. 6% to 8. 3% from 1983 to 1985. â€Å"Search for herb† was a slogan used by BK about a person that has never tasted a whopper burger, this campaign was supposed to increase market share by 10% but in reality only increased it by 1% it was a disaster. In 1986-1987 â€Å"this is a burger king town† and â€Å"best food for fast times† brought a lot of attention to the company. In 1988 â€Å"We do it like you do it† was used often but a year later they came out with two new slogans which confused the customer. In 1989 â€Å"Sometimes you gotta break the rules† and â€Å"BK tee vee† with MTV and Dan Cortese with â€Å"I love this place†. This was another huge setback for BK because people on the go and parents found this ad loud and irritating. BK at this time has failed to establish a solid image that would differentiate it from its competitors. Ads if anything only confused consumers as to what advantages BK offered. In 1993 it had a market share of 6. 1% were McDonalds had 15. 6% and BK’s sales were growing slower than its rivals. Failed advertising campaigns weren’t the only problem’s, they also had internal problems. Management lacked focus and direction and has struggled with marketing mix decisions. Franchises became confused and angered, service was slow and food preparation wasn’t consistent. Burger King lost its core product- flame broiled burgers, made the way the customer wanted them. Another thing that hurt them was the fact they didn’t lower prices to keep competing with their competitors this led to a below average sales growth. Many in store promotion also failed. In 1993 a new CEO was introduced, this allowed for huge turnaround and in fact it did. He helped please the franchises and responded to their problems and listened to their recommendations. Then later he lowered prices and hired a new advertising agency. 1. In reading this case analysis I figured Burger King to advertise the Whopper, but throughout the past years they didn’t do this. I figure the whopper or the flame broiled ads would have been more productive and probably would have resulted in greater sales margin. I also feel that the ads should have distinguished themselves from what other ads by letting the people know that burger king wasn’t just another standardized burger. Throughout the years, BK tried to establish the market by becoming someone they weren’t. I feel the ads used by BK should have been simple and to the point. This would have caused less confusion and more honesty with the customer, this is because you don’t want to advertise a pizza or a taco if your selling burgers. Other objectives BK wanted was to target teens with the MTV approach. This also failed because people found it loud and annoying. Then they tried a sit in type of restaurant, which also failed because people want a fast food low price meal not a high priced, sit down meal. Advertising is any paid form of non personal presentation and promotion of ideas, goods or services by an identified sponsor. Advertising is a good way to inform and persuade the customer. Advertising objectives are based on past decisions about the target market, positioning and target mix. There are five steps to making a major advertising decision these steps are as follows: Objective setting, Budget decisions, Message decision or media decision, and campaign evaluation. Along with these steps BK should also remember to inform, persuade, and to remind. These three are a must that a company should aim at, for example: in informing BK used the ad â€Å"Broiling vs. frying† in 1983 letting the consumer know that their burgers were broiled and not fried. In persuading, I think BK over did it and that is why I feel that they didn’t retain market share. They tried to be someone they weren’t with slogans like â€Å"search for herb† in 85 and many others like â€Å"BK Tee Vee† trying to persuade the younger generation and â€Å"Sometimes you gotta break the rules†. These slogans and more tried to persuade the consumer. In reminding their customers BK has done a good job. They’ve at least expanded nationally and internationally and always have commercials everywhere with a juicy whopper on the screen, reminding the viewer that BK is the only place a whopper is made. 2. BK’s past advertising and corporate strategy failed because BK did the two biggest mistakes they could have done. First they didn’t listen to the customer and second they didn’t advertise their main product a maintain a target market. In not accomplishing any of these two strategies in the past it allowed their rivals to get a lead on them. In 1993 McDonalds, for example, had a market share of 15. 6 percent compared to BK’s 6. 1 percent. This is because they established their market and didn’t try to invent new strategies. Burger King started to lose market shares when it first came out with the search for herb, and then it declined again when it tried to target the teenage generation rather than staying loyal to the general customer. It tried targeting the younger generation through MTV. This became insulting and irritating to the old customers and to the quiet more relaxed people and even all the young children who prefer clowns than some man screaming on TV . BK did not listen to its customer, they tried to establish a restaurant type of business, rather than their fast food burgers. Fast food patrons really wanted low prices and quick but high quality food, not a higher priced, sit down meal. The corporate strategy and the past advertising wasn’t the only problem and wasn’t the only one at fault for BK’s failure. They also had internal problems. Management has had troubles with the market mix decisions. Service was slow and food preparation was inconsistent and many stores needed remodeling. BK didn’t focus on its burger ,instead they were trying to experiment with pizza’s and ice cream. This caused confusion ,and confusion brings problems. To add to the problems BK was more expensive than McDonalds or Wendy’s combos, which was also hurt sales for Burger King. 3. For the new advertising campaign I would personally target the young and the old generation. I would also be very health conscious and try to establish myself as an environment safe corporation. Burger King is huge, they have the ability to do what they please, but they better make sure the customer are happy. I would make new slogans, and put new ideas for kids and grown ups to enjoy. I remember when I was growing up I used to love going to Burger King for a burger and getting a little toy. Now, you get a toy but the prices are so high you really end up paying for it anyway. I wouldn’t leave out the teenage to mid- twenty’s crowd, but I feel they are less influence by ads and specials, they will buy what is probably better and cheaper. Besides if you target them when they are small growing up then when they already grow they look they like you anyway. That is why you have to target the young and make sure you are good to them. New slogans are hard to come by in specially into this society where you better watch what you say or you will get suit. I do not really believe in slogans, I personally rather buy quality than to hear how good it could be. For me seeing is believing and I do not believe everything I hear. 4. I recommend a couple of things for Burger King to do. One has already been accomplish, this was I would first change the CEO. In this case Jim Adamson stepped in July 1991, since then Burger King has made a turn around. He listened and responded to franchise problems and recommendations. He locked into a strategy of concentrating on BK’s core products flame broiled, bigger burgers. He launched a new pricing structure which will compete with that of McDonald’s. Burger King also needed to get some effective advertising, and I believe Mr. Adamson also accomplished this, seeing BK has grown since 1991. He went back to the basics which I think was the most important part of a Company’s rebuilding, because this how you got to where you are and if all else fails, it’s like starting again with experience. BK became known as â€Å"The voice of the people† opposed to McDonald’s been known as the voice of the Corporation. I also feel BK advertising has improved. Now you see burgers on TV compare to Dan Cortese a couple of years ago. You also see people having a good time and eating a whopper. I feel Burger King is a company with many obstacles but it is also a company that if is stuck to its basic game plan, it could regain a great deal of the market share. If I was to give a recommendation it would probably be for BK to stay been loyal to your customers and to try to keep the market share.

Italian Soccer Teams Have Colorful Nicknames

Italian Soccer Teams Have Colorful Nicknames If there are three things you can count on Italians to be passionate about it would be: their food, their family and their soccer (calcio). The pride of Italian’s for their favorite team  knows no bounds. You can find fans (tifosi) fearlessly cheering in all kinds of weather, against all kinds of rivals, and with a dedication that endures generations. Part of the fun of learning about soccer in Italy is also learning about the nicknames of the teams. But first, its important to understand how soccer works in Italy. Soccer is broken down into various clubs, or â€Å"serie.† The best is â€Å"Serie A† followed by â€Å"Serie B† and â€Å"Serie C† etc. Teams in each â€Å"serie† compete against each other. The best team in â€Å"Serie A† is regarded as the best team in italy. The competition in Serie A is fierce and if a team doesn’t win or do well in a season, they can be demoted to a lower â€Å"serie† much to the shame and disappointment of their adoring fans. Now that you understand the basics of how Italian teams are ranked, it is easier to understand their nicknames. Italian Soccer Team Nicknames Some of these nicknames seem random but they all have a story. For example, one of my favorites is the Mussi Volanti (Flying Donkeys- Chievo). They were given this nickname by their rival team, Verona, because the odds of Chievo entering the Serie A league was so slim (like the English expression to express unlikely odds, â€Å"When pigs fly!† In Italian, it’s â€Å"When donkey’s fly!†).    I Diavoli (The Devils- (Milan), are called as such because of their red and black jerseys. I Felsinei (Bologna- is based on the ancient city name, Felsina), and I Lagunari (Venezia- comes from the Stadio Pierluigi Penzo that sits adjacent to the lagoon). Many teams, in fact, have multiple nicknames. For instance, the illustrious Juventus team (a longstanding member and winner of Serie A) is also known as La Vecchia Signora (The Old Lady), La Fidanzata dItalia (The Girlfriend of Italy), Le Zebre (The Zebras), and [La] Signora Omicidi ([The] Lady Killer). The Old lady is a joke because Juventus means young, and lady was added by rivals who were essentially poking fun of the team. It got it’s â€Å"girlfriend of Italy† nickname due to a large amount of southern Italians who, lacking their own Serie A team, became attached to Juventus, the third oldest (and most winning) team in Italy. Besides these less obvious nicknames, one other colorful tradition, is to refer to the teams by the color of their soccer jerseys (le maglie calcio). The terms are frequently seen in print (Palermo, 100 Anni di Rosanero), as part of fan club names (Linea GialloRossa), and in official publications. Even the Italian national soccer team is known as Gli Azzurri because of their blue jerseys. Below is a list of the nicknames associated with the 2015 Serie A Italian soccer teams when referring to their jersey colors: AC Milan: RossoneriAtalanta: NerazzurriCagliari: RossobluCesena: Cavallucci MariniChievo Verona: GiallobluEmpoli: AzzurriFiorentina: ViolaGenoa: RossobluHellas Verona: GiallobluInternazionale: NerazzurriJuventus: BianconeriLazio: BiancocelestiNapoli: AzzurriPalermo: RosaneroParma: GiallobluRoma: GiallorossiSampdoria: BlucerchiatiSassuolo: NeroverdiTorino: il Toro, i GranataUdinese: Bianconeri