Essay writing websites
Friday, August 28, 2020
Movie Review Fight Club
Film depiction An adjustment of a novel of a similar name wrote by Chuck Palahniuk in 1996, the American film ââ¬Å"Fight Clubâ⬠was discharged three years after the fact in 1999. This interestingly odd storyline was enlivened on the big screen by executive David Fincher and some of Hollywoodââ¬â¢s most significant on-screen characters; Brad Pitt, Edward Norton and Helena Bonham Carter. The movies disillusionment caused a stir of pundits as ââ¬Å"Fight Clubâ⬠turned into the most questionably discussed films. As per scholarly pundits, the 1999 film depicts occasions of industrialism and European fascism.Advertising We will compose a custom exposition test on Movie Review: Fight Club explicitly for you for just $16.05 $11/page Learn More The filmââ¬â¢s fundamental characters; the anonymous storyteller (Norton), a worker of a voyaging car organization experiences sleep deprivation, Tyler Durden (Pitt), a cleanser sales rep, who is a fabrication of the anonymous narrat orââ¬â¢s creative mind and Marla Singer (Carter), a medication someone who is addicted who winds up as the narratorââ¬â¢s love premium. The specialist of the anonymous storyteller will not treat his sleep deprived person condition with prescription, yet rather alludes him to visit bolster gatherings to watch different peopleââ¬â¢s languishing. The storyteller did only that, he went to an assortment of care groups comprehensive of a gathering for testicular malignancy casualties. He professed to be a casualty and amazingly discovered passionate alleviation. It was at one of these gatherings that he went over Marla Singer who was a faker such as himself. He haggled with her to abstain from meeting at a similar spot (Fight Club Film). Upon his arrival from an excursion for work, he found that his condominium had been annihilated by fire. He was crushed. Fortunately for him, he had met Tyler Durden on the flight home, a custom made cleanser sales rep who had the option to have the destitute storyteller at his once-over loft. Twistedly, the seriousness of the narratorââ¬â¢s ailment made him ignorant that Tyler was a character he made in his mind and that this character was set for shut down corporate greed by whatever implies. They are in certainty disassociated characters caught in a similar body. The moment the storyteller is sleeping; Tyler exploits and starts to overwhelm his body. In one scene, outside a club, Tyler mentioned that the storyteller hit him and the two of them occupied with a clench hand battle. It began to get routine for the two men to have clench hand battles outside the club which began to draw onlookers who later became individuals. That was the introduction of the battle club and all the commotion of this film (Kozlowski) Sociological Concepts of the film The numerous ideas of human science are identified with the numerous cooperations and improvement of individuals. The film gave a great deal of events where sociological ideas were communicated and this gave the film some measure of substance. Five most spoke to sociological ideas of the film incorporates; brutality, gatherings, commercialization, corporate greed and fascism.Advertising Looking for paper on workmanship and plan? We should check whether we can support you! Get your first paper with 15% OFF Learn More Violence The idea of savagery was an ever present in the film. It was utilized to pass on and simultaneously go about as an emblematic similitude of the contention among ages and the publicized standards and folkways of society. As it were, the contention between the ages and what is ââ¬Ëexpectedââ¬â¢ of them. During the film, the storyteller knows no bliss and takes part in the underground men-just boxing club, which may get extremely vicious as a methods for communicating. Watchers may see likewise that toward the beginning of the film, the intellectually sick storyteller slaughtered his folks, and with the impact of Tyler Durden â⬠Å"killedâ⬠his God and afterward he executed Tyler Durden who was his educator. Gatherings The storyteller never obviously fit into any gatherings in the public arena. He felt to some degree distanced and crushed. He is urgently attempting to fit in by being something he isn't. This clarifies why he was so bolted in the foundation of the clench hand battling gathering. In this gathering, shirtless men beat each other in wrecks of blood. His life was exhausting and without significance, he went through his days at an occupation he scorned and evenings scouring mail request lists hotly attempting to give his life some importance. His ailment additionally drives him to advance the battle club as an approach to feel incredible. (Battle Club Fascist). Commercialization According to Matthew Briggsââ¬â¢ survey on the film, the idea of industrialism was passed on at the hour of the blast of the narratorââ¬â¢s condominium. The storyteller related that the annihilation of his apart ment suite isn't only the devastation of a lot of things however the decimation of himself too. The film tended to the exorbitant industrialism as an indication of enthusiastic vacancy and self differentiation. The film depicts him as somebody who purchases things to fill his enthusiastic voids, since he didnââ¬â¢t have any companions or family. His assets characterized him in this manner giving him a customer personality. Tyler attempted to show the storyteller (who by the way is in some cases alluded to as Jack) that his assets and his activity doesnââ¬â¢t characterize him as a person. The film likewise affirmed the way that numerous people in the public arena look to supplant otherworldly satisfaction with material possessions.Advertising We will compose a custom article test on Movie Review: Fight Club explicitly for you for just $16.05 $11/page Learn More Commercialism Fincherââ¬â¢s adjustment of the novel displayed fiercely issue of how corporate greed and industriali sm influenced our social orders. One of Tylerââ¬â¢s primary objectives in the film was to stopped corporate greed. Watchers will see that the characterââ¬â¢s point made them move wildly about in the film, edgy to and obliterating structures which contained money related records for charge cards with an end goal to dispose of societyââ¬â¢s obligation (Interpretations of battle club). Totalitarianism A fundamentalist idea was additionally common in the film ââ¬Ëfight clubââ¬â¢ and as indicated by newspeak word reference, the film is extremist it might be said that the savagery depicted is perfect or more the prior types of civic establishments. This idea is comparative with the character Tyler whose vision of things to come was to come back to a glorified past, not thinking about, the issues which that time experienced. He considers the past as a period that had no companies; along these lines there was no advancement of industrialism. To accomplish this, he used techni ques, for example, savagery and pulverization. Sociological estimation of the film Not the run of the mill activity film of regular day to day existence, ââ¬Å"Fight Clubâ⬠fuses a large number of the sociological issues social orders are confronting. On the off chance that the filmââ¬â¢s messages are deciphered accurately, the film can have remarkably and high sociological worth. The storyline can be identified with by numerous people who are trying to locate their actual personality, are materialistic or even narcissist. The ideas may not generally be communicated emphatically, however they all streamed durably to pass on the numerous messages of the film. Pundits slammed the film since it overemphasized the way that the general public was consumerist, however for some individuals who watch the film, it encourages them to feel less second rate compared to the more practiced classes of individuals. It additionally instructs them that their personality isn't characterized b y their fine Giorgio Armani suit, land broker occupation title, rich condominium or their additional fine Lamborghini however rather by who they are inside. Works Cited Briggs, Matthew. ââ¬Å"Americaââ¬â¢s shopper clubâ⬠, n.d. Web. https://writing.colostate.edu/display/talkingback/issue1/briggs.htmAdvertising Searching for article on workmanship and plan? We should check whether we can support you! Get your first paper with 15% OFF Find out More ââ¬Å"Fight Club Fascist.â⬠, Newspeakdictionary.com, 2005. Web. ââ¬Å"Fight Club Filmâ⬠, Wikipedia.org, n.d. Web. https://en.wikipedia.org/wiki/Fight_Club ââ¬Å"Interpretations of battle clubâ⬠, Wikipedia.org., n.d. Web. https://en.wikipedia.org/wiki/Interpretations_of_Fight_Club Kozlowski, Jaime. ââ¬Å"The battle clubâ⬠, Dompse.org, 2007 Web. https://www.domspe.org/fight_club/soc_fightclub.html This article on Movie Review: Fight Club was composed and put together by client Jorge Robinson to help you with your own examinations. You are allowed to utilize it for exploration and reference purposes so as to compose your own paper; be that as it may, you should refer to it in like manner. You can give your paper here.
Saturday, August 22, 2020
Ethics and Corporate Social Responsibility Of Coles Supermarket
Question: Examine about the Business Ethics, Corporate Governance And Corporate Social Responsibility Of Coles Supermarket. Answer: Moral contemplations are an essential viewpoint inside the business issues. These contemplations help in deciding the methodology of the faculty towards the working environment activities. Cognizant methodology of the staff towards esteeming the assessment of the partners and investors brings about the accomplishment of maintainable development (Moscardo, 2013). Every one of these angles appear to be genuine in any event, for Coles Supermarket. The job of the board is pivotal regarding keeping up the working environment morals. The directors step up to the plate of creating set of principles, which improves the familiarity with the staffs in regards to the moral conduct, which they need to uncover. Adherence and consistence to the set of principles empowers the Coles faculty to increase rewarding arrangements, exchanges and exchanges from the investors (Crane Matten, 2016). This is a continuous movement towards raising the business income and overall revenue. Hypothesis of arranged conduct and contemplated move can be made into thought for evaluating the methodology of the faculty towards working environment morals. Utilitarianism can likewise be alluded for deciding the work environment culture of Coles Supermarket. Work environment culture is a basic issue as far as improving the social parameter. Nearness of straightforwardness, supportability, responsibility, duty and reasonableness legitimizes the situation of the Coles chiefs. This is regarding the administration uncovered for upgrading the proficiency in the business activities (Mason Simmons, 2014). The activity of hazard the executives mirrors the duty of the staffs towards guaranteeing the prosperity of the staffs. Including the partners and investors in the hazard appraisal practice demonstrates the introduction of moral methodology towards the way that the workers are a benefit. References Coles.com.au (2018), About us, Retrieved 26th March 2018 from www.coles.com.au Moscardo, G. (2013). Business morals, corporate administration and corporate social duty. Wiley-Blackwell.
Friday, August 21, 2020
Violence On Television :: essays research papers
Savagery on Television à à à à à Since its presentation, TV has expanded in fame to such a degree that the TV has become the electronic individual from the family. The TV can spellbind us and bait us into universes of imagination and experience as we escape from our concerns and cares. It can likewise illuminate us and welcome us cutting-edge on the most recent news. The TV can be an instructor, a companion, and a wellspring of information what's more, data, or it can negatively affect our conduct. Regardless what impact TV has on an individual, it is regularly conceivable to know somebody's way of life by watching the manner in which he stares at the TV. à à à à à When the TV was first presented, pundits asserted that it would be mind desensitizing, addictive, and absolutely uninvolved. These pundits were portraying the cliché TV watcher, the Addict. As his name infers, this current individual's life spins around sitting in front of the TV. Television resembles a medication to him, and he can't get enough of it. He exemplifies the habitual slouch and the ââ¬Å"boobâ⬠in boob tube, and can frequently be depicted as mentally vacant, particularly while he is sitting in front of the TV. The Addict lives hand to mouth from the potato chip pack. He is languid and will regularly go for a considerable length of time without moving from the TV. à à à à à If the Addict isn't stuck before the TV, he is destined to be discovered paging through his most recent issue of TV direct, cautiously choosing the shows which he will watch that week and stamping them off with a highlighter. On an normal day the Addict will return home from work or school, put off all obligations, and getaway into the universe of TV. In this world, the Addict has no requests or obligations. The TV turns into his lone focal point of consideration, and the entirety of his vitality goes into gazing at the TV. While watching one of his most loved shows, the Addict turns out to be absolutely negligent of his general surroundings. He won't answer his telephone, converse with his family or companions, or do whatever else which may divert from his survey delight. He lives to sit in front of the TV. à à à à à Just as the Addict rose with the development of the TV, the Surfer emerged with the development of the remote control. At the point when a Surfer plunks down to observe TV, he first snatches the remote before any other individual can get to it. He turns on the TV with the remote, and it doesn't leave his grip until he is got done with viewing. He is continually changing the channels and will delay on a specific show just for a second.
Tuesday, May 26, 2020
The Unexpected Truth About Contemporary Issues Topics
The Unexpected Truth About Contemporary Issues Topics Taking a look at the tradition of teaching in a larger context gives you the ability to explore a number of the issues you will face, and the evolving expectations of your function in a policy-led atmosphere. Education is potentially the most important aspect in an individual's success in society. Within this globalize world the organizations are needed to understand the requirements of their employees in order to handle the challenges of the changing external atmosphere. Nonetheless, the stability mission isn't in good standing with the country's political leaders and the American men and women. Human resource management is a rather important concern for all of the companies today. There are a couple of questions that I must answer to go together with the presentation as well 1. The other issues are rather important, but this one is on top of his list. The social issues research papers may appear easy to write in compar ison with different topics, but still it demands an extremely creative strategy, an enormous quantity of curiosity and capacity to think beyond the box and search info in unconventional sources. Human energy usage is responsible for approximately 85 percent of all of the particulate matter and nearly all the sulfur oxides and nitrogen oxides released into the atmosphere. Autism is a neurobiological condition which affects several elements of the brain. Meeting the expectation of patients is thought to be a priority in healthcare business and it's hard enough to realize. Every nation's aim is to boost its income through tourism. There are plenty of measures that could be taken considering the contemporaries. The African nations have gotten major beneficiaries of the business. The beginning of campaigning for the mid-term elections is under a calendar year away. Despite the attractions the tourists need excellent accommodation and far better health services. Tourism and the economy Tourism has been shown to be a pillar in the majority of world economies. The tourism market has to adopt policies that are directed at attracting a huge number of tourists. Individuals are moving fast to find the attraction places until they disappear rendering tourism still the most fascinating portion of the economy. Ultimately it's the duty of every student to finish their necessary work in time. Missing classes isn't acceptable and arriving late will damage your participation grade. Any student who feels they need more help can establish an opportunity to cover the material during my 1st hr. These challenges would be sufficient for any organization to handle. Type of Contemporary Issues Topics Writing an intriguing essay about trendy topics is an opportunity to reveal your understanding of earth. Employing ableism supplies an effective manner of ad dressing ableist discrimination. Your essay may concentrate on gender issues from different portions of the world such as women rights in the Middle East and so forth. If you wish to compose a controversial essay, you definitely must look for the very best social issues topics or satire topics. In general, literature has turned out to be among the best strategies to understand and combat the difficult social problems that shape our world. Women's literature has an extensive tradition in Western literature, but nonetheless, it only begun to obtain recognition in the 19th century. Therefore it is essential for all of the firms to outline a suitable human resource development plan alongside strategies to implement them. The most significant thing is that each one of the departments of any firm are in coordination with one another. Another step to the strategy building might include the decrease in status differentials. Decentralized work planning is a measure taken to make certain that all employees take part i n company decisions. 1 possibility is to check at unemployment. 1 issue from the past that should be addressed again is the essence of land warfare in the existence of nuclear weapons. For instance, a high unemployment rate which affects millions of people is a social matter. As a consequence, social issues can be raised by the unequal distribution of funding between public schools, including that seen in the usa. You can look for different kinds of a word (different word endings of the very same word), by typing the first couple of letters followed by means of an asterisk. Expert help in academic writing is always a better choice for students should they want to secure great grades. It is critical that you also have ready access to a great current college dictionary. You may make more elaborate searches using the words AND, OR, NOT, in conjunction with parentheses.
Friday, May 15, 2020
Immigration Stimulating Our Economy - 2710 Words
McKenzi Lott Argument Essay Mr. Gutierrez Immigration: Stimulating Our Economy Introduction With presidential elections fast approaching this fall, candidates are making known the issues that America faces in these times. Many things including national debt, education, and health care all seem to be hot topics floating around in the air. It is important for citizens to be well aware of what our nation is going through and who can best solve those problems; therefore, they can elect who needs to be in office to fix these problems. One main subject that seems to be buzzing around the nation is our economic system and what we can do to best help it become what it was before. After this last recession, there are still men and womenâ⬠¦show more contentâ⬠¦Without the vast number of immigration that takes place in America, we would not be the powerful, high-tech nation we are today; in fact, we might even be worse off than we feel we are right now. We, as American citizens need to welcome these immigrants with open arms, and if we do so, we will be more united as a nation and our economy will only benefit from it. Competition America has gone through rough times in the past couple of years. With the recent recession, many American citizens have lost jobs, property, and homes. Prices skyrocketed and consumers were afraid to purchase goods: although, this which would have kept our economy running smoothly. Things have gotten better, though. Studies show that the unemployment rateââ¬âwhich has been decreasingââ¬âstill remains at a high 8.3 percent, with a total of 12.8 million persons unemployedââ¬âthis is a lot better than in previous years: the unemployment rate reached as high as 10 percent in 2009 (ââ¬Å"United States Unemployment Rateâ⬠). America runs on a capitalist systemââ¬âsurvival of the fittestââ¬âso, during times like these, competition can get pretty rough. Some citizens feel threatened by immigrants who travel to America; they feel like their rightfully earned jobs will be taken by them. This isnââ¬â¢t the case, however. Most immigrants are legal citizens too and de serve the same opportunities as everyone else. According to scholar, Darrell M. West, there are 35 million immigrants that
Wednesday, May 6, 2020
Building Bridges For Environmentalists The Role Of...
Jody Chinchen PSY 513 November 21, 2014 Final Draft Building Bridges for Environmentalists: The Role of Diversity in the Environmental Movement Introduction Environmentalism has long been accused of being a condition of the affluent ââ¬â a veritable luxury of the first world condition, despite a resounding deficiency of empirical data to support this assumption. A number of studies countering this point of view are being disseminated, potentially dismantling these postulations (Brechin 1999; Fairbrother 2012; Ignatow 2006; Martââ¬â¢inez-Alier and Alier 2012), though the cultural disparity explaining a wide variety of environmentalist concerns remains difficult to explain (Brechin 1999), albeit important. Understanding commonalities, more so than polarities, will prove invaluable as we enter an era of globalization and face increased conflict over resource scarcity. A unified approach to solving environmental issues is imperative. This paper will examine the social constructions of environmentalism in the context of building and reinforcing environmental values. Kevin Archer, in Social Constructions of the Environment, states: ââ¬Å"Environmental issuesâ⬠¦ are consideredâ⬠¦ combined social and natural phenomena, neither wholly natural nor wholly social in origin or substance. Thus, environmental issues, problems and conditions should be studied as such if they are to be successfully identified, analyzed and resolvedâ⬠(2012:1). This paper seeks to examine more thoroughly this concept ofShow MoreRelatedThe Role of Internet in Cultural Globalization3579 Words à |à 14 Pagesï » ¿The Role of Internet in Cultural Globalization Introduction At this point of time, globalizationà has grown to be a phenomenon that is significantly important economically, politically, and culturally. The amalgamation and incorporation of the world economy around the globe has reshaped business. Not only this, it has created new social classes, different jobs, unimaginable wealth, and, occasionally, wretched poverty (Kiggundu 2002, p. 4) by restructuring the lives of the individuals. For someRead MoreThe Holy River of India-River Ganges9512 Words à |à 39 Pagestossing and foaming as they rush vertically down, with pine, deodar and oak trees on its banks. Rishikesh- This is one of the most holiest places for Hindus. It is a maze of temples, ashrams and ghats, a haven for sadhus, yogis and gurus. The famous bridge across the Ganga - LAKSHMAN ââ¬â JHOOLA meaning the swing built by Lakshman across the river to help his brother Ram cross it, is seen here. Haridwar- is in Uttar Pradesh State, India. Hardwar is an ancient town on the River Ganges, located betweenRead MoreImpact Of The World Trade Organization ( Wto ) On The Environment Essay5898 Words à |à 24 PagesFew environmentalists have positive things to say on the impact of the World Trade Organization (WTO) on the environment. WTO legal obligations are frequently cited as the most significant impediment to a range of environmental initiatives, including notably meaningful international coordination to combat climate change, particularly through carbon tax initiatives, and imposition of electronic waste disposal export bans. In this vein, adverse findings of WTO dispute panels on environmental conservationRead MoreNature and Scope of Marketing Ethics6686 Words à |à 27 Pagesof the basic principles have been codified as laws and regulations to require marketers to conform to societyââ¬â¢s expectations of conduct, marketing ethics goes beyond legal and regulatory issues. E thical marketing practices and principles are core building blocks in establishing trust, which help build long-term marketing relationships. In addition, the boundary-spanning nature of marketing (i.e. sales, advertising, and distribution) presents many of the ethical issues faced in business today. BothRead MoreKenyan Tourism Industry11160 Words à |à 45 Pagesopportunities for the future. It is envisaged as leading to the management of all resources in such a way that economic, social, and aesthetic needs can be fulfilled while maintaining cultural integrity, essential ecological processes, biological diversity and life support systems. Sustainability, sustainable tourism and sustainable development are all wellestablished terms that have been used loosely and often interchangeably in literature. To get a unambiguous view of sustainable tourism, its imperativeRead MoreDeveloping Management Skills404131 Words à |à 1617 PagesSelf-Awareness 45 Managing Personal Stress 105 Solving Problems Analytically and Creatively 167 PART II 4 5 6 7 INTERPERSONAL SKILLS 232 233 Building Relationships by Communicating Supportively Gaining Power and Influence 279 Motivating Others 323 Managing Conflict 373 PART III GROUP SKILLS 438 8 Empowering and Delegating 439 9 Building Effective Teams and Teamwork 489 10 Leading Positive Change 533 PART IV SPECIFIC COMMUNICATION SKILLS 590 591 Supplement A Making Oral andRead MoreLidl Norway30015 Words à |à 121 Pagesà Norwegianà groceryà market,à becauseà ofà theirà lowà pricesà andà ââ¬Å"exoticâ⬠à products.à Someà willà tellà youà thatà theyà neverà shoppedà there,à becauseà theyà didnââ¬â¢tà wantà toà supportà aà foreignà companyà thatà ignoredà theà laborà unions,à buildà largeà andà unattractiveà buildingsà inà theirà towns,à onlyà hadà unfamiliarà foodà inà theà shelvesà andà whoà sentà theà profità outà ofà theà country.à Ifà youà askà Norwegiansà whyà Lidlà failedà inà Norway,à manyà willà argueà thatà Lidlà didà notà fulfillà theà Norwegianà shoppersRead MoreContemporary Issues in Management Accounting211377 Words à |à 846 PagesPeasnell, Geoffrey Whittington, and à ´ David Tweedie as it has from the eminence grise of the profession itself. And even in auditing, significant roles have been played by Professors Peter Bird, David Flint, and Peter Moizer amongst others. Indeed it is possible to argue that the British academic accounting professoriate has played an extremely important role in mediating between the profession and the state, both bringing knowledge to bear on policy issues and providing a cadre of people who can operateRead MoreInternational Management67196 Words à |à 269 Pagessaw their economies stagnate or decline. The global political environment remains volatile and uncertain, with ongoing conflicts in the Middle East and Africa and continuing tensions in Iran, North Korea, Iraq, and Afghanistan, especially as the U.S. role in these latter two countries evolves. On the economic front, failure to conclude important trade agreements, including the so-called ââ¬Å"Developmentâ⬠Round of multilateral trade negotiations under the World Trade Organization, and the lag ging supportRead MoreOne Significant Change That Has Occurred in the World Between 1900 and 2005. Explain the Impact This Change Has Made on Our Lives and Why It Is an Important Change.163893 Words à |à 656 Pagestheir situation within the domestic sphere and the conditions under which they labored to expand the career opportunities available to them at different times and in diverse settings. She places special emphasis on the important but often overlooked roles they played in politics, particularly those associated with resistance movements, and their contributions to arts and letters worldwide. Drawing on the essay collections and series on women in world history that she has edited over the past decade
Tuesday, May 5, 2020
Charities free essay sample
The legal definition of charity has historically been somewhat elusive and stands distinct from any understanding of charity in a general or popular sense. As Lord Wright observed, in its legal sense the word ââ¬Å"charitable is a word of art, of precise and technical meaningâ⬠[1]. Viscount Simmonds further remarked that, ââ¬Å"no comprehensive definition of legal charity has been given either by legislature or in judicial utterance, there is no limit to the number and diversity of ways in which man will seek to benefit his fellow menâ⬠. The Preamble to the Charitable Uses Act 1601, also referred to as the Statute of Elizabeth I, contained a list of purposes which were then regarded as charitable. It assumed a central role for the courts as a reference point or catalogue of accepted instances of charity until almost 300 years later when Lord MacNaughten in the Pemsel case, famously classified charitable objects into four principal divisions: (i) trusts for the relief of poverty, (ii) trusts for the advancement of education, (iii) trusts for the advancement of religion, (iv) trusts beneficial to the community not falling under any of the preceding heads. We will write a custom essay sample on Charities or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page These four heads of charity were used as reference whenever the inherent charitable nature of a purpose or institution was questioned until the Charities Act 2006 received royal assent. Section 2(2) of the 2006 Act now provides a modern statutory definition of charity by listing 13 descriptions of purposes deemed charitable at law. In order to be charitable, an organisation has to be established for one or more purposes within the descriptions recognised by the law as capable of being charitable, and for the public benefit. Charity law in England and Wales has developed within the context of the traditional monotheistic religions but it has embraced for many years religions other than Christianity and Judaism. In Bowman[3], Lord Parker effectively held that it was not just the promotion of Christianity that would be recognised but that the Courts of this country were not precluded ââ¬Å"from giving effect to trusts for the purposes of religions which, however sacred they may be to millions of His Majestys subjects, either deny the truth of Christianity or, at any rate, do not accept some of its fundamental doctrinesâ⬠. Furthermore in the Commissionââ¬â¢s Scientology[4] decision it was firmly established that ââ¬Å"The law does not prefer one religion to another and as between religions the law stands neutralâ⬠[5]. The English courts have, for a long time, resisted closely defining what makes some belief systems religious and others not. However in the Scientology case, the Commissioners accepted that there are various characteristics of religion which can be discerned from the legal authorities: â⬠¢ Belief in a god or a deity or supreme being ââ¬â R v Registrar General[6] â⬠¢ Two of the essential attributes of religion are faith and worship: faith in a god and worship of that god South Place Ethical Society[7] â⬠¢ To advance religion means ââ¬Å"to promote it, to spread the message ever wider among mankind; to take some positive steps to sustain and increase religious belief and these things are done in a variety of ways which may be comprehensively described as pastoral and missionaryâ⬠. United Grand Lodge v Holborn BC[8]. Having considered these characteristics, the Commissioners concluded that the definition of a religion in English charity law was characterised by a belief in a supreme being and an expression of that belief through worship. This definition is further refined in the 2006 Act where s2 (3) a gives a partial definition of the word religion. However, the law does not automatically recognise as a religion everything that may designate itself as a religion and there are some principles to which a purpose must conform if it is to be regarded as within the Charities Actââ¬â¢s description of ââ¬Ëthe advancement of religionââ¬â¢. These general principles are gathered from the common law of England and Wales but also take into account the body of law which has developed concerning the European Convention right to freedom of thought, conscience and religion. As a general proposition, for its advancement to be capable of being charitable in this context, a religion should have a certain level of cogency, seriousness, coherence and importance[9]. Also, in order to be charitable for the advancement of religion, the content of any system of faith and worship has to be of a positive nature, impacting beneficially on the community. Sir John Wickens, V-C. in Cocks v Manners[10] observed: ââ¬Å"It is said, in some of the cases, that religious purposes are charitable, but that can only be true as to religious services tending directly or indirectly towards the instruction or the edification of the publicâ⬠¦Ã¢â¬ Hence, to be charitable a religious purpose has to be serious, tend directly or indirectly to the moral and spiritual improvement of the public as well as being for the public benefit. In Holmes v Attorney General[11] Walton J commented: ââ¬Å"â⬠¦ It is not for the benefit of the adherents of the religion themselves that the law confers charitable status, it is in the interests of the public. â⬠Hence, as a general proposition, in the case of charities for the advancement of religion the purpose must not simply be for the benefit of the followers of the particular religion. Formerly, the proposition stated that ââ¬Å"as between different religions the law stands neutral, but it assumes that any religion is at least likely to be better than noneâ⬠[12]. Plowman J in Re Watson[13] considered a case for the publication and distribution of the fundamentalist Christian writings of an individual where he quoted authority that the court does not prefer one religion or sect to another and said that where the purposes in question are of a religious nature then the court assumes a public benefit unless the contrary is shownâ⬠. He then went on to say that the only way of disproving a public benefit is to show that the doctrines inculcated are adverse to the very foundations of all religion, and that they are subversive of all morality. However, that part of the judgment being inconsistent with the judgment of the court of appeal and opinions given by the House of Lords in Gilmour v Coats, where it was held: ââ¬Å"â⬠¦the question whether a trust is beneficial to the public is an entirely different one from the question whether a trust is for the advancement of religionâ⬠, it is not regarded a binding. Since the Charities Act 2006, there is no longer any presumption that, because a purpose falls within the description ââ¬Å"the advancement of religionâ⬠, it is for the public benefit. Section 3(2) of the Act provides: ââ¬Å"In determining whether [the public benefit] requirement is satisfied in relation to any â⬠¦purpose, it is not to be presumed that a purpose of a particular description is for the public benefitâ⬠. Hence, with the removal of the presumption and in the modern context the proposition may now be interpreted as meaning that advancing religion can be seen as a public good if such advancement can be demonstrated to be in relation to a system having a benign and positive content which is being advanced for the benefit of the public. Over the years, there are some purposes which, despite being beneficial and religious and indeed seriously religious, did not fall within the legal framework. For example, fostering private piety, although being a religious activity, is not a charitable purpose due to the absence of benefit to the public. In Cocks v Manners[14] (supra) it was said that ââ¬Å"a voluntary association of women for the purpose of working out their own salvation by religious exercises and self-denial seems to have none of the requisites of a charitable institution. â⬠In the Re Joy[15] case it was held that the real object contemplated by the testator was the non-charitable purpose of improvement of the membership of a society by prayer. Further, in Re White[16], it was held that ââ¬Å"a society for the promotion of private prayer and devotions by its own members and which has no wider scope, no public element, and no purpose of general utility would not be charitableâ⬠. Lord Simonds in the Gilmour[17] case later confirmed the decision in Cocks v Manners and said that activities ââ¬Å"good in themselves but solely designed to benefit individuals associated for the purpose of securing that benefit, which may not have some repercussions or consequential effects beneficial to some section of the general communityâ⬠do not meet the prerequisites of a charitable institution. In Re Warreââ¬â¢s Will Trusts, on the matter of a retreat house, Harman J said: ââ¬Å"Activities which do not in any way affect the public or any section of it are not charitable. Pious contemplation and prayer are, no doubt, good for the soul, and may be of benefit by some intercessory process, of which the law takes no notice, but they are not charitable activities. â⬠Thus, in Re Hetherington[18] it was held that the celebration of a religious rite in private does not contain the necessary element of public benefit since any benefit of prayer or example is incapable of proof in the legal sense and any element of spiritual or moral improvement (edification) is limited to a private not public class of those present at the celebration. However, in the same case it was also held that the holding of a religious service which is open to the public is capable of conferring a ââ¬Å"sufficient public benefit because of the edifying and improving effect of such celebration on the members of the public who attend. â⬠There are also other purposes related to religion whose pursuits have not been considered as charitable because the purpose itself is not exclusively charitable. For example a trust ââ¬Ëfor Roman Catholic purposesââ¬â¢ may not be for exclusively charitable purposes furthering the Roman Catholic faith[19]. Also a gift to an Anglican vicar of a parish ââ¬Å"for parochial institutions or purposeâ⬠ââ¬â¢[20] was not considered charitable. A bequest to an archbishop to be applied ââ¬Å"in any manner he might think best for helping to carry on the work of the Church in Walesâ⬠[21] is not charitable either and neither is a generally stated purpose ââ¬Å"for religious, educational and other parochial requirementsâ⬠[22]. On the other hand, In Re Schoales[23], it was clarified that there is no distinction, from the point of view of validity as a gift for charitable purposes, between a gift to the Church of England and a gift to another Church. A gift for the general purposes of a particular church or denomination or faith community falls are considered in law as a gift which has to be applied only for such of its purposes as are for the advancement of religion for the public benefit, and hence charitable. As mentioned above, charitable purposes require some promotion or advancement that is to ââ¬Å"spread its message ever wider among mankind; to take some positive steps to sustain and increase religious beliefâ⬠[24]. Proselytising is one way of advancing religious purposes[25] but it may raise public benefit issues if it breaks the law or results in harm or detriment. Therefore, it would not be compatible with public benefit principles for an organisation to seek to inhibit anyone from their rights of freedom of thought, conscience or religion (Article 9 ECHR) and to manifest or change such beliefs. This matter was considered in Kokkinakis v Greece[26] and the court in considering attempts to forbid activities of a Jehovahââ¬â¢s Witness confirmed that a democratic society has a plurality of beliefs and held that freedom to manifest oneââ¬â¢s religion includes the right to convince oneââ¬â¢s neighbor. But, the court drew a clear distinction between bearing Christian witness and improper proselytism by stating that the former was true evangelism and the latter representing a corruption or deformation of it. Furthermore, proselytising being unlawful in some countries, the Commission dealt with the issue of whether it was possible to recognise a religious purpose as charitable in England and Wales which is not charitable and may be illegal abroad in its annual report in 1993 which mentioned: ââ¬Å"One should first consider whether they would be regarded as charities if their operations are confined to the United Kingdom. If they would, then they should be presumed also to be charitable even though operating abroad unless it would be contrary to public policy to recognise them. Hence, an organisation whose purpose is to proselytize, even if its activity is carried out internationally, may be charitable in England and Wales unless it causes harm or detriment which outweighs the public benefit. The High Court considered the statement in the Sonsino case[27] in 2002 and upheld it. However, it still remains unclear as to what the courts would rule contrary to public policy. Another way of advancing a religion would be by means of undertaking pastoral work. However, where a charity is operating solely for the purpose of advancement of religion, then any secular pastoral work which it undertakes should be as a means of advancing the particular religion. A convent in Cocks v Manners[28] was held charitable and there the nuns were engaged in exterior works (teaching the ignorant and nursing the sick) as part of their religious work. In the United Grand Lodge[29] case, Donovan J said that taking positive steps to sustain and increase religious beliefs was something done ââ¬Å"in a variety of ways which can be comprehensively described as pastoral and missionaryâ⬠. More recently, the Pilsdon Community House, a religious community living according to Christian principles and giving practical help in cases of drug addiction, drink, having been in prison or loneliness was considered in Re Banfield[30]. The court held that the fact that a religious community makes its services available to those of all creeds and of none does not prevent it being a charity for the advancement of religion also that furthering the purposes of the community amounted to the advancement of religion.
Subscribe to:
Posts (Atom)