The causes and effects of torture in prison

The causes and effects of torture in prison Prison Torture explains the harmful consequences that prison torture can cause to the detainees and why it should be abolished. The first part of this paper discusses the common causes of prison torture in which the most known is obtaining confidential information from criminals. The second part of this paper reflects the physical consequences of the prisoner during the process of torture. The third part explains how the experience of being tortured can lead to post-traumatic psychological disorders and other issues. This traumatic disorder could eventually intervene in the individuals behavior towards the society. In brief, torture in prison may generate results that could be even worse than the crimes committed by prisoners and therefore it should be banned. Introduction There are deplorable insights on the realism of life within prisons in the United States and around the world. Sadistic actions and treatment that are almost similar happen in all prisons evoking a lot of debate from human rights activists among other concerned bodies on the magnitude of torture in prisons. Torture varies in different prisons but at the end of the day, the human rights of a prisoner are violated. Some corrective institutions release prisoners to fierce dogs and they are savaged for about half an hour or so, other torture methods include electrocuting with Cattle Prods which is very traumatizing, in some cases a prisoner is burned by highly toxic or corrosive chemicals, among other barbaric abuse. Looking in the societal context a prisoners are considered to have little powers as long as they are behind bars. This explains why a prisoner is the most vulnerable to torture. Although a prisoner finds himself or herself behind bars owing to wrongdoing or breaking laws of a given society they are viewed as isolated people; who deserves to be deprived their freedom or liberty hence they are well placed in prisons. A common cause of prison torture is in a case where a prisoner is abused to obtain confidential information from him, this is common in war crimes, terrorism, or crimes against the state for instance treason. In some States, a prison or a corrective institution may choose to use torture on culprits in case they want to curb serious crimes like illegal movements and cults, drugs networks etc. Criminals netted in relation to specific crimes are tortured to a point of confession. American criminal judicial system is extremely ineffective, expensive, and revoltingly merciless with a rich history with racism. Most city departments are famous for their notorious brutality hence there is a record of over 2 million people in corrective or federal facilities; while other 3.5 million are placed under other types of social control like community service. For this reason Americans reformists came up with modern prisons in support of anti torture policies; they argued that even hard-core criminals would reform by imprisonment alone, hard labor and contrition. Although slavery was not legitimized, captives were punished for crime (Jared Elizabeth, 2006). Following the Abu Ghraib military prisoner torture and abuse scandal in the year 2004, prison torture was redefined since so much was revealed through leaked video tapes (Jared Elizabeth, 2006). Therefore many independent observers and researchers went ahead to explore the activities of torture in various prisons around America. It was evident that most prisons used similar or closely related ways of torture. Study shows that the brutality prisoners are exposed to leave irreversible physical and psychological scars or even cause death. In cases where prison officials use toxic chemicals on prisoners, it is obvious severe physical disfigurations may occur due to burns and erosion of flesh by the harsh chemicals some victims burn to death. Some prisons deprive the torture victims medical attention even after inflicting wounds on them. Moreover some prisons avail medical care which either is too little or too late. Other institutions may choose to have dogs that are released to prisoners in an enclosure and they let them savage on the prisoner causing so much pain and even loss of limbs or other body parts. Ruthless beating and kicks may cause fractures and cuts, which may worsen if they go untreated at times, they rot and a prisoner ends up losing the fractured part of the body. Some officers are so radical that they may choose to amputate a prisoner without anesthesia. The most common method of torture in prisons around the world is the electrocution using cattle prod; this can cause severe brain damage. Sexual abuse takes place every day in almost every prison in the world this is a form of torture from prison officials or fellow prisoners who may be forced to engage in sodomy, homicide and other inhumane acts like rape (Gebhardt, 2004). There are episodes in life that cannot be erased from the mind of a human being; Thus Personal experiences can make or damage the life of a prisoner. In most prisons the criminals are tortured before their fellow inmates hence their counterparts may see a prisoner tortured to death, their lives are filled with fear and anxiety and it is likely to find them hallucinating or they are rendered in permanent shock. Psychological and Social consequences are very common in victims of prison torture psychological outcomes include conditions like Post-traumatic psychiatric where a victim may have experienced a brain injury or brain trauma. This is symbolized by changes in personality traits, disorientation, confusion and at times impaired memory (Dylan, 2006). A victim of prison torture may never be able to interact freely with the people around him or her. This due to various factors that affect them from low self esteem to dull emotional responses like sexual inappropriateness especially if sexually abused, paranoid, aggressiveness etc A person who has experienced prison torture may change or may not change their lifestyle of crime; this could be because of general outlook of life. Some tend to harden and even become hardcore criminals than they were before. They develop a tendency to hate on law enforcers and all they want is to associate with criminals and rebels. Their relationship even with family and friends deteriorates since they feel unwanted. Many a times they may have episodes of their lives in their mind and they may do weird things like screaming, nightmares, wailing, or even trying to fight back; so they prefer staying alone (Coltheart, 2009). Torture might be a method used to gain information and to punish prisoners for decades, but we have to consider the use of other procedures. Torturing should also be considered as a crime, because the torturers behavior of causing pain and simulating death is an unethical process used by criminals as well. Revisiting the infamous horrors of Nazi prisons, which was discovered after the World War II; it really enhanced awareness all over the world about the extensive use of torture to get information from prisoners (Zinger, 2006). Movements such as World Medical Association (WMA) emerged in 1947 following protests and mission to curb torture and other cruel penal approaches used on prisoners. According to (Burgers Mark, 1994) the United Nations further endorsed conventions against torture of prisoners that are in place until today. It defines torture as any act by which severe pain or suffering. This may be physical or mental and intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession. It is aimed at punishing him for an act he has or is suspected of having committed. It can also be aimed at intimidating or coercing him or a third person for any reason based on discrimination of some kind. when such pain or suffering is inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting in an official capacity. It does not include pain or suffering arising only from, or incidental to lawful sanctions (UN, 2007).Thus prison torture is illegal according to the international law.

lieshod White Lies in Joseph Conrads Heart of Darkness Essay

White Lies in Heart of Darkness      Ã‚  Ã‚  Ã‚   In his novella Heart of Darkness (1899), Joseph Conrad through his principal narrator, Marlow, reflects upon the evils of the human condition as he has experienced it in Africa and Europe. Seen from the perspective of Conrad's nameless, objective persona, the evils that Marlow encountered on the expedition to the "heart of darkness," Kurtz's Inner Station on the banks of the snake-like Congo River, fall into two categories: the petty misdemeanors and trivial lies that are common- place, and the greater evils -- the grotesque acts society attributes to madmen. That the first class of malefaction is connected to the second is illustrated in the downfall of the story's secondary protagonist, the tragically deluded and hubristic Mr. Kurtz. The European idealist, believing the lies of his Company and of the economic imperialism that supports it, is unprepared for the test of character that the Congo imposes, and succumbs to the potential for the diabolical latent within e very human consciousness. Although numerous critics (including Johanna M. Smith, Peter Hyland, Herbert Klein, and Garrett Stewart) have drawn attention to how Marlow's lie to the Intended informs the whole preceding text and how that culminating scene with the Intended is connected to Marlow's initial impression of Brussels as a whited sepulchre (how appropriate in light of Belgian King Leopold II's hypocritical defense of his private company's rapacious exploitation of the ludicrously- named Congo Free State!), few have until recently focussed on how the lie affects the reader's reaction to Marlow as the protagonist and narrator of Conrad's Congo tale. Answering questions which the dead man's Intended poses him reg... ... Rosmarin, Adena. "Darkening the Reader: Reader- Response Criticism and Heart of Darkness ." Joseph Conrad, Heart of Darkness: A Case Study in Contemporary Criticism , ed. Ross C. Murfin. New York: St. Martin's Press, 1989. Pp. 148-171. Smith, Johanna M. Smith. "'Too Beautiful Altogether': Patriarchal Ideology in Heart of Darkness ." Joseph Conrad, Heart of Darkness: A Case Study in Contemporary Criticism , ed. Ross C. Murfin. New York: St. Martin's Press, 1989. Pp. 179-198. Stewart, Garrett. "Lying as Dying in Heart of Darkness ." PMLA 95 (1980): 319- 331. Trilling, Lionel. " Huckleberry Finn ." The Liberal Imagination: Essays on Literature and Society . New York: Doubleday Anchor Books, 1950. Pp. 100-113. Wright, Walter F. "Ingress to The Heart of Darkness ." Romance and Tragedy in Joseph Conrad . New York: Russell and Russell, 1966. Pp. 143-160.

Media & Invasion of Privacy

LAGOS STATE UNIVERSITY SCHOOL OF COMMUNICATION A TERM PAPER SUBMITTED IN PARTIAL FULFILLMENT OF THE COURSE: ETHICS AND PROFESSIONAL PRACTISE (MAC 854) LECTURER: DR. JIMI KAYODE TITLE: MEDIA AND THE INVASION OF PRIVACY BY AKANDE ADEFEYISAYO ADEBOLARINWA †¢ SUBMITTED ON 30th JANUARY, 2010 INTRODUCTION Media practitioners possess the function of gathering, processing and disseminating news item to a heterogeneous large audience which often times not done with sound moral judgement in mind lands them into pool of troubled waters. Celebrities, politicians and other sought-after sources of news have over time expressed justifiable anguish over the diminishing aspects of their lives that are no longer free from prying eyes and publication from the press. They routinely assert that members of the media violates their privacy based strictly on their need to publish any news story that comes their way for the main purpose of profit and simply can not distinguish what type of information is private, public or newsworthy. Journalists, however, often possess diverse concepts of privacy and newsworthiness, and know that the issue is more complicated based on the fact that reporting news stories in a way that serves and informs the public will often require publicizing details or displaying images that will mortify or anger someone. To make privacy issues even more complicated for journalists, courts constantly redefine what is private based upon interpretations of the elusive legal standard of a â€Å"reasonable expectation of privacy. ( www. winning-newsmedia. com/privacy) â€Å"The U. S. Supreme Courts scolding of the media in the 1999 â€Å"ride along† cases for a perceived inattention to the privacy rights of the people featured in the news most likely reflects the current attitude of many judges and lawmakers and, thus, underscores the importance for journalists to be aware of general privacy principles. † (www. associatedcontent. com/topic) The intrusion and publication of private images can expose journalists to overwhelming financial liability if a court determines that a news organization has invaded a person’s privacy. The invasion of another’s privacy is a tort, meaning a civil wrong against another that results in injury. A privacy tort occurs when a person or entity breaches the duty to leave another person alone. When reporters intrude on a person’s privacy and cause emotional or monetary injury, they may be forced to pay damages. To avoid lawsuits, journalists must know how the law operates while seeking to balance the competing interests of the press and the public against the privacy interests of the subjects of the reports. Journalists often run contrary of this tort through the process of gathering information. Actions that may violate this privacy right include intrusion onto private property, concealed observation and the deceptive access into private areas. Conduct that invades privacy may also violate the criminal law. In general, courts have held that journalists must obey all relevant laws. In Cox Broadcasting Corp. v. Cohn, 420 U. S. 469 (1975) â€Å"the U. S. Supreme Court noted that in privacy tort, claims of privacy most directly confront the constitutional freedoms of speech and press†. www. definitions. uslegal. com) This study provides a universal explanation of each privacy tort and related causes of action. The privacy facts tort presents the unsettling circumstances in which journalists may be liable for monetary damages for coverage of news item. In several cases the Supreme Court has held that â€Å"where a newspaper publishes truthful information which it has lawfully obtaine d, punishment may lawfully be imposed, if at all, only when narrowly tailored to a state interest of the highest order. Florida Star v. B. J. F. , 491 U. S. 524, 541 (1989). Although the Supreme Court has prevented states from punishing journalists who published legally obtained names of juvenile offenders and rape victims, the Court has not absolutely rejected the private facts tort in this context. Although crimes such as rape are newsworthy and newsworthiness is a defence to a private facts suit, not all courts have agreed that the identity of a rape victim is newsworthy. Apart from news story either in the broadcast or in the print medium, photography has also been observed as posing some inimitable problems in privacy law, broadly, the legal analysis for invasion of privacy through images parallels the analysis for invasions through words. Essentially, the scope of this study is simply to analysis the fundamental nature of privacy laws, the various types that a mass media practitioner can run afoul of in the course of his or her duty and its implication for the society as a whole. Emergence of Privacy Laws: Concerns about intrusive newspaper reporting were mainly the beginning of the law of privacy. At that time, metropolitan daily newspapers used a variety of sensational information to attract potential readers. Media practitioners often played out the lives of the affluent and famous on the pages of their newspaper, permitting their readers to vicariously enjoy the wealth and the status of the celebrity. It was the kind of journalism now commonly referred to as â€Å"yellow journalism† that drove two Boston lawyers, Samuel D. Warren and Louis Brandeis to use the pages of the Harvard Law Review to recommend an officially documented right to privacy titled â€Å"The Right to Privacy† in 1890. Thus, their enterprise can be justifiably referred to as the source from which the law of privacy sprouted from. In their words as cited in Pember & Calvert, 2006: To satisfy a prurient taste the details of sexual relations are spread broad-cast in the columns of the daily papers. To occupy the indolent, column upon column is filled with idle gossip, which can only be procured by intrusion upon the domestic circle†¦Ã¢â‚¬ ¦.. The common law has always recognised a man’s house as his castle, impregnable, often, even to its own officers engaged in the execution of its commands. Shall the courts close the front entrance to constituted authority, and open wide the back door to idle or prurient curiosity? Warren and Brandeis strongly proposed that people should be able to go to courts to stop such unwarranted intrusions and also to secure monetary damages for the hardship or emotional distress they suffered from prying and from publication of private materials about them. The question of when the coverage and reporting of news became an invasion of privacy is a difficult one, especially for photographers and videographers. Consequently, the combination of a lack of clear definitions of privacy standards and an acceptance of degree of privacy puts media practitioners in a precarious position. In Sanders v. American Broadcasting Cos. , Inc. , 978 P. 2d 67 Cal. 1999, â€Å"the California Supreme Court held in 1999 that even an employee who holds a conversation in an open office space and overheard by co-workers can pursue an invasion of privacy claim if that conversation is recorded by a reporter’s hidden camera. The court rejected the notion of privacy as an â€Å"all-or-nothing† concept and described an â€Å"expectation of limited privacy† as follows: †¢ A subjective expectation of privacy is an opinion of a person that a certain place or situation is private. †¢ An objective, legitimate or reasonable expectation of privacy is an expectation of privacy recognized by society Under different circumstances, however, courts have established that news media are justified in doing what their subjects may feel is invasive. ( wikipedia: 2002) Definitions: According to the United Nations’ Universal Declaration of Human Rights Resolution 219A (III), Article 12 of 10 December 1948 as cited in Malemi (2002: 163): No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks. Privacy refers primarily to a person’s right to be left alone by the media, not necessarily a physical intrusion into one's private property or personal space. Invasion of privacy charges are usually presented in a civil lawsuit against media outlets that have crossed a perceived line into a celebrity or other public figure's private life, or have used his or her likeness or name in an unauthorized public manner Privacy law is the area of law concerned with the protection and preservation of the privacy rights of individuals. Increasingly, governments and other publics as well as private organizations collect vast amounts of personal information about individuals for a variety of purposes. The law of privacy regulates the type of information which may be collected and how the information may be used. The Right to Privacy: According to the 1999 Constitution of the Federal Republic of Nigeria, chapter IV, Section 37 on the right to private and family life says: â€Å"Citizens have right to privacy of themselves, their homes, correspondence, telephone and telegraphic communications. † A violation of this rights amounts to invasion of privacy. Remedies can then be pursued in the courts when anyone goes contrary to the above provisions. The right of privacy is a common-law cause of action that is a recent legal development. The U. S. Constitution contains no direct references to the right of privacy, although the Fourth Amendment states: â€Å"The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated†¦ † The right of privacy competes with the freedom of the press as well as the interest of the public in the free dissemination of news and information, and these permanent public interests must be considered when placing the necessary limitations upon the right of privacy. The First Amendment states: â€Å"Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech or of the press†¦ † â€Å"[pic][pic]Invasion of privacy, then is the intrusion into the personal life of another, without just cause, which can give the person whose privacy has been invaded a right to bring a lawsuit for damages against the person or entity that intruded. It encompasses workplace monitoring, Internet privacy, data collection, and other means of disseminating private information†. Photographers’ guide to Privacy, 2003). The wrongful intrusion into a person's private activities by other individuals, the media or by the government has generally been defined as invasion of privacy. Privacy is invaded when one intentionally intrudes, physically or otherwise, upon a person's solitude or into his private area or affairs. Invasion of privacy is considered a violation of to rt law and can be litigated inside the civil courts for monetary damages. Recently, invasion of privacy has taken on even greater meaning with recent technological advances. Bussian & Levine 2004 opine that: Whether an article or broadcast is newsworthy, whether the information was gathered in an objectionable fashion, whether truthful information is nonetheless highly offensive — all are considerations in weighing individuals' claims against the news media. Invasion of privacy is a tort, a civil wrong, which can lead to jury trials and potential claims for compensatory and punitive damages. It also places judges in the unfamiliar and uncomfortable role as â€Å"editors† of last resort. Celebrities are not protected in most situations, since they have voluntarily placed themselves already within the public eye, and their activities are considered newsworthy. Categorically, invasion of privacy or the intrusion into the personal life of another, without just cause, can give the person whose privacy has been invaded a right to bring a lawsuit for damages against the person or entity that intruded. Folarin, 2005:155 also agrees that the right to privacy is a legal means by which consumers can control media content through suits instituted against the media in defence of their right relating to invasion of privacy which includes insulation from needless publication of private matters. Also that people can sue any media that uses their names falsely. He asserts that the people who have little or no chance of winning most of the suits are acknowledged public figures who are generally assumed to have lost their to privacy by taking up public office or otherwise become public by being involved in a newsworthy act or incident. In distinguishing invasion of privacy among other claims facing the media, unusual situations involving crime victims and witnesses and also photographs of virtually anything visible in a public place do not give rise to actions for publication of private facts. Also facts that give rise to a false light claim may support a defamation claim while injury to reputation is not required for a false light claim. The false light tort aims primarily to protect against emotional distress rather than to protect one’s reputation. Based on First Amendment of the US constitution concerns, and the similarity between the claims, some states have not been persuaded to recognize the false light tort. However, public personalities are not protected in most situations, since they have placed themselves already within the public eye, and their activities (even personal and sometimes intimate) are considered newsworthy and are perceived to be of legitimate public interest. Dimensions of Invasion of Privacy: ) Intrusion on one's solitude or into one's private affairs includes: †¢ The Home: A person's home gets the highest protection from the courts. Entering a house or apartment without permission of the occupant or, in some circumstances, the police, can be considered as an unlawful intrusion. †¢ Photographs and Tape Recording: Taking photographs of a person or his property in a private place may be an invasion of privacy. Tape recording a person without his consent may also provoke damage awards. ) Public di sclosure of embarrassing private information such as: †¢ Personal Matters: Details about a private person's sexual relationships, the contents of personal letters, private facts about an individual, or other intensely personal matters are off-limits to the news media unless they are considered as absolutely newsworthy. †¢ Newsworthiness: Even truthful accounts are actionable if they contain highly offensive details which are not of legitimate concern to the public. ) Publicity which puts him/her in a false light to the public: †¢ Fabrication: Ascribing quotes or fictionalizing actual events can lead to invasion if a person is portrayed in a false light before the public. †¢ Photographs: Using photographs or films to illustrate a story that implies falsely that a person is involved in a disreputable incident. d) Appropriation of one's name or picture for personal or commercial advantage such as: †¢ Advertising: The unauthorized use of a person's name or photo graph in an advertisement is another immense subject in nvading people’s privacy. †¢ Property Rights: This happens when the press offers to give away unauthorized broadcasts or photographs of a performance. The Supreme Court in the United States has ruled that there is a limited constitutional right of privacy based on a number of provisions in the Bill of Rights and subsequent amendments. This includes a right to privacy from media surveillance into an area where a person has a â€Å"reasonable expectation of privacy† and also in matters relating to marriage, procreation, contraception, family relationships, child rearing and education. However, records held by third parties such as financial records or telephone call records are generally not protected unless a specific federal law applies. The court has also recognized a right of anonymity and the right of groups to not have to disclose their members' names to media agencies. (www. answers. com) Generally, it’s been considered that one ought to have a reasonable â€Å"expectation of privacy†, meaning: i. A place where a reasonable person would believe that he or she could disrobe in privacy, without being concerned that his or her undressing was being photographed or filmed by another; or ii. A place where one may reasonably expect to be safe from casual or hostile intrusion or surveillance. Given the similarity to voyeurism, an adjudicator might find that placing a hidden camera in a certain location may amount to the torts of indignation or deliberate infliction of emotional distress. Invasion of privacy laws are usually broken into four separate categories highlighted earlier including intrusion, appropriation, false light and public disclosure of embarrassing facts. Intrusion of Solitude: Intrusion of solitude, seclusion or into private affairs is an arm of invasion of privacy done by spying on or intruding upon another person where that person has the expectation of privacy. Places that a person ought to have an expectation of privacy are usually in a home or business setting. Consequently, people who have become public figures do not have the same expectation of privacy. A media practitioner, who intentionally intrudes, physically or otherwise, upon the solitude or seclusion of another or his private affairs or concerns, is subject to liability for invasion of privacy, if the intrusion would be highly offensive to a reasonable person. To be liable for intrusion upon seclusion or solitude, the plaintiff must prove the following elements: Invasion of a secluded place or privacy: this happens when the defendant is alleged to have invaded the plaintiff's personal or private space. This could be determined by: Physical intrusion into a place where the plaintiff has secluded himself. ) Use of the defendant's senses to eavesdrop or spy in order to oversee or overhear the plaintiff's private affairs or b) Some other form of investigation or examination into plaintiff's private concerns. Objectionable intrusion: this is the type of intrusion that would be highly offensive to the ordinary reasonable person. †¢ Invasion of private affairs or matters: the i nterference with the plaintiff's privacy must be substantial (however, if the event reported occurs in public, there is no expectation of privacy). Other examples of intrusion upon privacy include placing microphones or cameras in someone's bedroom or hacking into their computer. Society does not expect a journalist to place wiretaps on a private individual’s telephone without his or her consent. Opening someone's mail is also considered to be intrusion of solitude, seclusion or private affairs. The information gathered by this form of intrusion need not be published in order for an invasion of privacy claim to succeed. Trespass is closely related to the intrusion tort and may be claimed simultaneously. Intrusion claims against the media often centre on some aspect of the newsgathering process. This tort may involve the wrongful use of tape recorders, cameras or other intrusive equipment. Trespass also can be a form of intrusion. An actionable claim for intrusion may arise whether or not a news story is published or aired. (A photographer’s guide to privacy, 2003) Appropriation of Name, Likeness or Identity: The appropriation of a private person's name, likeness or identity by a person or company for commercial gain is prohibited under the invasion of privacy laws. However, this law pertains to a private figure and not a public figure or celebrities, who have fewer and different privacy rights. The Restatement (Second) of Torts Section 652C (1977) defines appropriation of name or likeness as follows: â€Å"One who appropriates to his own use or benefit the name or likeness of another is subject to liability to the other for invasion of his privacy. † (Bussian & Levine, 2004) Appropriation of name or likeness occurs when someone uses the name or likeness of another for their own advantage. Action for misappropriation of right of publicity protects against commercial loss caused by appropriation of an individual's personality for commercial exploitation. It gives the individual exclusive right to control the commercial value of his or her name and likeness to prevent others from exploiting that value without permission. It is similar to a trademark action with the person's likeness, rather than the trademark, being the subject of the protection. The appropriation category of invasion of privacy prevents others from using a person's name or identity for commercial gain. Ordinarily, the news media do not run afoul of this form of tort. However, seemingly harmless news coverage or advertisements can lead to lawsuits. This law came into existence from a couple of court decisions in the early 1900's where a private person's photograph was being used without consent for advertising purposes and without them receiving any monetary reward for using their pictures in print. The court recognized that the common law right to privacy including a person's identity had been violated by the unauthorized commercial use. In later cases, a person's voice was also included. Public figures, especially politicians do not have the same right to privacy as regards to appropriation of name, likeness or identity since there is much less expectation of privacy for public figures. Celebrities may sue for the appropriation of name, likeness or identity not on grounds of invasion of privacy, but rather on owning their own right to publicity and the monetary rewards (or damages) that come from using their likeness. False Light: As cited in Bussian , (2004) The Restatement (Second) of Torts Section 652E (1977) provides that: One who gives publicity to a matter concerning another that places the other before the public in a false light is subject to liability to the other for invasion of his privacy, if the false light in which the other was placed would be highly offensive to a reasonable person, and the actor had knowledge of or acted in reckless disregard as to the falsity of the publicized matter and the false light in which the other would be placed. Creating a false image for an individual may constitute an invasion of privacy. This is an aspect of invasion of privacy that deals with untruthful publication. In this instance, the offended person is placed in a false light through misleading descriptions, confusion of the person's identity with another, fictionalization of actual events, or photographs taken out of context. Its features are: It gives an individual unreasonable and highly objectionable publicity that attributes false characteristics, conduct or beliefs to him or her. The said material must be published to a third person or publicised to a large audience or to so many persons that the matter must be regarded as substantially certain to become one of public knowledge. The invasion of privacy tort of false light is upheld in court when the plaintiff can prove that the defendant publicize the plaintiff in such as way that it would be highly offensive to a reasonable person. However, it is pertinent to note that this tort shares many similarities with libel and many courts have trouble separating the two. Public Disclosure of Embarrassing Private Facts: Public disclosure of embarrassing private facts becomes an invasion of privacy tort when the disclosure is so despicable that it becomes a matter of public concern and it outrages the public sense of decency. In this invasion of privacy tort, the information may be truthful and yet still be considered an invasion if it is not newsworthy, if the event took place in private and there was no consent to reveal the information. The Restatement (Second) of Torts Section 652D (1977) provides that: One who gives ublicity to a matter concerning the private life of another is subject to liability to the other for invasion of his privacy, if the matter publicized is of a kind that (a) would be highly offensive to a reasonable person, and (b) is not of legitimate concern to the public. (ibid) The media can also be held accountable for damages for truthful publication. It is considered that the antisocial article or broadcast exposes to public view certain highly offensive matters that are not considered newsworthy. In order for an offended plaintiff to prevail, he must prove that the publication was: a) Extremely offensive to a reasonable person, b) And that the matters were not of legitimate concern to the public. The latter requirement may give the news media what might be called the newsworthiness defence. Though, the legal concern of the public in a matter is not presumed by the matter's publication. Thus, a plaintiff may prove that an article is lacking in newsworthiness despite its publication. Below is a good example: Case study: Publication of Embarrassing Private Facts Nollywood actress and 2005 Gulder Ultimate Search star, Anita Hogan, was reported to have lost a three-month-old pregnancy following the shock caused by the publication of her nude pictures in Daily Sun, an evening newspaper in 2006. Anita, according to her lawyer, was engaged to be married to a white man whose nude pictures were published along with hers in the Friday, August 11th edition of the newspaper. Police detectives in Lagos eventually arrested one Emeka Nwankwo, a computer engineer who allegedly circulated the shocking pictures to the media, after the actress rebuffed his alleged bid to blackmail and extort money from her over the lurid shots. The actress through her counsel explained that the computer where the controversial photos were saved developed a fault and had to be taken for repairs, from where they were allegedly stolen. The shots were said to have been taken by Anita’s fiance and stored on her personal computer. Emeka allegedly approached her to pay him N500, 000 or risk getting her pornographic pictures with the white man published in newspapers. The actress was said to have turned down the request, which she regarded as blackmail, and Emeka allegedly went ahead with his threat to circulate the pictures to media houses. A petition written by Anita’s lawyer, Mr Tony Dania of Dania and Associates, to the Deputy Commissioner of Police SCID, Lagos, actually admitted that the pictures in circulation were those of the actress but stressed that they were Anita’s private pictures with her fiance, stolen and doctored to suit the purpose of blackmail. The aforesaid publication is a criminal invasion of our client’s privacy. From the story the suspects published, it was obvious that there was blackmail and attempts to extort money from our client. They stole some of our clients’ pictures, used the computer to improvise and superimpose further images on them, called our clie nt and demanded for money. â€Å"The white man in the published pictures is a true resemblance of Anita’s fiance who works in a very decent organisation. In fact, they have done the pre-marriage formal introduction. Anita, who lost her dad recently, was actually carrying the baby of the white man, but the shock of the aforesaid inglorious publications made her to lose her pregnancy between Saturday/Sunday, August, 12, 13, 2006,† the petition alleged. CONSTITUTIONAL PROVISIONS Misappropriation: There are statutes that govern the right of publicity. These laws have two purposes: 1) To protect ordinary individuals from the mental anguish that may accompany the undesired commercial use of their name or image, and 2) To protect the property interest that celebrities develop in their identities. Under these laws the use of a relevant picture to illustrate a newsworthy article will generally not lead to liability. The unauthorized use of a celebrity’s picture in an advertisement often will. False Light: A photograph or videotape by itself will rarely place a subject in a false light. Rather, the accompanying text, caption, or voice-over could be misleading and portray the person in a false context. However, an accurate depiction of a person in a publication the person finds offensive does not, in itself, state a false light claim. Private Facts: The private facts tort presents unsettling scenario in which media practitioners may be iable for money damages for reporting the truth. In several cases the US Supreme Court has held that â€Å"where a newspaper publishes truthful information which it has lawfully obtained, punishment may lawfully be imposed, if at all, only when narrowly tailored to a state interest of the highest order. † Florida Star v. B. J. F. , 49 1 U. S. 524, 541 (1989) as cited in Bussian & Levine 2004. Although the Supreme Court has prevented states from punishing journalists who published legally obtained names of juvenile offenders and rape victims, the Court has not absolutely rejected the private facts tort in this context. Although crimes such as rape are newsworthy not all courts have agreed that the identity of a rape victim is newsworthy. Intrusion: Intrusion always comes into play through the process of gathering information. Here, the subsequent publication of the information is not required. Actions that may violate this privacy right include trespass onto private property, hidden surveillance, and the fraudulent entry into private areas. Conduct that invades privacy may also violate the criminal law. In general, courts have held that journalists must obey generally applicable laws. Trespass is the illegal entry onto private property. If the owner or person in charge of private property orders a photographer to leave, the photographer should leave or be prepared to face a trespass charge. Photographers who accompany police onto private property are not necessarily immune from liability. Camera operators should also be aware of federal and state laws that govern the taping of oral communications. The federal wiretap statute prohibits the interception of oral communications unless one party such as the journalist consents to the recording. And there have been instances where barring the taping of oral communications exist unless all parties consent to the taping. Privacy and the Internet: â€Å"The US Congress and its state legislatures across the nation have considered or are considering scores of bills aimed at reducing public concern about the ability of Internet users to protect their private lives as they surf the World Wide Web. † (Pember & Calvert, 2006). Despite the positive usage of the internet, the have been growing concern among users about the technology considering the ease with which third parties can collect data bout users and what the data collectors can do with the material they have gathered. However, the Nigerian Government have not woken from its slumber towards the direction of giving adequate protection to its citizens, properties and of course, rights. Defences available to Privacy Suits: Several defences are available to photographers and news organizations accused of invasion of privac y: Legitimate concern: defendant in a disclosure can challenge the plaintiff's proof of the basic elements of intrusion. For example, the defendant may be able to show that the facts that the defendant disclosed were matters of legitimate public concern. If a person is involved in a matter of legitimate public concern, a â€Å"newsworthy† event, the person becomes a public figure with respect to that event, regardless of the person's intentions or desires. If a person is a public official or public figure, his or her reasonable expectations of privacy are dramatically reduced. As a practical matter, a public official or public figure cannot successfully sue unless the invasion of privacy is outrageous or done with actual malice. Consent: it is a voluntary agreement to a publication or permission to enter a private place to gather information. It could be expressed or implied. Allis (2009) opines that a person who accepts money or other considerations in exchange for the invasion of privacy is said to have sold his or her â€Å"rights. † Though some defendants, such as prosecutors and government officials do have immunity if they are acting within the scope of their authority. Anything to be used in a commercial context, whether it is a photo taken in public or in private, must have consent, usually in the form of a model release. Consent must be obtained from someone who can validly give it. Consent to enter a home may not be consent to photograph it. Consent exceeded can be the same as no consent at all. Although oral consent may protect the press from liability for invasion of privacy, written consent is more likely to foreclose the possibility of a lawsuit. However, a subject’s subsequent withdrawal of consent does not bar the publication of the photograph. It simply means that the journalist may not assert consent as a defence if the subject later files suit. Cornwell (2008) sums it by saying â€Å"the more explicit the consent, the better the protection for the press. † Newsworthiness: Is generally defined as what the public is interested in. According to Wulfemeyer (2003), if a story that includes legally obtained private information that is embarrassing to the plaintiff but the subject matter is of public concern, it would be difficult for the plaintiff to win the law suit because courts give wide latitude to the newsworthiness defence. Photographs taken in public places generally are not actionable. Photographs of crimes, arrests and accidents usually are considered newsworthy and immune from privacy claims. Public places: if an event occurs in public view, they are almost always considered public and not private. Though public places defence have been considered not absolute. Public proceedings: Information obtained during public meetings, hearings or trials can be reported by a news organization. Public records: if information has been obtained from a document that is of a public record, it can not be deemed private. ETHICAL OBLIGATION Momoh (2004) opines that as a rule a journalist should respect the privacy of individuals and their families unless it affects public interest in the following ways: †¢ Information on the private life of an individual or his family should only be published if it impinges on public interest, †¢ Publishing of such information about an individual as mentioned above should be deemed justifiable only if it is directed at: 1. Exposing crime or serious misdemeanour; 2. Exposing anti – social conduct; 3. Protecting public health, morality and safety; 4. Preventing the public from being misled by some statement or action of the individual concerned. SUMMING UP The Right of Privacy is a good measure to check media practitioners on inappropriate media content so a news medium while carrying out its function must at all time be concerned with the welfare of its consumer. A media practitioner must ensure the accuracy of his or her information and must be ready to make corrections and clarifications when necessary after publishing or broadcasting untrue information. A media practitioner must at all time uphold the dignity of his or her profession comply with his or her professional codes and respect the human rights. A media expert must also recognise that gathering and reporting information may sometimes cause discomfort, so must seek ways to minimise the hurt. (Kayode, 2009). REFERENCES Allis. (2009). Invasion of Privacy—Appropriation. Retrieved September 19, 2009, from Lexis-Nexis database. Bussian & Levine. (2004). Invasion of Privacy: The Right â€Å"to be left alone† Retieved September 18, 2009, from Lexis-Nexis database. Cornwell, C. N. (2008). Freedom of the Press: Rights and liberties under the law. Retrieved September 18, 2009, from http://www. abc. clio. com Expectation of privacy (2002). Retrieved September 18, 2009, From http://www. wikipedia. com Folarin , B. (2005). Theories of Mass Communication: An Introductory Text. Abeokuta: Bakinfol Publication Invasion of Privacy (2003). Retrieved September 18, 2009, From http://www. winningnewsmedia. com/privacy Kayode, J. (2009). Ethics and professional practise [Record] . Lagos. Malemi, E. (2002). Mass Media Law: Cases and materials Lagos: Grace Publishing Incorporation Momoh, T . (2004). Nigerian Media Laws & Ethics Lagos : Efua Media Associates. Pember & Calvert. (2006). Mass Media Law Boston: McGraw Hill. Phtographers’ giude to Privacy (2003), Retrieved September 18, 2009, From http://www. rcfp. org Wulfemeyer, K. T. (2003). Radio & TV Newswriting: A workbook Retrieved September 19, 2009, from Lexis-Nexis database.

An Investigation of the Impact of the Financial Crisis on the UAE Real Estate Market The WritePass Journal

An Investigation of the Impact of the Financial Crisis on the UAE Real Estate Market Background An Investigation of the Impact of the Financial Crisis on the UAE Real Estate Market ). This statement is indeed true for the United Arab Emirates which over the last decade has recorded strong growth in its real estate market on one hand. And on the other hand has seen marked decline as a result of the global financial crisis which began in 2007. The crisis has caused significant decline to the real estate development and activities of the UAE economy prior to which the Emirates enjoyed an unprecedented real estate growth which was above any other in the Gulf Corporation Council (GCC region) (Kamco Research, 2010). In nominal term, research shows that the industry recorded a CAGR of 20% from the early 2000s to 2007 and as of 2007 the market showed a strong growth rate of over 21% with real estate constituting about 8% of the country’s total GDP estimated at over (15 billion USD) (Whatley, 2011). Given the country’s attractive position as a global tourist and investment destination, infrastructural growth and development of tourist sites and hotels as well as other entertainment and hospitability sectors has buoyed the real estate growth of the country. Indeed prior to the financial crisis, demands for properties were said to have significantly outweighed supply in both private and commercial real estate markets (Kuwait Finance House, 2011). Indeed, according to the Kuwait Finance House (2011), â€Å"there is still a shortage of units in the residential and commercial segments due to the unprecedented economic boom, high employment growth, foreign companies setting up base in the country, and huge inflow of expatriates†. The Kuwait Finance House further notes that the main factors underpinning the Emirates rapid real estate market growth are: Solid macroeconomic foundation, Public expenditure and huge fiscal surplus, Dollar-dirham peg and the record high inflati on rates given that stubbornly high rates of inflation in the country rationalises investment decisions into the real estate market since property is used as a hedge against inflation. It has been noted indeed that inflation has overtaken official lending rates in the Emirates thus it is cheaper for people to borrow than to keep money in deposit accounts, therefore real estate investment is considered as a realistic way of hedging against inflation (Albayan, 2009). In addition to the above stated factors, the Kuwait Finance House also suggests that part of the drivers of the Emirates real estate market are population growth, abundant liquidity and finally the availability of Islamic banking. The irony of the real estate market growth of the economy is that while most of the factors which gave rise its emergence has helped to hedge against the global financial crisis at the very start of the crisis, many of the factors also contributed to its decline. The financial crisis of 2007 did not start to unfold on the Emirates economy until the third quarter of 2008 but when its impacts downed on the economy, it put to test a growth that has been unprecedented in any region in the Middle East for the past 10 years (Albayan, 2009). According to Kamco Research (2011) at the heat of the financial crisis in 2009, the government asked the Dubai World which is its official real estate investment agency to stop all investment activities until March 2010 as a r esult of what it described as ‘terrible impact of the crises until when its impact might have subsided. Since 2009, the Dubai World has laid off over 10,500 construction staff with Dubai World’s debt standing at over $59 billion. As of 2009, the emirates debt was put at $80 billion. While at first quarter of 2009, the Abu Dhabi investment agency offered to help Dubai amidst its real estate market collapse, Abu Dhabi also felt the impact of the crisis as a result of the global crisis. As of the first quarter of 2009, the real estate market plunged by almost 70% of the pre-crisis value and of the 980 ongoing real estate projects in Dubai, only 47 were completed in 2009 with about 500  registered with the Real Estate Regulatory Agency (Rera) cancelled. Since most investment into the emirate’s real estate market were from investors abroad with over 70% investment being FDI, the crisis which started from the United States and Europe unleashed   its impact on the emirates as investors could not get funds from their western financiers and the rate of financial liquidity which initially increased the crisis reduced in the economy. Albayan (2009) also notes that most of the factors which led to the demands of real estate in the emirates were stunted. For instance he notes that the demand for tourism declined significantly thus affecting hotels rate of occupancy. This also led to the impact of the crisis felt in ongoing developments. While several accounts have been put forward to rationalise the real estate market decline in relation to the financial crisis, knowledge about the country’s real market decline amidst the crisis is still skewed. Besides, as the market is still struggling to come back to the pre-crisis period, there are concerns that if the real causes to the decline are not identified, there will be difficulty in moving forward and achieving the needed growth. In view of this background, the proposed dissertation will critically explore the impact of the financial crisis on the real estate market. The dissertation is concerned with identifying and examining the main causal factors responsible for transmitting the impact of the crisis on the real estate market and the varying strategies that have been employed to mitigate future impacts. The following are the specific aims and objectives of the dissertation. Research Objectives: Investigate the similarities or differences between UAE real estate markets, and those in the UK. Ascertain the reasons why the global financial crisis could have had an impact on the UAE real estate, especially given differences in banking principles. Ascertain the role of Islamic banking in mitigating the impact of the financial crises. Investigate the direct and indirect impacts that the financial crisis had on the UAE real estate market, and its subsequent impact on the UAE economy. 1.3 Research Question How has the financial crisis impacted upon the UAE real estate market? 2.0 Literature Review   The 2007 global economic and financial Crisis which started from the US subprime mortgage crisis has affected virtually all the countries around the world given the interconnectedness of the global economy. The crisis which led to the collapse of several well known institutions such as Lehman Brothers also led to the bailout of financial institutions, and the near collapse of many governments as well as downturns in stocks markets around the world (Bob, 2012). As a result of the crisis, there have been credit default problems, negative interest rate movements, inflation rate fluctuation and several distortions in the financial agreement of many financial obligations and agreements. As the credit crisis led to the collapse of financial institutions, it became problematic for investors to expend more on their business commitments and financial obligations as borrowing became squeezed as the liquidity ratios of many banks almost diminished (TIME Magazine  Friday, April 10, 2009). While the crisis has unleashed its impact on every economy and the Emirate’s economy in particular on one hand through its heavy financial implication, it has on the other hand had huge impact on other Emirate’s industries. As noted by Kamco Research (2011), the financial crisis started to affect the UAE through the decline of tourists and tourism activities which further led to decreased demand for housing and real estate as well as hospitality and h otels in particular. Kamco Research notes that since investors income started to nosedive as a result of low hotel occupancy and diminishing tourism activities which once fuelled the real estate market, this led to falling profits and investors started to abort new projects. As noted by Wam (2010), when the crisis started in UAE in late 2008, over 150 real estate investment projects were called off by investors who had started to fall into trouble with their financial institutions regarding their financial agreements. The Citibank notes that: â€Å"real estate projects worth 170 billion USD have been cancelled since the financial crisis explosion with rents seeing a decline of over four fifths since 2008. Also, Al Futtaim a Real Estate group in Dubai during the financial crisis stopped work on the Dubai Festival City which was billed to cost almost 3 billion USD. Similarly, major projects were stalled such as hotel and other developments were stalled. For instance, Four Seasons Ho tel and the Al Badia Business Centre which are major real estate development projects were stopped. According to the Executive Magazine, the company has taken this step in order to benefit from a further fall in construction costs due to the financial crisis, which would enable it to reduce its expenses. At the same time, the UAE government which has enjoyed almost a decade of surplus fiscal regime had started to feel the impact of the crisis as the government debt has quickly risen to over $30 billion as of early 2008. The government’s bad fiscal position led it to order the Dubai Corporation to stop all real estate market activities while the heat of the crisis subsides. While the Kuwait Finance House had in 2008 earlier predicted that the UAE will not feel the global credit squeeze due to private consumption growth that is likely to remain strong as well as the population growth of expatriates in the country who boosted consumer confidence. The financial crisis at its peak contrarily affected the growth of private consumption in a lot of ways. According to Mintel Research (2010), â€Å"since private institutions were unable to obtain credits from banks to sustain different projects and demands for almost entirely all services declined, private consumption growth was affect ed to much that it took the UAE back to a pre-20 year period when it could the country could not be found on the face of the earth†. Following the crisis, the government has taken several steps to mitigate the impact of the crisis (Global Property Guide, 2011). The central bank has for instance begun to overhaul the banking system by raising bank’s liquidity ratio in order to encourage banks to give credit while the capital base has also increased (Hatoum, 2012). As a result of the steps taken by the central bank and other government agencies, the UAE reality market has began to emerge out of the crisis. Dubai’s residential real estate market is finally recovering after hitting bottom, while neighbouring Abu Dhabi continues to struggle. A property index published by Zawya Dow Jones (2012) shows that the home prices in Dubai saw a rise of almost 7.6 percent for the year at the start of 2012, but prices in Abu Dhabi dropped 4.1% in the same time period. 3.0 Methodology The methodology is an important element of the research process which shows the design elements of the research particularly with regard to data collection and the adopted techniques as well as their justification. Accordingly, this section of the proposal sets out the proposed methodology of the dissertation. The current literature shows the existence of two approaches to research: namely the deductive and inductive methods (Saunders et al, 2003). While the deductive approach is leaned towards a scientific evaluation or understanding of data as well as the relationship between variables, the inductive approach owes much to gaining an understanding of the meanings humans attach to events as well as the research context (Saunders et al, 2003). The merits of both approaches have been considered useful for the proposed dissertation; hence both the deductive and inductive research will be employed. The inductive approach will employed in specific in order to be able to understand the bro ad experiences, causes, problems and important factors which underlined the global financial crisis and how it affected the real estate market of the Emirates. As the approach which helps to understand events and how they occurred, it is expected the deductive approach will offer insight into other broad issues regarding the financial crisis and its broad effects on the UAE reality and other markets. The inductive approach on the other hand will be employed based on the need to critically analyse the major effects of the crisis, the approach will also help to gain knowledge into numbers and figures which are key to understanding the real nature and effects of the crisis. The approach is also highly favoured due to what Hussey and Hussey (1997) describe as some of the characteristics of the deductive research approach which fits well into the objectives of the proposed dissertation. This includes: The use of statistical methods in testing samples The uses a highly structured methodology in order to enhance reproducibility of the results An exploration of relationships between complex variables Concerning the strategy suitable for the dissertation, the exploratory research methods have been considered useful given that it is the one used explore phenomena that are yet to be studied or to further explore areas that have received few investigations as is the proposed dissertation. As noted by Silverman (1993), exploratory research seeks to understand a particular phenomenon as well as to gain new insights and perspectives on the phenomenon under investigation. Saunders et al (2003) note an advantage of exploratory research as being its flexibility and adaptability permitting the researcher to easily take on any direction that the data may dictate in the course of gathering the data. Data Collection Given the complexity of primary data collection such as access to the needed respondents, resources and time which the research lacks altogether, it would be impossible to use primary data collection as the main source of data gathering for the proposed dissertation. Hence, secondary data will be used in a way that would allow the researcher to analyse the UAE real estate market and the impact of the crisis. Secondary data will be mainly collected from the Newspapers and UAE authorities such as the Dubai World and the Abu Dhabi Investment authority. The option of data gathering would be employed because the country lacks an organised data gathering system with anyone unique database regarding the property market unidentifiable (See: Ameinfo.com November 24, 2009). With regard to data, the real estate market would be examined in specific and about 20 real estate projects will be critically analysed. The analysis will be based upon how the financial crisis affected the various real estate development projects and the extent of the impact. The dissertation will be a longitudinal study and will focus on the crisis period between 2007 and 2010 when the heat of the crisis were most severe.    Activities July Aug Sep Oct Nov Dec Start the thesis +++++ Complete Chapters 1 2 +++++ Data collection begins +++++ Start with Methodology +++++ Begin to analyse data +++++ Check analysis for consistency +++++ Get supervisor’s approval +++++ Start with the final chapter +++++ Get the dissertation edited and checked +++++ Get supervisor’s final approval +++++ Correct mistakes +++++ TIMESCALE: GANTT CHART References Albayan, M. (2009). The Global Financial Crisis and the GCC region, Research Series Ameinfo.com (November 24 – 2009). Lack of data hampers Dubai property market forecasts, Available at: ameinfo.com/217619.html Bob, I. (September 24, 2008).  (quoting Joshua Rosner as stating Its not a liquidity problem, its a valuation problem. Bloomberg, Retrieved June 6, 2012 Executive Magazine (Jun 11, 2012). UAE Construction hits the wall, Available at: executive-magazine.com/getarticle.php?article=11520, Accessed: 13th June, 2012. Global Economic Research (March, 2012). Global Real Estate Trends, available at: gbm.scotiabank.com/English/bns_econ/retrends.pdf Hussey, J. and Hussey, R. (1997) Business Research: A Practical Guide for Undergraduate and Postgraduate Students, Basingstoke: Macmillan Business. Silverman D (1993). Interpreting Qualitative Data: Methods for Analyzing Talks, Text  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   and Interaction, London: Sage. Saunders M, Lewis P and Thornhill A (2003). Research Methods for Business  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Studies, 4th edn, Harlow: Pearson Education Kuwait Finance House (2011). UAE Real Estate Sector Research: KFH Research Ltd. Available at: liquidityhouse.com/upload/UAE_Real_Estate_-_12_Sep_08_1443.pdf Kamco Research (2010). United Arab Emirates (UAE) Economic Brief and Outlook, menafn.com/updates/research_center/UAE/Economic/kamco130411.pdf. TIME Magazine  Friday, (April 10, 2009). The financial crisis and the Dubai reality.    Whatley, S. (2011). The Impact of the Financial Crisis on Dubai’s Property Market, available at:trcb.com/real-estate/real-estate/the-impact-of-the-financial-crisis-on-dubais-property-market-22671.htm Wam, N. (Aug 2, 2011).  Why a Weaker Dollar Could Help the U.S,  Time. Retrieved , June 9th, 2012.

Essay The Grammar of Nebrijia

Essay The Grammar of Nebrijia Essay The Grammar of Nebrijia The Grammar of Nebrija was a book written Antonio de Nebrija and was published in the year of 1492. Antonio de Nebrija was a Spanish scholar, historian, teacher, and poet well known for writing this book which for the idea of learning Spanish and the breakdown of the language with thought being given to the breakdown of the language along the lines of phonetics, verb conjugation, etc. Spanish is known as Castilian because the language originated in Castile a region in Spain; Spanish also has basis in Latin with some the words and phrases of the language being similar to that of French and other languages based out of Latin. The Grammar of Nebrija is often credited as one of the first published grammars of a Romance language, and it set the standard for subsequent colonial grammars. It was the first book of their kind to written for European language and also for Spanish. The book also included rules for the Spanish language including grammar and also included verbal conjugation for readers of that present era to gain an understanding of the Spanish language. The book was divided further into books which included orthography which is the method of spelling and having to do with the Spanish alphabet; prosody which is the rhythm and the intonation of the speech which is intended to help the speaker pronounce and speak Spanish how it is intended. The book also included Etymology which is the study of the basis of the word or how the word came to be; diction which is how the words in Spanish are intended to pronounced and syntax which is the study of the rules for the formation of grammatical sentences in a language. Antonio de Nebrija wrote The Grammar of Nebrijia in 1492 which was around the time Columbus decided to sail to across the Indian Ocean to discover a shorter path to India; this book was mostly helpful for Columbus. Since he landed in what he thought was India, he discovered natives and Spanish was introduced; the de facto decision became to teach the natives Spanish and strip of their native tongue which would allow Spanish to be the primary language spoken. Antonio de Nebrija’s intention for writing and publishing The Grammar of Nebrija was so that people who didn’t and couldn’t understand Spanish would be able to learn and understand Spanish. His book set the groundwork for many of today’s books and language learning programs that assist people in learning a new language for example the Rosetta Stone which is a technology based computer program that assists people in learning a brand new language without the difficulty of tapes and books. Antonio de Nebrija believed that language and grammar should be embraced and not viewed upon as being hard and ugly. He felt that learning Spanish would have the Spanish Empire move ahead and conquer more territory than that of the English. This was very prophetic considering since The Grammar of Nebrijia was subsequently published the same year Columbus ventured out on the Santa Maria along with three other ships and his men on a quest to seek a new and better path to India than the long and arduous one that Columbus had been taking beforehand. "Language has always been the perfect instrument of empire." Antonio de Nebrija stated this in the Granidtica Castellana. The vision of Antonio de Nebrija, Bishop of Avila, as stated in the prologue of the Castilian Grammar he published in 1492, was one that was to prove prophetic in the following years, as the Spanish Empire extended its reign across the Atlantic. It was prophetic, in that throughout the conquest of the Americas, and the centuries of colonialism, language was used by the Spanish as a tool for conquest: to consolidate political power, to spread the Catholic faith, and to unify the empire. The language policies in the colonial period, however, were not always aimed at spreading the Spanish language. In some situations, Spanish was used as a medium for control, whereas in others, Spaniards employed the Native

Trends In HR Technology Essay Example | Topics and Well Written Essays - 2500 words

Trends In HR Technology - Essay Example The benefits to the organization from efficiencies realized when employees change their own HRIS data and â€Å"serve themselves,† to more informed, effective decision making by managers support a transformation of HR’s role within the organization. The role will change from an essentially administrative function to a strategic business partnering function where HR personnel contribute to bottom-line results. HR self-service eliminates the non value- adding administrative tasks that can be handled automatically by the system. HR self-service are somewhat different for employees than for their managers. In all cases, however, the time, cost, and quality improvements enabled by a self-service HR adds value to the organization. Not only are HR department and HRIS administrative expenses sharply reduced, but employees and managers using a well designed self-service system spend â€Å"less time doing more† for themselves, their colleagues and the business.

Dell development Essay Example | Topics and Well Written Essays - 1000 words

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