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Ali zato nikad ne zaboravi pogledati ono sto je obecala, pa na sljedeci sat dolazi ne samo s tom jednom nego s jos desetak okolnih, slicnih rijeci i fraza. Marijana uvijek ima dovoljno vremena za sve. Nikad ni preko cega ne pretrcavamo, sat nikada nije gotov ni sekundu prije, dapace, ostanemo i koju minute duze ako je potrebno. Sve sto radi, Marijana radi s gustom i daje se u to film and juliet 100% upravo je takav moj dojam. Ona je ta koja motivira, inspirira i povlaci cijelu grupu, njezin je entuzijazam zarazan. Can You! Mozda bih mogla uciti i jos koji strani jezik#8230; No, s obzirom na to Essay on Can Ameliorate Condition? da Marijana predaje (samo) portugalski ostajem na #8216;njemu#8217; do daljnjega! Excelente guia .Competente, educada, atenciosa.Comprometida e profissional.

Recomendo a todos#8230;. Sucesso ! No ano de 2014 no seu mes de Setembro eu e a minha esposa decidimos visitar a Croacia. Nessa viagem alem das inegaveis belezas que tivemos o privilegio de conhecer e disfrutar, tivemos a felicidade de termos como guia uma Senhora do seu nome Marijana Mijatovic. Can You Eat Poop! Ora a Marijana, revelou-se a maior beleza de todas as que conhecemos, beleza de caracter, beleza profissional, beleza de ser humano. Supernaturalism In Macbeth! Sempre bem-disposta, sempre solicita, sempre competente, sempre atenciosa, Marijana marcou a mim e a minha esposa de uma forma indelevel, ficando para sempre nos nossos coracoes.

Obrigado Marijana por tudo, mereces o melhor, de nos, teras para sempre a nossa admiracao e sincera amizade. O trabalho prestado pela guia Marijana so merece elogios pela eficiencia com que executa as suas funcoes. E uma pessoa gentil, dedicada e que da a sensacao de tranquilidade e seguranca a quem usa os seus servicos.Tem pleno dominio da lingua portuguesa permitindo uma comunicacao perfeita. Mostra total conhecimento dos lugares, sua historia, sua cultura, tornando a excursao rica em detalhes. Demonstrou ser uma profissional muito competente. Can You! Excelente trabalho e disponibilidade de nossa guia. Marijana durante nossa estadia na Croacia ! Conhecemos a historia do pais e vivenciados sua cultura neste periodo ! Obrigada e espero reve- la breve ! Beijos . Excelente trabalho exercido por voce, durante nossa estada na Croacia!

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The rest of the day passed awesome after meeting her. After three years when my family and I came back to New York, I saw my friend one day on Main street. College , Debut albums , English-language films 1007 Words | 3 Pages. Love Is Diverse Love is like a war, its easy to supernaturalism start but very hard to finish. Throughout history there have been so many . different ways to describe it between different cultures because it is such a broad subject. There are so many different types of love but I think they all have the same similar meanings.

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Tell your readers about the preparation that you were able to do, the reasons that you didn't get to prepare as well as you wanted, taking the test. Change , Learning , Narrative 1202 Words | 3 Pages. ? Pontificia Universidad Catolica Madre y Maestra Departamento de Linguistica Aplicada Academic Writing Teacher: Newcombe Rosa . Narrative Essay Participant: Marcelle Lama 2011-5053 November 8th, 2013 Hope they didnt hear! Things arent often what they appear to be at first blush. In Children Palsy Essay. But embarrassment is. It was one of those boring days at school; my friends and I were used to it.

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Bus stop , Kelantan , Kota Bharu 1560 Words | 4 Pages. English 151 Chapter 28 Argument Essay - What is Happiness? About Love In the world we live in, there are people who oppose . love and everything that comes with it. And then there are people who are all for it and want it to happen to them. Who Is The Demon Hoarder Of Wealth. Being in can you, love with someone is one of the most beautiful, life changing things there is.

Love gives you a completely outlook on life and it makes you realize how precious life really is. As said in the beginning of the the importance of being, paragraph, love is can you eat poop, not for everybody. Everyone. 2002 albums , American films , English-language films 1027 Words | 4 Pages. The Story of My Love 02/13/2013 Love is a crazy, strange, yet enticing game. Many think that they will never fall into its . captivating lure; I am one of these people.

If someone had told me back in the outsider, April, when Aingeal and I were officially introduced that he would later become my Fiancee, I would have laughed at eat poop, the mere thought. Its quite funny how life works. We have had our share of problems but I never would have thought I would lose him so soon. Shortly before finishing the last of. Debut albums , Friendship , Graduation 1433 Words | 3 Pages. Power of Love and Relationship La Toya Varnado PSY: 301 Social Psychology Professor Jeanne Henry April 30, 2012 . We learn as grow from children into in macbeth adulthood that all relationships donat last and they were not all meant to can you be. Who Is. The relationships depends on factors inside the relationship , like costs and rewards; factors inside the person, like comparison level; and factors outside the relationship , like available alternatives. This paper will address the many.

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I struggled my whole childhood through Elementary ,Middle, and High school. I remember feeling like my life was over when it came time to victorian write an can you . essay , I could already hear my mother and fathers voice in the outsider, my head as I recieved a big fat F on my paper. I found a way to breeze by school during my childhood. I still had no clue how to write a simple essay , or an interest in picking up a newspaper or magazine and reading it. Eat Poop. My mother and the demon father worked to keep food on the table so they only had time. Essay , Full-time , High school 1159 Words | 3 Pages. law; my mother was in can you eat poop, the PTA. A pile of of being earnest society, our clothes scattered on the floor of our Tarrytown apartment makes me so happy that I took that unexpected, . unfamiliar trip to Katowice, Poland.

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Mother 1761 Words | 4 Pages. Name: Jamin Clubb English 1101 Class 425 9/20/11 Narrative essay I remember Valentines Day this past year like no other; . The Demon Hoarder Of Wealth. it was on a Monday this year. Mondays for my wife and me were like our Fridays, we both worked weekends, and for years never got to go out can you eat poop much; that was until we discovered half priced beers at a place called World of Beer. That became our normal spot; we even got a large group of Ameliorate, friends to can you come out with us every Monday night for Essay on Can Technology Ameliorate the Human Condition?, drinks and games at eat poop, the bar. About a. Debut albums , Doctor , Human chorionic gonadotropin 1124 Words | 3 Pages. Camacho Narrative Essay Week 5 Revision There can be major physical changes and effects to of wealth a females body after having a . Can You. child.

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Debut albums , Debut singles , Interpersonal relationship 1425 Words | 4 Pages. essay on A Different Kind of Love. Different Kind of eat poop, Love Throughout time, men and women have struggled with the idea of love . What is it? How can I tell when I . feel it? Is it the same for everyone? While there are these questions, amongst many more, people will search and fight for a feeling they are uncertain of. Different people can express the great mystery that is love many different ways. In both Ernest Hemingway's Hills Like White Elephants and the importance society Raymond Carter's What We Talk About When We Talk About Love , the authors explore. 2007 films , Drama films , English-language films 1852 Words | 5 Pages. Keba Raye Eng 101 (online) Narrative Paper / Final Draft A DANCER WAS BORN I had only hours until those big red curtains slowly dragged . apart. I had been practicing for can you, the most important showcase of the Essay Technology Ameliorate, year for over a month now.

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They ride for the thrill and supernaturalism in macbeth because they love to do it. Not everyone is eat poop, able to do half of the things professional athletes in and juliet, action sports. English-language films , Love , Motocross 1190 Words | 3 Pages. in relationships with others, who tend to fall in love immediately and can you want a commitment fast little trust for other and unable . to have love and intimacy * Cant establish a stable intimate relationship with one person * Never feel love and of wealth trust in their upbringings, doesnt know how to love other people * Motivational component in Sternbergs triangular theory of love physical attraction, romantic feelings and sexual desire by others * Colors of loving game playing love (ludus). Human bonding , Human sexuality , Interpersonal attraction 1142 Words | 5 Pages. ? True Love From a simple mixture of sexual attraction and attachment to a manifestation of the human soul, feelings of fierce romantic . desire boast no shortage of theories explaining their origin and meaning. Love is can you eat poop, as much a mystery as it is familiar, highlighting a lack of the outsider analysis, insight into the human psyche. As man attempts to unravel the endless enigmas behind this apparently paradoxical emotion, more and can you more questions seem to arise. What is hoarder of wealth, love's true purpose? Why does it begin? How are.

Affection , Emotion , Interpersonal relationship 1180 Words | 3 Pages. April 15, 2013 Multicultural Literature Christian Davis Relationships in Love Medicine Love Medicine is can you, a . series of short stories that was written by Lousie Erdrich in 1984 and Sleep Disorders with covers a time span of 60 years. Love Medicine is set in North Dakota on an Indian reservation known as Turtle Mountain. Although the novel is fiction, the cultural, social, and economical aspects depicted are very realistic. Hertha Sweet Wong describes Love Medicine as Metafiction, ironically self-conscious in its mode. Family , Grandparent , Interpersonal relationship 1286 Words | 4 Pages. Eternal Love We were sitting in the doctors office when he told us, your wife has breast cancer. All of a sudden the eat poop, room vanished and in Children Cerebral Palsy I . found myself in a darker room, unable to can you eat poop feel anything.

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I prefer Descriptive essays , rather than narrative essays . Can You Eat Poop. In my belief, it's that the descriptive essays are more effective when an author is trying to analysis convey a story or get a. Essay , Fiction , Narrative 1153 Words | 4 Pages. sailor he knew, in the back of his mind, rushing blindly into a strong current was the definition of eat poop, stupidity. He didt care, that young creature in the Human, the . Eat Poop. stream was innocent and supernaturalism in macbeth worth far more than an unappreciative, selfish old man who had wasted the love of friends and family for nothing but his unyielding pride. He swam downstream as fast and as hard as he could, his injured leg now resembling a rusty old anchor dragging him down towards the can you eat poop, cold and murky depths.

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An Essay On Criticism - Poem by Alexander Pope. 'Tis hard to say if greater want of skill. Appear in writing or in eat poop judging ill; But of the two less dangerous is film romeo th'offence. To tire our patience than mislead our sense: Some few in that, but numbers err in this; Ten censure wrong for one who writes amiss; A fool might once himself alone expose; Now one in verse makes many more in prose. Go just alike, yet each believes his own. In Poets as true Genius is but rare, True Taste as seldom is the Critic's share; Both must alike from Heav'n derive their light, These born to judge, as well as those to write. Let such teach others who themselves excel, And censure freely who have written well; Authors are partial to can you their wit, 'tis true, But are not Critics to their judgment too? Most have the seeds of judgment in in macbeth their mind: Nature affords at can you eat poop, least a glimm'ring light; The lines, tho' touch'd but faintly, are drawn right: But as the slightest sketch, if justly traced, Is by ill col'ring but the more disgraced, So by false learning is good sense defaced: Some are bewilder'd in the maze of schools, And some made coxcombs Nature meant but fools:

In search of wit these lose their common sense, And then turn Critics in their own defence: Each burns alike, who can or cannot write, Or with a rival's or an eunuch's spite. All fools have still an itching to deride, And fain would be upon the laughing side. If M?vius scribble in Apollo's spite, There are who judge still worse than he can write. Turn'd Critics next, and prov'd plain Fools at romeo, last. Some neither can for Wits nor Critics pass, As heavy mules are neither horse nor ass. Those half-learn'd witlings, numerous in our isle, As half-form'd insects on the banks of Nile; Unfinish'd things, one knows not what to call, Their generation's so equivocal; To tell them would a hundred tongues required, Or one vain Wit's, that might a hundred tire.

And justly bear a Critic's noble name, Be sure yourself and eat poop your own reach to know, How far your Genius, Taste, and Learning go, Launch not beyond your depth, but be discreet, And mark that point where Sense and romeo and juliet Dulness meet. And wisely curb'd proud man's pretending wit. As on the land while here the ocean gains, In other parts it leaves wide sandy plains; Thus in the soul while Memory prevails, The solid power of Understanding fails; Where beams of can you, warm Imagination play, The Memory's soft figures melt away. One Science only will one genius fit; So vast is Art, so narrow human wit: Now only hoarder of wealth, bounded to peculiar arts, But oft in those confin'd to single parts. Like Kings we lose the can you, conquests gain'd before, By vain ambition still to make them more: Each might his sev'ral province well command, Would all but stoop to what they understand. Romeo And Juliet. By her just standard, which is still the same; Unerring Nature, still divinely bright,

One clear, unchanged, and can you universal light, Life, force, and romeo beauty must to all impart, At once the source, and end, and test of Art. Art from that fund each just supply provides, Works without show, and without pomp presides. In some fair body thus th'informing soul. With spirits feeds, with vigour fills the whole; Each motion guides, and every nerve sustains, Itself unseen, but in th' effects remains. Some, to whom Heav'n in can you eat poop wit has been profuse, Want as much more to who is turn it to its use; For Wit and Judgment often are at strife.

Tho' meant each other's aid, like man and wife. Can You Eat Poop. 'Tis more to the outsider guide than spur the Muse's steed, Restrain his fury than provoke his speed: The winged courser, like a gen'rous horse, Shows most true mettel when you check his course. Are Nature still, but Nature methodized; Nature, like Liberty, is can you eat poop but restrain'd. Disorders With Palsy Essay. By the same laws which first herself ordain'd. When to can you repress and when indulge our flights: High on the outsider Parnassus' top her sons she show'd, And pointed out those arduous paths they trod; Held from can you eat poop, afar, aloft, th'immortal prize, And urged the rest by hoarder of wealth equal steps to rise. Just precepts thus from great examples giv'n, She drew from can you, them what they derived from Heav'n. The gen'rous Critic fann'd the poet's fire, And taught the world with reason to Sleep Cerebral Essay admire. Then Criticism the Muse's handmaid prov'd, To dress her charms, and make her more belov'd: But following Wits from that intention stray'd: Who could not win the mistress woo'd the maid; Against the can you eat poop, Poets their own arms they turn'd, Sure to who is hoarder of wealth hate most the men from eat poop, whom they learn'd. Who Is Hoarder Of Wealth. So modern 'pothecaries taught the art.

By doctors' bills to play the doctor's part, Bold in the practice of mistaken rules, Prescribe, apply, and call their masters fools. Can You. Some on the leaves of ancient authors prey; Nor time nor moths e'er spoil'd so much as they; Some drily plain, without invention's aid, Write dull receipts how poems may be made; These leave the sense their learning to display, And those explain the meaning quite away. Know well each ancient's proper character; His fable, subject, scope in Sleep Cerebral Palsy every page; Religion, country, genius of his age: Without all these at once before your eyes, Cavil you may, but never criticise. Be Homer's works your study and delight, Read them by day, and meditate by eat poop night; Thence form your judgment, thence your maxims bring, And trace the Muses upward to their spring. Essay Technology Ameliorate Condition?. Still with itself compared, his text peruse; And let your comment be the can you, Mantuan Muse. A work t'outlast immortal Rome design'd, Perhaps he seem'd above the critic's law, And but from who is the demon, Nature's fountains scorn'd to draw; But when t'examine ev'ry part he came, Nature and eat poop Homer were, he found, the same. Convinced, amazed, he checks the bold design, And rules as strict his labour'd work confine. As if the Stagyrite o'erlook'd each line.

Learn hence for ancient rules a just esteem; To copy Nature is to copy them. The Importance Of Being Earnest Victorian Society. For there's a happiness as well as care. Music resembles poetry; in each. Are nameless graces which no methods teach, And which a master-hand alone can reach. If, where the rules not far enough extend, (Since rules were made but to promote their end) Some lucky license answer to the full. Can You Eat Poop. Th'intent proposed, that license is a rule. Thus Pegasus, a nearer way to who is the demon of wealth take, May boldly deviate from the common track. Great Wits sometimes may gloriously offend, And rise to faults true Critics dare not mend; From vulgar bounds with brave disorder part, And snatch a grace beyond the reach of Art, Which, without passing thro' the judgment, gains. The heart, and eat poop all its end at of being earnest victorian, once attains.

In prospects thus some objects please our eyes, Which out of Nature's common order rise, The shapeless rock, or hanging precipice. But tho' the ancients thus their rules invade, (As Kings dispense with laws themselves have made) Moderns, beware! or if you must offend. Against the can you, precept, ne'er transgress its end; Let it be seldom, and on Can Technology Ameliorate compell'd by eat poop need; And have at supernaturalism, least their precedent to can you plead; The Critic else proceeds without remorse, Seizes your fame, and puts his laws in force. On Can Technology Condition?. Those freer beauties, ev'n in them, seem faults. Some figures monstrous and misshaped appear, Consider'd singly, or beheld too near, Which, but proportion'd to their light or place, Due distance reconciles to form and grace. A prudent chief not always must display. His powers in can you eat poop equal ranks and fair array, But with th'occasion and the place comply, Conceal his force, nay, seem sometimes to romeo and juliet fly.

Those oft are stratagems which errors seem, Nor is eat poop it Homer nods, but we that dream. Romeo And Juliet. Above the reach of sacrilegious hands, Secure from flames, from can you, Envy's fiercer rage, Destructive war, and all-involving Age. Supernaturalism In Macbeth. See from each clime the learn'd their incense bring! Hear in can you all tongues consenting Paeans ring! In praise so just let ev'ry voice be join'd, And fill the gen'ral chorus of mankind. Hail, Bards triumphant! born in Sleep in Children Essay happier days, Immortal heirs of universal praise! Whose honours with increase of ages grow,

As streams roll down, enlarging as they flow; Nations unborn your mighty names shall sound, And worlds applaud that must not yet be found! O may some spark of your celestial fire. Can You. The last, the meanest of your sons inspire, (That on weak wings, from far, pursues your flights, Glows while he reads, but trembles as he writes) To teach vain Wits a science little known, T'admire superior sense, and doubt their own. Analysis. Of all the eat poop, causes which conspire to blind. Film. Man's erring judgment, and misguide the mind, What the weak head with strongest bias rules, Is Pride, the never failing vice of fools. Whatever Nature has in worth denied. Eat Poop. She gives in large recruits of in Children Cerebral Palsy, needful Pride: For as in bodies, thus in eat poop souls, we find. What wants in blood and spirits swell'd with wind: Pride, where Wit fails, steps in to hoarder our deference, And fills up all the mighty void of Sense: If once right Reason drives that cloud away, Truth breaks upon us with resistless day.

Trust not yourself; but your defects to know, Make use of eat poop, ev'ry friend--and ev'ry foe. Drink deep, or taste not the Pierian spring: There shallow draughts intoxicate the brain, And drinking largely sobers us again. Fired at first sight with what the the outsider, Muse imparts, In fearless youth we tempt the heights of arts, While from the can you, bounded level of our mind. Short views we take, nor see the lengths behind: Bur more advanc'd, behold with strange surprise. New distant scenes of endliess science rise! So pleas'd at first the Essay Ameliorate Condition?, tow'ring Alps we try, Mount o'er the can you, vales, and the outsider seem to tread the sky; Th'eternal snows appear already past,

And the first clouds and mountains seem the last: But those attain'd, we tremble to survey. Eat Poop. The growing labours of the the outsider, lengthen'd way; Th'increasing prospect tires our wand'ring eyes, Hills peep o'er hills, and Alps on can you Alps arise! With the same spirit that its author writ; Survey the whole, not seek slight faults to find. Essay Technology Ameliorate The Human Condition?. Where Nature moves, and Rapture warms the mind: Nor lose, for that malignant dull delight, The gen'rous pleasure to can you be charm'd with wit. But in such lays as neither ebb nor flow, Correctly cold, and regularly low, That shunning faults one quiet tenor keep, We cannot blame indeed--but we may sleep.

In Wit, as Nature, what affects our hearts. Is not th'exactness of peculiar parts; 'Tis not a lip or eye we beauty call, But the joint force and full result of all. Thus when we view some well proportion'd dome, (The world's just wonder, and ev'n thine, O Rome!) No single parts unequally surprise, All comes united to the outsider th'admiring eyes; No monstrous height, or breadth, or length, appear; The whole at can you, once is the demon of wealth bold and regular. Can You. Thinks what n'er was, nor is, nor e'er shall be. In every work regard the writer's end, Since none can compass more than they intend; And if the means be just, the conduct true, Applause, in spite of supernaturalism, trivial faults, is due. Eat Poop. As men of breeding, sometimes men of wit, T'avoid great errors must the in macbeth, less commit; Neglect the can you eat poop, rules each verbal critic lays, For not to know some trifles is a praise. Most critics, fond of Sleep Cerebral Essay, some subservient art, Still make the whole depend upon a part: They talk of Principles, but Notions prize, And all to eat poop one lov'd folly sacrifice.

A certain bard encount'ring on the way, Discours'd in terms as just, with looks as sage, As e'er could Dennis, of the Grecian State; Concluding all were desperate sots and analysis fools. Who durst depart from Aristotle's rules. Our author, happy in can you eat poop a judge so nice, Produced his play, and begged the knight's advice; Made him observe the Subject and the Plot, The Manners, Passions, Unities; what not? All which exact to rule were brought about, Were but a combat in the lists left out. ``What! leave the combat out?'' exclaims the on Can Technology Ameliorate the Human, knight. ``Yes, or we must renounce the Stagyrite.'' ``Not so, by Heaven!, (he answers in a rage) Knights, squires, and steeds must enter on can you eat poop the stage.'' ``So vast a throng the stage can n'er contain.'' ``Then build a new, or act it in a plain.'' Curious, not knowing, not exact, but nice, Form short ideas, and offend the Arts. Of Wealth. (As most in can you Manners), by a love to parts. And glitt'ring thoughts struck out at of being, every line; Pleas'd with a work where nothing's just or fit, One glaring chaos and wild heap of can you, wit. Poets, like painters, thus unskill'd to trace. The naked nature and the living grace, With gold and the outsider jewels cover every part, And hide with ornaments their want of Art.

True Wit is Nature to can you eat poop advantage dress'd, What oft was thought, but ne'er so well express'd; Something whose truth convinced at sight we find, That give us back the image of our mind. As shades more sweetly recommend the light, So modest plainness sets of the importance of being earnest society, sprightly wit: For works may have more wit than does them good, As bodies perish thro' excess of can you eat poop, blood. And value books, as women men, for of being earnest society, dress: Their praise is still--the Style is excellent; The Sense they humbly take upon content. Words are like leaves; and where they most abound, Much fruit of sense beneath is rarely found. False eloquence, like the can you eat poop, prismatic glass, Its gaudy colours spreads on every place; The face of Nature we no more survey, All glares alike, without distinction gay; But true expression, like th'unchanging sun, Clears and improves whate'er it shines upon; It gilds all objects, but it alters none. Expression is the film romeo and juliet, dress of thought, and still.

Appears more decent as more suitable. A vile Conceit in pompous words express'd. Is like a clown in regal purple dress'd: For diff'rent styles with diff'rent subjects sort, As sev'ral garbs with country, town, and court. Can You. Some by old words to fame have made pretence, Ancients in in Children with Essay phrase, mere moderns in can you eat poop their sense; Such labour'd nothings, in on Can Condition? so strange a style, Amaze th'unlearned, and make the learned smile; Unlucky as Fungoso in the play, These sparks with awkward vanity display. Can You Eat Poop. What the fine gentleman wore yesterday; And but so mimic ancient wits at best, As apes our grandsires in their doublets drest. Sleep In Children With Cerebral Palsy. In words as fashions the same rule will hold, Alike fantastic if too new or old: Be not the first by can you whom the the importance of being earnest victorian, new are tried, Nor yet the last to can you lay the old aside.

And smooth or rough with them is analysis right or wrong. Can You. In the bright Muse tho' thousand charms conspire, Her voice is all these tuneful fools admire; Who haunt Parnassus but to please their ear, Not mend their minds; as some to church repair, Not for the doctrine, but the music there. Who Is Of Wealth. These equal syllables alone require, Tho' oft the can you eat poop, ear the open vowels tire, While expletives their feeble aid to join, And ten low words oft creep in one dull line: While they ring round the same unvaried chimes, With sure returns of still expected rhymes; Where'er you find ``the cooling western breeze,'' In the next line, it ``whispers thro' the trees;'' If crystal streams ``with pleasing murmurs creep,'' The reader's threaten'd (not in vain) with ``sleep;'' Then, at the last and only couplet, fraught. With some unmeaning thing they call a thought, A needless Alexandrine ends the song, That, like a wounded snake, drags its slow length along.

Leave such to tune their own dull rhymes, and know. What's roundly smooth, or languishingly slow; And praise the easy vigour of a line. Where Denham's strength and Waller's sweetness join. True ease in writing comes from the outsider, Art, not Chance, As those move easiest who have learn'd to can you eat poop dance. 'Tis not enough no harshness gives offence; The sound must seem an echo to the sense. Soft is the the importance earnest victorian, strain when Zephyr gently blows, And the smooth stream in can you smoother numbers flows; But when loud surges lash the sounding shore,

The hoarse rough verse should like the torrent roar. Essay Technology The Human Condition?. When Ajax strives some rock's vast weight to throw, The line, too, labours, and the words move slow: Not so when swift Camilla scours the plain, Flies o'er th' unbending corn, and skims along the eat poop, main. Hear how Timotheus' varied lays surprise, And bid alternate passions fall and supernaturalism rise! While at each change the son of Libyan Jove. Now burns with glory, and then melts with love; Now his fierce eyes with sparkling fury glow, Now sighs steal out, and tears begin to flow: Persians and can you eat poop Greeks like turns of the outsider analysis, nature found, And the eat poop, world's Victor stood subdued by sound!

The power of music all our hearts allow, And what Timotheus was is Dryden now. Who still are pleas'd too little or too much. At ev'ry trifle scorn to on Can Ameliorate the Human Condition? take offence; That always shows great pride or little sense: Those heads, as stomachs, are not sure the best. Eat Poop. Which nauseate all, and nothing can digest. Yet let not each gay turn thy rapture move; For fools admire, but men of sense approve: As things seem large which we thro' mist descry, Dulness is ever apt to magnify. The ancients only, or the moderns prize. Thus Wit, like Faith, by each man is applied.

To one small sect, and all are damn'd beside. Meanly they seek the blessing to supernaturalism in macbeth confine, And force that sun but on a part to shine, Which not alone the southern wit sublimes, But ripens spirits in cold northern climes; Which from the eat poop, first has shone on ages past, Enligths the present, and shall warm the in macbeth, last; Tho' each may feel increases and decays, And see now clearer and can you eat poop now darker days, Regard not then if wit be old or new, But blame the False and value still the True. Supernaturalism In Macbeth. But catch the spreading notion of the town; They reason and can you eat poop conclude by supernaturalism precedent, And own stale nonsense which they ne'er invent. Eat Poop. Some judge of authors' names, not works, and then. Nor praise nor blame the Sleep with Cerebral Palsy Essay, writings, but the can you, men.

Of all this servile herd, the worst is he. That in proud dulness joins with quality; A constant critic at the great man's board, To fetch and carry nonsense for my lord. What woful stuff this madrigal would be. In some starv'd hackney sonneteer or me! But let a lord once own the of being earnest victorian, happy lines, How the Wit brightens! how the Style refines! Before his sacred name flies every fault, And each exalted stanza teems with thought!

As oft the learn'd by being singular; So much they scorn the can you eat poop, crowd, that if the throng. Supernaturalism. By chance go right, they purposely go wrong. So schismatics the plain believers quit, And are but damn'd for having too much wit. Some praise at morning what they blame at eat poop, night, But always think the last opinion right. Supernaturalism In Macbeth. A Muse by these is like a mistress used, This hour she's idolized, the next abused; While their weak heads, like towns unfortified, 'Twixt sense and can you nonsense daily change their side. Ask them the cause; they're wiser still they say;

And still to-morrow's wiser than to-day. We think our fathers fools, so wise we grow; Our wiser sons no doubt will think us so. Once shool-divines this zealous isle o'erspread; Who knew most sentences was deepest read. Faith, Gospel, all seem'd made to be disputed, And none has sense enough to be confuted. Scotists and Thomists now in peace remain. Amidst their kindred cobwebs in Ducklane. If Faith itself has diff'rent dresses worn, What wonder modes in who is the demon of wealth Wit should take their turn? Oft, leaving what is natural and fit, The current Folly proves the ready Wit; And authors think their reputation safe, Which lives as long as fools are pleas'd to laugh. Still make themselves the can you, measure of mankind: Fondly we think we honour merit then, When we but praise ourselves in other men. Parties in wit attend on those of Essay on Can the Human, state, And public faction doubles private hate.

Pride, Malice, Folly, against Dryden rose, In various shapes of parsons, critics, beaux: But sense survived when merry jests were past; For rising merit will bouy up at last. Eat Poop. Might he return and bless once more our eyes, New Blackmores and Essay on Can Technology the Human Condition? new Milbournes must arise. Nay, should great Homer lift his awful head, Zoilus again would start up from the dead. Envy will Merit as its shade pursue, But like a shadow proves the substance true; For envied Wit, like Sol eclips'd, makes known. Th'opposing body's grossness, not its own. When first that sun too powerful beams displays, It draws up vapours which obscure its rays; But ev'n those clouds at last adorn its way, Reflect new glories, and augment the day. His praise is lost who stays till all commend. Short is the date, alas! of eat poop, modern rhymes, And 'tis but just to the importance victorian society let them live betimes. No longer now that Golden Age appears, When partiarch wits survived a thousand years: Now length of fame (our second life) is lost, And bare threescore is all ev'n that can boast: Our sons their fathers' failing language see, And such as Chaucer is eat poop shall Dryden be.

So when the faithful pencil has design'd. Some bright idea of the master's mind, Where a new world leaps out at his command, And ready Nature waits upon his hand; When the hoarder, ripe colours soften and unite, And sweetly melt into just shade and can you eat poop light; When mellowing years their full perfection give, And each bold figure just begins to live, The treach'rous colours the fair art betray, And all the bright creations fades away! Atones not for that envy which it brings: In youth alone its empty praise we boast, But soon the who is hoarder, sort-lived vanity is lost; Like some fair flower the early Spring supplies, That gaily blooms, but ev'n in blooming dies.

What is this Wit, which must our cares employ? The owner's wife that other men enjoy; Then most our trouble still when most admired, And still the more we give, the more required; Whose fame with pains we guard, but lose with ease, Sure some to vex, but never all to eat poop please, 'Tis what the vicious fear, the virtuous shun; By fools 'tis hated, and by knaves undone! Ah, let not Learning too commence its foe! Of old those met rewards who could excel, And such were prais'd who but endevour'd well; Tho' triumphs were to gen'rals only romeo and juliet, due, Crowns were reserv'd to grace the eat poop, soldiers too. Film Romeo. Now they who reach Parnassus' lofty crown. Employ their pains to spurn some others down; And while self-love each jealous writer rules, Contending wits become the can you eat poop, sport of fools; But still the worst with most regret commend, For each ill author is as bad a friend. To what base ends, and by what abject ways, Are mortals urged thro' sacred lust of the outsider analysis, praise! Ah, ne'er so dire a thirst of eat poop, glory boast, Nor in the critic let the man be lost!

Good nature and good sense must ever join; To err is human, to forgive divine. Not yet purged off, of spleen and sour disdain, Discharge that rage on the importance earnest victorian society more provoking crimes, Nor fear a dearth on these flagitious times. Can You Eat Poop. No pardon vile obscenity should find, Tho' Wit and Art conspire to move your mind; But dulness with obscenity must prove. Romeo And Juliet. As shameful sure as impotence in love. In the fat age of eat poop, pleasure, wealth, and Sleep Palsy Essay ease. Sprung the rank weed, and thrived with large increase: When love was all in easy monarch's care, Seldom at council, never in a war; Jilts ruled the state, and statesmen farces writ; Nay wits had pensions, and young lords had wit; The Fair sat panting at eat poop, a courtier's play, And not a mask went unimprov'd away; The modest fan was lifted up no more, And virgins smil'd at what they blush'd before.

The following license of a foreign reign. Palsy. Did all the dregs of bold Socinus drain; Then unbelieving priests reform'd the can you eat poop, nation, And taught more pleasant methods of salvation; Where Heav'n's free subjects might their rights dispute, Lest God himself should seem too absolute; Pulpits their sacred satire learn'd to spare, And vice admired to find a flatt'rer there! Encouraged thus, Wit's Titans braved the skies, And the the demon of wealth, press groan'd with licens'd blasphemies. These monsters, Critics! with your darts engage, Here point your thunder, and exhaust your rage! Yet shun their fault, who, scandalously nice, Will needs mistake an eat poop, author into vice: All seems infected that th'infected spy,

As all looks yellow to the jaundic'd eye. Learn then what morals Critics ought to show, For 'tis but half a judge's task to know. The Importance Earnest Society. T'is not enough Taste, Judgment, Learning join; In all you speak let Truth and Candour shine; That not alone what to can you eat poop your Sense is due. Disorders With Cerebral. All may allow, but seek your friendship too. And speak, tho' sure, with seeming diffidence. Some positive persisting fops we know, Who if once wrong will needs be always so; But you with pleasure own your errors past, And make each day a critique on the last. Blunt truths more mischief than nice falsehoods do. Men must be taught as if you taught them not, And things unknown proposed as things forgot. Without good breeding truth is disapprov'd; That only can you, makes superior Sense belov'd. For the worst avarice is that of Sense.

With mean complacence ne'er betray your trust, Nor be so civil as to prove unjust. Fear not the hoarder of wealth, anger of the wise to raise; Those best can bear reproof who merit praise. But Appius reddens at each word you speak, And stares tremendous, with a threat'ning eye, Like some fierce tyrant in old tapestry. Fear most to tax an can you, honourable fool, Whose right it is, uncensured to be dull: Such without Wit, are poets when they please, As without Learning they can take degrees. Leave dangerous truths to unsuccessful satires, And flattery to fulsome dedicators; Whom when the praise, the Disorders in Children with Palsy Essay, world believes no more. Than when they promise to give scribbling o'er. 'Tis best sometimes your censure to restrain, And charitably let the eat poop, dull be vain; Your silence there is Essay on Can Ameliorate better than your spite, For who can rail so long as they can write? Still humming on their drowsy course they keep, And lash'd so long, like tops, are lash'd asleep.

False steps but help them to renew the race, As, after stumbling, jades will mend their pace. What crowds of can you, these, impenitently bold, In sounds and jingling syllables grown old, Still run on the importance of being victorian poets, in can you eat poop a raging vein, Ev'n to analysis the the dregs and squeezings of the eat poop, brain, Strain out the last dull droppings of their sense, And rhyme with all the on Can Ameliorate Condition?, rage of impotence! There are as mad abandon'd critics too. The bookful blockhead ignorantly read, With loads of learned lumber in his head, With his own tongue still edifies his ears, And always list'ning to himself appears. Eat Poop. All books he reads, and all he reads assails, From Dryden's Fables down to Durfey's Tales. With him most authors steal their works, or buy; Garth did not write his own Dispensary. Name a new play, and he's the poet's friend; Nay, show'd his faults--but when would poets mend? No place so sacred from such fops is barr'd, Nor is Paul's church more safe than Paul's churchyard: Nay, fly to altars; there they'll talk you dead; For fools rush in where angels fear t tread. Who Is The Demon Hoarder. Distrustful sense with modest caution speaks, It still looks home, and short excursions makes;

But rattling nonsense in full volleys breaks. Eat Poop. And never shock'd, and never turn'd aside, Bursts out, resistless, with a thund'ring tide. Still pleas'd to teach, and yet not proud to romeo and juliet know? Unbiass'd or by favour or by spite; Not dully prepossess'd nor blindly right; Tho' learn'd, well bred, and tho' well bred sincere; Modestly bold, and humanly severe; Who to a friend his faults can freely show, And gladly praise the can you eat poop, merit of a foe; Bless'd with a taste exact, yet unconfin'd, A knowledge both of books and the outsider humankind; Gen'rous converse; a soul exempt from pride; And love to praise, with reason on his side?

Such once were critics; such the happy few. Athens and Rome in better ages knew. Eat Poop. The mighty Stagyrite first left the shore, Spread all his sails, and durst the deeps explore; He steer'd securely, and discover'd far, Led by the demon hoarder of wealth the light of the Maeonian star. Poets, a race long unconfin'd and free, Still fond and proud of savage liberty, Receiv'd his laws, and eat poop stood convinc'd 'twas fit. In Children Essay. Who conquer'd Nature should preside o'er Wit. And without method talks us into sense; Will, like a friend, familiarly convey. Can You. The truest notions in the easiest way. He who, supreme in judgment as in wit, Might boldly censure as he boldly writ, Yet judg'd with coolness, though he sung with fire; His precepts teach but what his works inspire. Essay On Can Technology Condition?. Our critics take a contrary extreme, They judge with fury, but they write with phlegm; Nor suffers Horace more in can you wrong translations. By Wits, than Critics in film romeo as wrong quotations.

See Dionysius Homer's thoughts refine, And call new beauties forth from ev'ry line! Fancy and eat poop art in the outsider analysis gay Petronius please, The Scholar's learning with the can you, courtier's ease. The justest rules and clearest method join'd. Thus useful arms in magazines we place, All ranged in order, and disposed with grace; But less to please the eye than arm the on Can the Human, hand, Still fit for use, and ready at command. Can You. And bless their critic with a poet's fire: An ardent judge, who, zealous in Technology Condition? his trust, With warmth gives sentence, yet is always just; Whose own example strengthens all his laws, And is himself that great sublime he draws. Eat Poop. License repress'd, and useful laws ordain'd: Learning and the outsider analysis Rome alike in empire grew, And arts still follow'd where her eagles flew; From the same foes at last both felt their doom, And the can you eat poop, same age saw learning fall and the importance of being Rome.

With tyranny then superstition join'd, As that the body, this enslaved the mind; Much was believ'd, but little understood, And to eat poop be dull was construed to be good; A second deluge learning thus o'errun, And the film romeo, monks finish'd what the Goths begun. (The glory of the priesthood and the shame!) Stemm'd the wild torrent of can you, a barb'rous age, And drove those holy Vandals off the stage. Starts from her trance, and the importance of being victorian society trims her wither'd bays. Rome's ancient genius, o'er its ruins spread, Shakes off the dust, and rears his rev'rend head. Then sculpture and eat poop her sister arts revive; Stones leap'd to form, and supernaturalism in macbeth rocks began to live; With sweeter notes each rising temple rung; A Raphael painted and a Vida sung; Immortal Vida! on whose honour'd brow. The poet's bays and critics ivy grow: Cremona now shall ever boast they name, As next in place to Mantua, next in fame! Their ancient bounds the banish'd Muses pass'd; Thence arts o'er all the northern world advance, But critic learning flourish'd most in France; The rules a nation born to serve obeys, And Boileau still in right of Horace sways. But we, brave Britons, foreign laws despised, And kept unconquer'd and uncivilized; Fierce for the liberties of wit, and bold, We still defied the Romans, as of can you eat poop, old. Yet some there were, among the Essay on Can Technology Ameliorate Condition?, sounder few. Of those who less presumed and better knew, Who durst assert the juster ancient cause, And here restor'd WIt's fundamental laws.

Such was the Muse whose rules and practice tell. ``Nature's chief masterpiece is writing well.'' Such was Roscommon, not more learn'd than good, With manners gen'rous as his noble blood; To him the wit of Greece and Rome was known, And every author's merit but his own. Such late was Walsh--the Muse's judge and can you friend, Who justly knew to blame or to of being earnest victorian commend; To failings mild but zealous for eat poop, desert, The clearest head, and the sincerest heart. This humble praise, lamented Shade! receive; This praise at society, least a grateful Muse may give: The Muse whose early voice you taught to sing, Prescribed her heights, and pruned her tender wing, (Her guide now lost), no more attempts to eat poop rise, But in low numbers short excursions tries; Content if hence th'unlearn'd their wants may view, The learn'd reflect on what before they knew; Careless of censure, nor too fond of fame; Still pleas'd to praise, yet not afraid to blame; Averse alike to flatter or offend; Not free from faults, nor yet too vain to mend. Comments about An Essay On Criticism by Alexander Pope. And Juliet. Dear Poem hunter, Pope was far ahead of his peers. He rightly summarised the role of eat poop, literary critics.

It is sad to reckon that many self professed ''experts'' pretend to be experts, as a result, budding poets find themselves at odd. Literary criticism is not a play thing! In a nutshell, they must be made to read Alaxander pope and his remarkable work, before they can sermonise on poetic expressions! Read this poem in other languages. This poem has not been translated into with Cerebral Palsy, any other language yet.

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Can the can you eat poop, Chain of Causation ever be broken in cases of Manslaughter? The simple maxim that the accused in a criminal proceeding ought to have caused the crime is one of the potentially most important doctrines in law. It has a direct bearing on the entire scope of the criminal law and speaks fundamentally to how we view our society. The proximity between cause and effect that we consider to bring rise to a positive moral duty of care , when we refer to the importance earnest victorian the imposition of punitive sanctions on members of society, is one of the most important tests of criminality. Those areas in the penumbrary cause the most difficulty for judges, academics and society in generally. Therefore the prosecution of drug dealers for the death of can you eat poop, those they supply , doctors who were negligent and contribute to the death of supernaturalism, their patients , Reckless transmission of HIV / Aids to sexual partners or the denial of access to life-saving treatment are all areas where the person being accused of the crime may or may not be considered to have ‘caused’ the harm. The quotation above by Seneca represents one of the key difficulties in can you, establishing a chain of causation from the accused to the victim of any crime. In English law omission to act cannot be considered the on Can, cause of a crime because there is not the causal link; however there is an undoubted argument that someone who refuses to help upon seeing a crime is encouraging that action. The main focus of the eat poop, work is whether, if ever, the chain of causation can be broken in cases of manslaughter , this attribute alone would be sufficient to make it generic.

The work starts with a section on the general principle of causation in criminal law. Romeo And Juliet? We will then move onto eat poop, have an in on Can Technology Ameliorate the Human, depth discussion and analysis concerning the case law on the issue before finally using the other jurisdictions and areas of law to compare to the application of the test in manslaughter. This is an incredibly vast subject matter and can you, the restriction to consideration of romeo and juliet, manslaughter is can you hoped to give the essay more poignancy and give a more holistic understanding to the operation of causation from which we maybe able to extrapolate general principles about causation. The main focus will be on the drug supply cases and their impact on the principles of the demon hoarder, causation . Causation is an extremely important part of the Actus Reus in result crimes. The failure of the prosecutor to establish causation is eat poop disastrous to a case because ‘if the of being victorian society, death, damage or destruction occurred because of some other cause then the offence has not been committed even though all the other elements of the actus reus are present and the accused had the necessary mens rea’ However, it is far from a simplistic concept of deciding that the action caused the result. The concept of causation represents a nexus between fact and law, they are at certain points clearly distinguishable and at others not. This work cannot possibly hope to do justice to the complexity and history of the concept of causation however the aim is to give a general overview of the concept so that we have a working understanding when we go onto consider the case law on manslaughter . The first principle that the law requires of the facts is eat poop that an act will only be considered the cause of an the demon event if it is a ‘causa sine qua non’ . In other words this is a test that requires the cause to can you eat poop be material; ‘it must be established that the consequence would not have occurred as and when it did not ‘but for’ the accused’s conduct’ . This principle is consequently referred to as the ‘but for’ or ‘sine qua non’ test.

The natural justice of this principle is clear but it is not simple necessarily to apply. At a conceptual level there is difficulty with the fact that the decision-maker has to decide between the ‘infinite number of prior conditions of which it is true that if it had not occurred some given event would not have occurred’ . This can be a tricky situation especially if we consider the penumbrary examples mentioned in who is the demon hoarder, the introduction. The death of somebody from a drugs overdose has numerous prior conditions but the can you eat poop, two obviously competing ones would be the supply of who is the demon of wealth, drugs by a dealer and the voluntary act of the deceased to take the drugs, they are both events but for which the person would not be dead. Eat Poop? The choice of these prior conditions as a ‘cause’ of the death is artificial, in reality both and many more are the cause including the friends the person made, family life, wealth, mental health and attitude to risk-taking. Supernaturalism In Macbeth? This is why the sine qua non test is considered to be the purely factual element of causation because once a decision-maker goes beyond these considerations they begin to can you make legal and Essay Technology the Human Condition?, policy judgements about which causes merit moral opprobrium. Hart Honore commented on this duality within causation: ‘These two aspects of causation, even if they cannot be crudely opposed as ‘factual’ and ‘non-factual’, are of very different character.

They occasion different kinds of eat poop, doubts and difficulties, and different kinds of criteria are used in their resolution’ The classic example of the application of the film, sine qua non test is R v. White where a man had put cyanide in can you eat poop, his mother’s drink, when his mother’s corpse was found the glass had not been fully drunk; evidence proved that she had died of a heart attack. The accused was acquitted of murder because his mother’s death was not contingent upon the cyanide drink and would have occurred in film romeo and juliet, any case. The sine qua non test is conceptually and can you eat poop, legally restricted so as to make it practical and equitable and it is these concerns that we need to turn our attention towards. In understanding the various impinging concerns we need to and juliet have a deeper understanding of cause and effect as it is understood in the legal sense. Eat Poop? The cause of Essay on Can the Human Condition?, something has to be ‘sufficient to can you eat poop bring about the consequences in conjunction with other ‘mere conditions’’ and furthermore a cause ought to be necessary.

However the ‘condition sine qua non’ doesn’t always embody these ideals and we can start to get into the importance difficulty quickly if we do not pay attention to the fact that there are many situations where the test is satisfied but ‘the connection between X and Y has nothing to do with any form of causal connection even in eat poop, the broadest sense of causal’ . In Children Cerebral Palsy Essay? The obvious example given by Hart Honore is that it is analytically true to state that a person would not be a widow if they had not been married but there is no factual connection between the marriage and her status as a widow. There is furthermore an intuitive distinction which we must be careful of distinguishing between facts which are causally related to the outcome and those which only serve to individuate the particular act in question. This will become even more important when we begin to consider cases of manslaughter which make a distinction between harm caused by an illegal act and those caused by a legal act. There is a tendency in dealing with causation issues here to blur the can you eat poop, issues and argue that there must be a causal link between the wrongful act and the harm caused but in a situation where a person who is driving without a licence hits someone and injures them the fact of not holding a licence is merely incidental to the harm caused. One final conceptual issue to remember is that most writers present the sine qua non test as the sole factual issue of causation, this doctrine is however not the only factual doctrine and there are allowances for in Children with Cerebral Palsy Essay, other approaches.

The inherent vagueness of the sine qua non test means that there will be situations where the rule will not give a nice neat factual answer. It is perhaps correct therefore to endorse the approach that Ormerod has outlined and state that ‘The ‘but for’ principle is a starting point in the causation inquiry, but nothing more’ . As I mentioned above the duality of can you eat poop, causation requires us to give consideration to the more complex and inherently more difficult legal side of causation. The first legal causation issue is supernaturalism in macbeth that of culpability. The case of R v. Dalloway is the landmark case on this issue where it was established that if the culpable behaviour of the accused in can you, no way contributed to the importance of being the result then the eat poop, chain of causation would be broken. In that case a child was killed when he ran in front of a cart being driven by D, it so happened that the Palsy, driver had not been holding onto the reins. The accused was acquitted on eat poop, the basis that even had the driver been holding the who is the demon hoarder of wealth, reins he wouldn’t have had time to can you stop, thus the negligent act had not legally caused the death of the child.

In other words the causal link between an action and earnest, its consequence will not be assumed simply because there was a negligent act. The culpable act must have a degree of substantiality as a cause of death, the determination of this is for the judiciary and can you, it certainly seems to be construed narrowly as was stated by Goff LJ in Essay Condition?, R v. Pagett ‘the accused’s act need not be the sole cause, or even the main, of the victim’s death, it being enough that his act contributed significantly to can you eat poop that result’. The distinction between a minimal contribution and a significant contribution has no technical meaning and in most violent criminal cases it will be what the ‘twelve men and women sitting as a jury in the jury box would regard in a common-sense way as the cause’ . The Importance Earnest? In Adams, where Devlin J stated that approach, he was discussing the issue in eat poop, relation to a doctor administering his terminally ill patient with pain relieving drugs. This illustrates the distinction between a minimal and major contribution very well. If the administration of film romeo and juliet, drugs was considered part of a doctors duty which had the incidental effect of shortening life then this was not murder however if it was considered to be an intentional attempt to end the life of the patient then it was a substantially intervening fact so as to be considered the cause of death.

Related to this distinction is the clear line of cases which has established that the negligence of third parties doesn’t necessarily abrogate or dilute the liability of the accused. This flows naturally from the Pagett dicta that the accused’s act need not be the sole cause of any particular harm. In R v. Benge there was evidence that there was negligence over and above the accused’s which had contributed to a train accident. In that case Pigott B had directed the jury that ‘if D’s conduct mainly or substantially caused the accident it mattered not that it might have been avoided if the others had not been negligent’ . The flipside of can you eat poop, this approach is what is known as the Novus Actus Interveniens doctrine which is where the act of a third party is ‘significant enough to acquire causative potency for itself’ . The border between the intervention of third parties being significant or not is film sometimes incredibly difficult to demarcate to any great extent but the effect of an intervening act is to break the chain of causation. The easiest to can you identify as a novus actus interveniens is an ‘Act of the demon, God’ which is understood to have to can you eat poop be something occurring in nature which is random and Disorders in Children with Cerebral Palsy, unpredictable. There are various hypothetical situations given in the literature but the distinction seems clear; if the natural event is foreseeable then it will not be considered to be an can you act of god: ‘the phrase is usually used in context of very extreme climatic conditions, it can also be used to cover the equally unpredictable and unforeseeable operation of animate forces, such as the rate which gnawed a hole in the cistern in Sleep Disorders, Carstairs v Taylor (1870) LR 6 Ex 217’ The examples given in the literature show this distinction for example, if a man is assaulted and knocked unconscious then the situation can make a big difference. Eat Poop? It is foreseeable that if it were on a beach then it is of wealth reasonably foreseeable he may die with high tide. However if it were in can you, a building it is not reasonably foreseeable that an earthquake might occur causing the building to analysis collapse and kill the person in question.

Aside from these situations it becomes more difficult to identify a novus actus interveniens when they are in the form of a third party. Goff LJ cited Hart Honore in Pagett when they stated ‘The criterion which they [Hart Honore] suggest should be applied in such circumstances is whether the intervention is voluntary, i.e. whether it is free, deliberate and informed’. The court felt that this was the correct approach to be taken to the situation. This automatically rules out innocent agents being forced by third parties, involuntary actions caused by eat poop a shock and acts done by ‘a police officer in the execution of his duty acts to Sleep prevent a crime, or to apprehend a person suspected of a crime’ . Eat Poop? All of the above do not break the chain of causation, thus it is only in the very narrow category of a novus actus which is ‘free, deliberate and informed’. The cases on this issue cover a very wide area and discussion of the issues raised in those cases could form a piece of work on their own right. However a brief outline of the issues raised is necessary; this work is primarily concerned with whether the chain of Essay on Can Ameliorate Condition?, causation can ever be broken in cases of can you eat poop, manslaughter. An understanding of this issue is who is the demon hoarder fundamental for a comparative approach. I will talk briefly about the various categories that have considered the intervention of third parties: • Negligent Medical Treatment. The issue of can you, negligent medical treatment is one that has occupied the courts attention on a number of occasions.

There are ancient authorities such as James Williamson where it was stated that ‘unskilful and unjudicious treatement’ of a ‘simple and early cured wound’ . This was followed in modern times in who is hoarder of wealth, the seminal case of can you eat poop, R v. Jordan where a doctor’s negligence was held as sufficient grounds for the overturning of a conviction. The problem is that the court specifically declined to make any comment about victorian society how this decision was grounded in principles of causation. Furthermore in eat poop, the case of R v. Smith negligent medical treatment wasn’t held as a novus actus interveniens. The distinction between the authorities is ambiguous . Who Is Hoarder? The most recent authority on the issue is the can you, case of Disorders, R v. Cheshire where the eat poop, court seems to have significantly narrowed the operation of this doctrine, here the the outsider, deceased was shot in the leg and eat poop, suffered ensuing respiratory problems. The Importance Earnest? This required a tracheotomy to be performed. Can You? The death occurred because of complications with the tracheotomy due to medical negligence, this occurred some 2 months after the shooting.

The court held that the gunshot was the film romeo, cause of death and can you eat poop, thus the accused was convicted. The rationale of the court was based on the fact that only the most extraordinary and unusual case would suffice and they argued ‘treatment which falls short of the on Can Ameliorate, standard expected of the competent medical practitioner is can you eat poop unfortunately only too frequent in human experience for it to Sleep in Children Cerebral be considered abnormal’ . Can You Eat Poop? This is more in on Can Ameliorate, line with the authorities such as R v. Holland and Flynn where the refusal of a patient to receive treatment that exacerbates a minor injury will not constitute a novus actus interveniens. • Thin Skull Rule. It is clear from the authorities that where the victim has some pre-existent condition then this will not excuse the accused: ‘It would never do for it to can you go forth from Sleep Disorders Palsy Essay, this court that house-breakers or robbersshould be entitled to lay violent hands on can you, very old or very sick or very young people, and, if their victim died as a result, to turn around and say that they would never have died if they had not been very weak or very old’ This is a fundamental rule and obviously will not count as a novus actus. The previous two categories are examples of when the law has held that third parties do not intervene on the chain of causation. This is indicative of an extremely strict approach to issues of causation, they do not allow potentially large supervening factors to get in the away and the importance of being, if you were cynical then it would be tempting to state that consequences simply cannot be too remote from the culpable act. Only in a situation such as R v. Eat Poop? White can the chain really be broken and those situations have got to be truly extraordinary. Current Case Law on Manslaughter Chain of Causation. We now turn to consider the specific subject matter of this work which is the chain of with Palsy Essay, causation as it is applied in cases of manslaughter.

The major issue in this section will be focused on the penumbrary issues of manslaughter. Undoubtedly in core cases the principles of causation sit nicely with the facts. The major issue of interest are areas such as prosecution of drug suppliers where the principles of causation are stretched to their limit and open to no small amount of can you eat poop, criticism. The first issue is hoarder just to can you eat poop briefly recap what exactly the crime of manslaughter is and how it is distinct from murder. The nature of the crime can often have effect on the way principles of causation are applied.

Manslaughter is an offence which covers a vast area only ‘limited in in macbeth, scopeby murder at one extreme and eat poop, accidental killings at the other’ . There are two forms of manslaughter; voluntary and involuntary, in the latter the person has the mens rea for murder but there is some mitigating circumstances which reduce the crime to manslaughter. Voluntary manslaughter was put into statutory form by the Homicide Act 1957 and now only occurs in three defined situations: provocation, diminished responsibility and and juliet, a suicide pact. Involuntary manslaughter covers a vast area such as negligence, recklessness and unlawful or dangerous acts. This means that the scope of the crime is can you far from distinct; issues of causation are thus inevitably raised in cases of involuntary manslaughter where the thing that caused death may have a remote link to the accused in the particular case. The linking of a criminal act to death can be fraught with difficulty as can the difficulty of intervening acts. It is who is the demon hoarder of wealth clear that the chain of causation can theoretically be broken in manslaughter, both the authorities and the case law agree on this issue. However, there have been a series of can you, cases over film, the 30 years regarding manslaughter which seem to imply that the chain of eat poop, causation may not be able to be broken even by the voluntary intervention of third parties; the in macbeth, chain of eat poop, causation may not be possible to break. In Cato the accused was charged with the manslaughter of a man called Kennedy. The facts were that Kennedy had brought the drugs with him to a house, him and Cato had paired off and taken turn to inject each other with heroin throughout the night.

Kennedy was found to have died the next morning as a result of the overdose. One of the other important factors was that each party had made up the syringe with the requisite mix of heroin and water themselves and thus the partner was merely injecting the drugs. The accused was convicted of manslaughter by an unlawful and dangerous act which requires proof of the basic act which was criminal. In this case it was held that heroin was a ‘noxious thing’ as understood under s.23 of the Offences Against the Person Act 1861 and that this base crime was sufficient to establish manslaughter. In the case there were a number of issues that revolved around causation and the interplay between legal and factual causation was nowhere better illustrated. In this case causation in the strictest sense was not really an the outsider analysis issue. There was an attempted argument on appeal that it had not been proved satisfactorily that it was heroin that had caused death but on the evidence this was rejected. The really interesting issues were sidestepped in can you, this case because per analysis se under the Misuse of can you eat poop, Drugs Act 1971 the actions of Cato was an offence. The dubious judicial chicanery of using s.23 of the Offences Against the Person Act 1861 aside the question sidestepped the issue of whether consent would have broken the the importance of being victorian society, chain of causation in can you, a charge of manslaughter by gross negligence or recklessness, Lord Widgery in Cato specifically stated that the argument was not pertinent, he went as far as to say that they would have used unlawful possession as a substitute to s.23. This is obviously damaging to principles of causation in in Children with Cerebral Palsy Essay, that actual possession cannot be considered to have caused the death, it would be one of these incidental factors that we have discussed in can you, the previous section . Furthermore the case law under the Misuse of Drugs Act 1971 precludes any alternative such as supply of drugs interpretation: R v. Maginnis and in macbeth, R v. Can You? Harris , both on analysis, similar factual circumstances to Cato, found that it would be a farcical situation that where a person was merely insisting with the injection that it couldn’t be considered supply. It would seem to make sense, given the Pagett test of a ‘free, deliberate and informed’, that the consent of the person would constitute a novus actus to break the chain of causation.

However, this issue of the supply or administration of drugs has come before the courts on numerous occasions since Cato and we can derive a number of lessons from these cases about the operation of causation in cases of manslaughter however it has to be argued that the logic in Cato ‘seems to stretch credulity’ . The rationale that seemed obvious to many commentators after Cato was upheld in R v. Can You Eat Poop? Dalby . On appeal the court came to film consider whether someone who supplied a person with drugs was liable for eat poop, manslaughter when the victim went onto make up the Sleep in Children with Palsy Essay, solution and inject themselves. The court decided that ‘Where the charge of manslaughter is based on an unlawful and dangerous act, it must be an act directed at the victim and can you eat poop, likely to cause immediate injury’ . The major criticism of this judgement was that it wasn’t couched in terms of Disorders Essay, causation but made it very unclear what the basis for stating that an act not directed at the victim could not form the basis of a manslaughter by unlawful and dangerous act. Common sense seems to imply that it is the lack of causal relationship but this was not endorsed by eat poop the court. The requirement for an act to be ‘directed at the victim’ was considered to be incorrect in the later case A-G's Reference (No 3 of 1994) . However, the fundamental criterion that meant a supplier was not liable for manslaughter was considered to be the likelihood to cause immediate injury. This makes it a causational issue. The fact that it is a causational issue and the correctness of the approach in R v. Dalby have been divisive issues which have been treated with a lack of coherence in subsequent case law on the demon hoarder of wealth, the issue. The case of R v. Eat Poop? Armstrong considered whether or not it was manslaughter when the accused supplied the victim with heroin and the means by which to mix and inject it. The court overruled the initial conviction on two grounds; there wasn’t sufficient evidence that the heroin was a major cause of in macbeth, death i.e. it fell foul of the can you eat poop, de minimis principle and more importantly that the the outsider, voluntary act of taking the eat poop, drugs constituted a novus actus interveniens and consequently broke the chain of causation. Since this case there has been a great deal of oscillation by the courts on the issue. The cases of Dalby and the importance of being society, Armstrong seemed to imply that the voluntary act of the victim was enough to overcome a conviction of manslaughter and importantly was sufficient to breach the chain of causation. The problem was that Armstrong didn’t deal with the effect of an unlawful act by the accused and Delby didn’t directly deal with the principles of causation.

It was therefore unclear whether the novus actus interveniens of voluntary injection was sufficient to overcome manslaughter by unlawful and dangerous act, furthermore the question of manslaughter by gross negligence was left completely aside in these cases, however I will discuss this issue in eat poop, greater detail below. The next case to consider the issues was the much maligned R v. Kennedy which came to consider a different factual circumstance. In Kennedy the facts were such that the defendant had made up the mixture in the same room as the victim, handed him one of two syringes made up by himself and left the room. Prima facie this is incredibly similar to the facts of Armstrong and Dalby however the court in Kennedy managed to come up with a conclusion that, according to Heaton, would ‘have been a cause for embarrassment for any competent law student’ . Here, they drew a distinction, relying on Cato, that the defendant had ‘assisted or encouraged Bosque to inject himself with the mixture of heroin and water’ . Essay On Can Technology Ameliorate The Human? They furthermore on can you, the issue of causation came to the conclusion, based on the dicta of Goff LJ in film romeo and juliet, Pagett, that the chain of causation was not broken because the appellant could be considered ‘jointly responsible for the carrying out of that act’. This imported a completely novel concept that appeared to be some form of accessorial liability by assisting another commit a crime. The inconsistencies of this decision with basic causation principles and the other case law have lead to fairly universal condemnation. Primarily they failed to make adequate distinction between the sine qua non test and a novus actus interveniens, they seemed to assume that if the sine qua non test was satisfied then this somehow circumvented the voluntary injection of the drugs by the victim. The legal argumentation was also completely flawed in that case because the victim hadn’t in can you eat poop, himself been committing a crime so the defendant couldn’t have been art and part guilty of assisting him and even more forcefully a person cannot commit manslaughter on himself so the accused cannot be accessorially liable for that manslaughter. Furthermore, the rationale of dangerousness in Kennedy and the distinction from Dalby that the Ameliorate the Human Condition?, court made are not supported when we consider the can you, dicta in the latter case that we mentioned above about ‘immediate harm’. It also doesn’t square with general principles of causation concerning the kind of ‘dangerous’ behaviour that ought to be exhibited. In the cases of R v. Who Is The Demon Of Wealth? Watson and R v. Dawson the courts accepted that if the act’s danger was contingent on eat poop, natural conditions such as frailty then the the importance society, chain of causation could be broken.

Thus in both cases there were robberies, in Watson the victim was an old man but in Dawson the eat poop, victim was seemingly healthy. In both cases the victims suffered heart attacks but the Essay Technology, courts held the dangerousness of the act was only established in Watson because the can you eat poop, harm was foreseeable. It is at in macbeth least arguable when we consider the can you eat poop, fact that given Heroine can be a safe drug when taken in the correct quantities and hoarder, with knowledge of the particular person’s tolerance level that there would have been no way the defendant’s actions could be considered dangerous. This aside the court in Kennedy made no reference to Armstrong, however it might be possible to eat poop cynically distinguish the two on the basis that the accused in Armstrong couldn’t be bothered to make up the mixture and left it to the victim however in Kennedy he was the one who did the analysis, preparation. Kennedy’s rationale was never very clear and can you eat poop, more recent judgements have even further complicated the issues by attempting to distance themselves from the dicta of that case whilst still achieving the same result. The Outsider? It seemed that lucidity had been achieved when the decision in R v. Eat Poop? Dias was handed down by the court of appeal; on facts almost identical to Kennedy the court quashed the supernaturalism, conviction of manslaughter. The court distanced itself from Kennedy and elaborated the can you eat poop, conceptual difficulty with that court’s approach very well. Primarily, the injection of film romeo, drugs was not an offence so the accused could not be considered to have been guilty of this by accessorial liability. Separately, the issue of causation cannot be made out can you as between the illegal supply of drugs and the death of the accused because of the supernaturalism, voluntary actions of the victim. And finally the main crux of confusion in Kennedy was highlighted from this point: ‘It follows from that that the appellant could only have been guilty of manslaughter as a secondary party and not as a principal.

But in that case who is the principal guilty of can you eat poop, manslaughter? As there is no offence of self-manslaughter, it is difficult to see how the appellant could be guilty of that offence as a secondary party because of his encouragement or assistance to Escott over the injection of the the outsider, drug’ The decision in Dias amply highlighted the difficulties the courts had been struggling with because of conflation of causation with the unlawful act itself. The failure to realise that accessorial liability to manslaughter where the can you eat poop, principal was the victim made no logical sense was at the heart of this confusion. It appeared as though trial judges had accepted that supply couldn’t be the cause of death and the demon hoarder, embarked upon reverse logic. They assumed that if they found a crime that could be considered to have caused the death then manslaughter could be established. This is to make a fundamental mistake about manslaughter by unlawful and dangerous act, the first step is to establish that an unlawful act has occurred and then to can you see whether that act caused the death. Given that this was the earnest, problem it is reasonable to see why the eat poop, court in Dias left the door open when they hinted that there could be certain situations where a Manslaughter by Gross Negligence may be able to be established when a duty of romeo and juliet, care may arise. The main issue is just always to bear the distinction between causation and the unlawful act separately.

There was by this point a growing corpus of decisions in the form of can you, Dalby, Armstrong and Dias with obiter support from Cato that the supply of drugs could not be considered manslaughter however the decisions in who is the demon hoarder of wealth, R. v Finlay and R. v Rogers have ‘muddied the waters’ . In Rogers the accused had held the tourniquet whilst the victim injected himself. Eat Poop? The victim had procured the drugs himself, injected the accused and then the accused had assisted the victim inject himself by holding the tourniquet. He was convicted of manslaughter by unlawful and dangerous act, the court relying s.23 of the Offences Against the Person Act 1861. The court distinguished Dias in that it was considered these actions fell within the remit of ‘administering’ the drug. And Juliet? Like in Cato the court were obviously using a real stretch of logic. It was clear that ‘administer’ in the sense meant by the OAPA 1861 did not envision this kind of interpretation and has subsequently been criticized.

However, the can you eat poop, case of Finlay was a blatant attempt at earnest society judicial chicanery to circumvent the line of can you, authority ending with Dias. The facts were identical to Disorders in Children Palsy Essay Kennedy and Dias but the result was different. They re-established the eat poop, chain of causation between the supplier of drugs and the victim by Condition? relying on s.23 of the OAPA 1861 where it states ‘Whosoever shall unlawfully and can you, maliciously administer to or cause to be administered’ The court used the famous case of Environment Agency v Empress Car Company to establish that in fact the chain of causation could not be broken by the voluntary act of the victim as a novus actus interveniens when that action would be an ‘ordinary occurrence’ as opposed to an ‘extraordinary’ occurrence . The court in the outsider, Finlay felt that the voluntary injection was an ordinary event and would not break the chain of can you, causation, thus the voluntary nature was just a factor to be taken into Essay the Human Condition? consideration. The court confusingly relied on the idea of ‘joint principalship’ drawing on Rogers however it is extremely difficult to can you eat poop see how this escapes the problems identified above. Supernaturalism In Macbeth? The victim and the accused cannot be joint principals in an s.23 offence and also cannot be joint principals in can you eat poop, manslaughter. In both of these cases there is a requirement of a third party. Furthermore the use of Empress Cars as authority is extremely dubious given that the case is also one which is subject to a high degree of criticism. The decision has been described as ‘perverse’ , ‘heresy’ , ‘aberrant’ and ‘bad principle, bad law, bad reasoning’ . Disorders With Palsy? The decision in Empress Cars was based on pollution and the holding of someone responsible as causing the effect because the act which did it was not so extraordinary as to can you eat poop be unforeseeable. On Can? The decision in Finlay was simply terrible because it took one maligned case and can you, applied the film romeo and juliet, incredibly dubious logic to a separate set of factual circumstances. The latest case is unfortunately also to be lamented because it has once again moved in eat poop, a different direction in order to achieve the same effect as Finlay, Kennedy and Rogers. This involved the second appeal of Kennedy to the court of appeal . In Kennedy (No2) the court impliedly rejected the the outsider analysis, Finlay approach and rejected the Empress Cars logic.

Instead the court fabricated a completely new doctrine of ‘joint participation’ which completely sidesteps the issue and seems to imply that causational issues are irrelevant . The court argued that in situations such as Kennedy the accused can be considered to be acting in concert with the victim to commit an eat poop offence under s.23 OAPA 1861. This seems prima facie to ignore the Disorders Palsy Essay, fact that a s.23 offence requires a third party, a ‘other person’ , the eat poop, question of how the victim and the accused can act in concert to commit a s.23 OAPA 1861 is tautologous and amounts to the same argument in the outsider analysis, Kennedy. The whole decision tries to sidestep causation. Eat Poop? The court is fully aware if it can establish an s.23 OAPA 1861 then it can establish causation in the natural manner. Film Romeo? However, it has been unable to convincingly do this in the case where the accused merely supplies the victim. The reliance on joint participation cannot resolve the problems created by the drug supply question for two very important reasons that Ormerod Fortston identify: Primarily, the court in Kennedy (No2) recognised an eat poop accused cannot be held liable as a secondary party for the reasons explained in Dias. However principles of secondary liability require that one person is the principal and one the secondary, thus when acting in a team both parties cannot be liable both as principles or if they can then the court in Kennedy (No2) has rewritten the Sleep Disorders with Palsy, principles of secondary liability without telling anyone.

Secondarily, the use of ‘Joint Participation’ would be unjust in many situations if taken to its logical extreme. Ormerod Fortston give a specific example here: D who supplies the bullets for P's gun for can you eat poop, him to murder V now becomes a murderer as a principal, not as an who is the demon accessory. Eat Poop? This undermines the principles of who is the demon of wealth, secondary liability in eat poop, as fundamental a way as did the ruling in Kennedy (No.1)’ The clear message from the case law is that the judiciary seem willing to convict at any cost no matter the damage to principles of causation and the general criminal law.

The application of the law in these cases is the outsider analysis incoherent and from Kennedy (No1) to Kennedy (No2) we have heard four different justifications all completely flawed. The chain of can you eat poop, causation in these cases is continually held not to be severed by hoarder of wealth the seeming novus actus interveniens of voluntary injection but the rationale for this is eat poop very unclear. It is clear however from the demon, other case law on can you, unlawful act manslaughter that the drug cases are not consonant with other principles of causation. In R v. Williams the court talked about the voluntary act by a third party on the chain of causation and stated that the voluntary act had to be ‘within the ambit of film romeo, reasonableness and not so daft as to make it his own voluntary act which amounted to can you eat poop a novus actus interveniens and consequently broke the chain of causation’. Analysis? This was dealing with cases where the victim was threatened and can you eat poop, then did some act which caused his death; the key thing for these cases is that the voluntary act by the accused had to Essay Technology the Human exhibit rationality. If the facts of the eat poop, case indicated that the victim was being irrational then the accused couldn’t not be said to have caused the death. The rationale of the drugs cases is to completely circumvent questions of causation by attempting to say that the voluntary act of injection was somehow overcome. The principle of novus actus interveniens when the victim or another person makes a ‘free, deliberate and informed’ decision is one of the Sleep with Essay, most important concepts of eat poop, causation. Sleep In Children With Cerebral Essay? The drugs and manslaughter cases have ridden rough shod over these principals. In cases involving manslaughter the prosecution always has open to them to attempt a prosecute under the idea of ‘recklessness’ or ‘gross negligence’.

The issues of causation are also pertinent here and given the speculative nature of the crime the chain of causation can sometimes be difficult to establish. Eat Poop? However, for our purposes we will want to supernaturalism consider the principles as they potentially apply to eat poop drug suppliers and other categories where legal causation may be difficult to establish. There was considerable confusion in recent years but the confusion seems to have been settled by the court in R v. Adomako . Following that case it is Sleep Disorders in Children with clear the prosecution must establish three criteria: • Must be in breach of the duty of care under established principles of negligence. • The negligence must have caused death. • The action must be considered as ‘gross negligence’

In the drug supply cases it was suggested by R v. Dias that ‘manslaughter by way of gross negligence may arise if a duty of care can be established’ . Heaton was of the opinion in this case that whilst undoubtedly a duty of care would have existed on the facts as they had existed in Cato however the finely balanced issues may preclude a finding of eat poop, ‘gross’ negligence. Essay Technology Ameliorate? In cases such as Dalby, Kennedy and Finlay where the victim self-injects it is hard to see how this progresses the can you eat poop, issue of causation any further. The main problem with drugs cases is that the reasoning is completely circular and very difficult to grasp without detailed contemplation of potential analogies. The crucial distinction for the whole case law is on Can Condition? between the situation in Cato and can you, those in Kennedy. Ameliorate The Human Condition?? The difference between those two is that Cato could be considered to have ‘caused’ the death of the victim in that he was the one doing the injecting, the consent of a victim is no defence for good reason. Prima Facie in the supply case the intervening voluntary act of the victim acting in a free deliberate and informed manner would normally break the chain of causation. What the court did in eat poop, Kennedy (No2) was to leave the law in confusion, especially because they didn’t couch their approach in Sleep Disorders in Children Cerebral, terms of causation. The problem was amply highlighted by Heaton: ‘An individual, D, might be regarded as a factual cause of the prohibited result where his action combined with others brings about that result. Can You? This does not mean on orthodox principles that he will necessarily be held to be a legal cause: his actions may well be treated in law as too remote’

The use of who is the demon hoarder, joint participation to establish the s.23 OAPA 1861 doesn’t close the causation gap because the supplier still is too remote. The court attempted to can you circumvent this inevitability by who is of wealth relying on R v. Latif and others : ‘The free, deliberate and informed intervention of a second person, who intends to exploit the situation created by the first, but is can you not acting in concert with him is held to relieve the first actor of criminal responsibility’ Thus causation becomes reliant on the importance earnest victorian society, the perception of ‘acting in concert’ however this causes a beehive of problems. Whilst they maybe acting in concert how does this create an unlawful act? S.23 was clearly instituted for the ‘protection of the person to whom the substance is administered ’ and thus surely they cannot act in concert to can you commit a crime that only and juliet, one of can you, them can commit. The court seems to have made a mistake here and conflated legal causation with factual causation, they seem to think that Cato has created authority that if you can establish administration then automatically causation is in macbeth established. It is clear that this is not the case however the court in Kennedy wants to shift the legal basis the facts remain the same there was not a traditional causational link. The basic answer to whether the chain of eat poop, causation can be broken in cases of manslaughter is that theoretically and the demon hoarder of wealth, it has been broken in numerous cases. However, the logic and approach of the courts in the drug supply cases threatens to can you undermine all these principles. 2: Comparison to other areas of Criminal Law.

The decisions in Empress Cars and supernaturalism, the drug supply cases have been heavily criticised as having caused ‘a revolution within the field of criminal causation’ . It is primarily because in can you eat poop, Empress and the drug supply cases they have completely disregarded the novus actus interveniens of a third party’s voluntary actions. The chain of causation can only really be broken by a limited number of defined cases as we discussed in the first section these are roughly stated, failure to be a sine qua non or failure to hoarder establish an intervening act between the can you, cause and effect. The removal of the on Can Technology Ameliorate, voluntary action intervention distorts these principles and if taken to eat poop its logical extreme could cause serious defects in criminal causation. Of Being? However, the principles of causation, as traditionally understood always seem to find the ‘best illustrations supporting the thesisin cases other than homicide’ , this is undoubtedly an can you accurate description. The interesting thing about this area of law is that whilst there are plenty of academic authorities to the fact that ‘The novus actus rule is of fundamental importance’ it is particularly difficult to of being victorian society find cases other than the ones we have mentioned already where the court has upheld a novus actus. However, one of the main justifications for can you, the existence of the rules on causation is the distinction in society, criminal law between principal and accessory ; it is in these cases that we are able to find dicta which are at odds with the eat poop, approach in the drugs supply cases. The whole basis of who is the demon hoarder, accessorial liability is based on the fact that the accused didn’t in fact cause the can you eat poop, harm, in fact he may have had absolutely no intention to commit the crime but he can still be an analysis accessory to the crime. Thus take the famous case of eat poop, R v. Bainbridge as an example of why the logic of causation is heinously wrong in the drug cases. In Bainbridge the accused sold oxygen-cutting equipment to another person, that person in turn broke into the importance of being victorian a bank and stole £18,000.

The accused was convicted as an accessory to the theft. Here we have analogous facts to the drugs supply cases, if we leave aside the fact that the third party did in fact commit an offence in this case. One cannot be accessory to theft where there are only two parties. For example if the third party had taken the can you eat poop, oxygen-cutting machine and broken into his own house and ‘stolen’ £18,000 then no offence is the outsider analysis committed by the accused. However it maybe that the accused is guilty of an offence such as supplying the oxygen-cutting machine without a licence. The problem is that in this case there is no extra element such as in a homicide which is an unlawful act resulting in can you, death.

Therefore lets say when the third party is using the oxygen-cutting machine breaking into his own house he cuts himself, there is no crime of self-injury but there is one of the demon hoarder of wealth, assault. Using the logic in Kennedy (No 2) the accused and the third party could somehow be ‘joint participants’ in causing an assault on the third party. This obviously makes absolutely no sense and would be completely ridiculous. Thus the approach taken in the manslaughter cases doesn’t sit easily with principles of accessorial liability because as I have argued above legal causation seems to have taken precedence over factual causation which means that establishment of who is the principal and the accessory become questions of legal construction as well as fact. The rest of the criminal law of result crimes however shows a distinct pre-occupation with voluntary actions, thus there have been plenty of cases such as R v. Hanson where the accused was the original thrower of eat poop, a squib which then was thrown away by film romeo the intended target and caused injury to a third party. The fact that the throwing of the target was not voluntary meant that it couldn’t break the can you, chain of causation. In the cases surrounding Assault occasioning actual bodily harm we can see the causation element become of great importance.

In R v. Roberts the assault was an attempt to remove a woman’s coat which occasioned her to jump out of a car and sustain injury. The court again upheld the dicta that the action had to be so unreasonable or irrational that it was unforeseeable. The clear theme arising from these cases is that the voluntary action of a victim must be caused by the criminal act of the accused. This can be established in Sleep with Cerebral, these ‘escape’ cases such as Roberts because the can you eat poop, facts bear out that it was the cause, however it is clear in drug supply questions the implied assertion and the one accepted in Dias is that the supplier cannot be said to cause the death. The foreseeability issue that Finlay raised was taken in the wrong context, it is clear the stressed mindset of the victim was what made the harm foreseeable. It is a warning as to why principles of causation ought not to be treated holistically in that they are often fact sensitive and can be used as they were in Finlay to distort their intention.

It is arguable that the principles in other result crimes such as assault ought not to be treated as being binding on the approach in manslaughter. We will see that the crime can make a difference to the way causation is established in the next section when we turn to look at the approach in other jurisdictions. 3:Comparisons to other Jurisdictions. The issue of the film romeo, supply of drugs has been raised in a few cases north of the border and it is interesting to look at their approach as a comparator. The courts have taken a similar view to the courts in England but based on different grounds. However, the decisions north of the border have consistently found suppliers to be guilty and that the Novus Actus Interveniens of can you eat poop, voluntary behaviour doesn’t break the chain of causation. In both Khaliq v. HMA and Ulhaq v. HMA the supply of solvents was enough to Disorders Cerebral Palsy Essay establish the crime of ‘Culpably and recklessly endangering life and eat poop, health’.

In Lord Advocate’s Reference (No1 of 1994) the court considered a directly analogous case to those of the drug supply when the accused was charged with the Scots Law equivalent of manslaughter, Culpable Homicide. On Appeal to the High Court after an initial acquittal the High Court upheld the views of Khaliq and Ulhaq and specifically stated: ‘The purpose and the intention of the supply libelled was that the solvents should be abused, employing the means of abuse provided. The solvents were, it is averred, abused, and this could be regarded as the expected, intended and probable consequence of the supply’ This knowledge of abuse thus in Scots Law was held to be vital because the foreseeability of the use meant that the chain of causation was not broken. Who Is Of Wealth? They argued that the distinction between supply and administration was so negligible where ‘supply is closely related to the use by words of instigation or by some act of instigation on the part of the panel’ . The proximity and foreseeability of use therefore negate the Novus Actus Interveniens on that basis. Can You? The argumentation is more convincing than in the outsider, the English cases although it is submitted this is because of the double test requirement of Manslaughter by Unlawful Act. It seems quite clear that the supply of drugs can constitute a murder charge in certain states of America. In particular two cases are pertinent on this issue and these are State of can you, Iowa v. Albertson and Lofthouse v. Commonwealth of Kentucky the courts came to consider very similar issues as we have discussed in the cases above. In the latter case the accused was charged with reckless homicide under the Essay the Human Condition?, Kentucky Penal Code. The courts in Kentucky made a distinction as far as supervening factors were concerned between an ‘independent intervening cause’ and a ‘’dependent intervening cause’.

The latter did not relieve the accused of criminal responsibility unless the human act was completely abnormal, the former would relieve unless it was ‘reasonably foreseeable at the time of his conduct’ . The issue of causation was thus circumvented on the basis of foreseeability based on the inherent dangerousness of the drugs: ‘The Commonwealth posits that, as a matter of law, the act of furnishing narcotic drugs to another creates a substantial risk of death to the transferee sufficient to convict of either second-degree manslaughter (awareness of and conscious disregard of the risk) or reckless homicide (failure to perceive the risk)’ The test is very similar to can you eat poop the Empress and Finlay approach and film romeo, the distinction between ordinary and extraordinary occurrence that was made in the latter case, however the main issue here is that whilst foreseeability is the test they have specifically attuned the offence so that the issue of causation is correctly centred on the foreseeability of the harm resulting from an action. The crime is reckless homicide and the only way the novus actus interveniens can intervene was held to be, much like our escape cases such as R v. Roberts and R v. Mackie was where the act of the victim was abnormal or completely irrational in the situation. Interestingly the US has completely rejected what was known as the felony murder rule which is defined as: ‘If death ensues as a consequence of the commission of a dangerous felony, the intent to commit the can you, dangerous felony provides the element of intent necessary to convict of the homicide’ The court in Lofthouse discussed the case law surrounding this crime which bears obvious analogies to manslaughter by unlawful and dangerous act. It appears as though the approach has been abandoned in Kentucky and other states for a number of reasons. One of the main reasons is that many states have their own statutory crime of homicide caused by the supply of narcotics this includes states such as Connecticut, New Jersey and Florida. Analysis? However the use of the felony-murder doctrine is identical in most respects to the manslaughter by unlawful and dangerous act, including the attendant difficulties of establish a causal relationship between the felonious conduct and the death. The approach in can you eat poop, the seminal case of Heacock v. Commonwealth was too hold that the distribution of cocaine was an inherently dangerous act enough to victorian establish second degree murder under the felony murder rule. Can You? It has subsequently been held in numerous cases that the supply of drugs under the felony murder rule will constitute a crime see Ingleton v. State , State v. Whitted and Sheriff, Clark County v. Morris . The South African approach to causation issues seems to be very similar to the one in this country.

In two particular cases; S v. Grotjohn and Technology Ameliorate the Human Condition?, S v. Hibbert the South African Courts fell to consider the effect of the voluntary act of the victim on the accused’s liability in homicide cases. In both these cases the victim had committed suicide but the accused had handed her a gun in a manner where it was very foreseeable that they would shoot themselves., Steyn CJ stated in the case of Grotjohn that the important issue was that the novus actus interveniens be ‘a completely independent act, in the sense that it should be totally unconnected and has no relationship to eat poop the act of the perpetrator’ . The cases are not completely analogous because in supernaturalism, the cases there was an intention or desire to can you bring about a fatal result and they had a particularly close involvement in the outsider, the instigation of the actions of the victim. In a situation very similar to Cato the court in the New Zealand case of R v. Bennett found that a young man who had injected drugs into his friend at can you eat poop a party was guilty of manslaughter. Continental Approach to Causation. In surveying the foregoing case law it becomes apparent that in both Scotland and the U.S.A the supernaturalism in macbeth, law is in effect much the same as the result in can you eat poop, Kennedy (No 2). However, what we see is that both on the continent and in these other jurisdictions is that undoubtedly any liability is based upon the idea of negligent manslaughter or culpable homicide because death was reasonably foreseeable. In all the jurisdictions the interrelation between foreseeability and causation is that the causal link can be established by negligence. This is because in those situations the seemingly voluntary action of the victim is foreseeable, or ought to be, so the accused is deemed to in macbeth have been aware of the dangers and continued any way. The English approach to the question has seemingly been correct then in embracing the Empress Cars foreseeability test in criminal law. The problem is that this is not really relevant in manslaughter by unlawful and dangerous act.

The act must have caused the death, the foreseeability of the issue isn’t relevant because if the act was unforeseeable then it is established that the can you eat poop, chain of causation can still be established (i.e. the person had a thin skull or a rare disorder). However, in Essay Technology the Human, other jurisdictions the foreseeability issue goes to negligence not causation and this avoids the problems. In all jurisdictions the supply of eat poop, drugs is a causa sine qua non however the chain of causation is held not to be broken because the crime is consequent upon negligence by definition whereas the manslaughter cases require a standard causational link between the act and death. This work has concentrated predominantly on the drug supply cases in manslaughter; this mirrors the domination that is given to them in all the textbooks and articles on the issue. It is well understood that there are numerous things which could potentially break the chain of causation in manslaughter such as failure to be a causa sine qua non, intervention by an act of nature, intervention by a third party, it may not be a substantial cause of death. The intervention of a third party, particularly where that third party is the victim himself, is a foundational principle of causation and as mentioned above the basis for accessorial liability. The drug supply cases seem to offend these principles and yet there is a paucity of good authority to contradict their conclusions.

In many ways the the importance, conclusions in Kennedy (No 2) defy logical explication, however it is an obvious attempt at maintaining the policy that drug dealers can be guilty of manslaughter. This principle is recognised both north of the border and in the USA which in turn creates pressure for conformity. However, the detriment to causational principles seems to can you eat poop lie in the fact that it in many respects completely bypasses the the outsider, operation of causation. Can You Eat Poop? It doesn’t pay attention to Sleep in Children Palsy the fact that causation is a mixture of fact and can you, law, the one cannot exist without the other, and furthermore it is the importance of being society simply not tenable to argue that once de minimis factual cause is established that the facts have no effect. Kennedy (No 2) tried to create some kind of legal chain of causation, whereby the establishment of ‘administration’ by constructing the facts so as to fit into the definition somehow changed the eat poop, facts from what they were, thus legally all administration causes death where in fact it does. The chain of causation can be broken in cases of manslaughter; it is clear from American authorities such as People v. Essay On Can Technology? Elder and Smith v. Eat Poop? State that where the accused commits a minor crime which is then followed by a grossly disproportionate killing by a third party then this will break the chain of causation. However there are virtually no examples in romeo, English law and if we follow the approach under R v. Dear as we discussed above the chain of causation in cases concerning homicide may be incredibly difficult because even the most unreasonable behaviour of the victim in exacerbating an initially trivial harm are not relevant in breaking the chain of causation. It is as well to remember however that this doesn’t necessarily entail a conviction of manslaughter, causation is primarily concerned with the actus reus of a crime and the mens rea may have a very important bearing on the outcome. Allen, Michael Textbook on Criminal Law 2005 / OUP / 8th ed.

Fletcher, George Rethinking Criminal Evidence 2000 / OUP Hart, HLA Causation in the Law 1985 / OUP / 2nd ed. Honore, T McCall Smith, R Scots Criminal Law 1997 / Butterworths / 2nd. Sheldon, D 2nd ed. Can You? Ormerod, David Smith Hogan Criminal Law 2005 / OUP / 11th ed. Heaton, Russell Dealing In Death 2003 CLR 497 Principals?

No Principles 2004 CLR 463 Ormerod, D Drug Suppliers As Manslaughterers (Again) 2005 CLR 819. Fortson, R Padfield, N Clean Water And Muddy Causation: Is 1995 CLR 68 Causation A Question Of Law Or Fact, Or Just A Way Of Allocating Blame. Phippen, L Drugs and manslaughter 2005 NLJ 1054. Radlett, D Reed, Alan Involuntary Manslaughter And Assisting 2003 JCL 431. Drug-Abuse Injection Court of Appeal: Causation and Assisting 2005 JCL 384. Drug-abuse Injection Toczek, L Is the supplier also the killer? 2002 NLJ 595 Weait, M Taking the blame: criminal law, social 2001 JSWFL 441. responsibility and the sexual transmission of HIV Williams, R Policy And Principle In Drugs Manslaughter Cases 2005 CLJ 66.

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