The Food Industry Is Good At Selling Half Truths - 1480 Words

Many people have had that moment where they have stared at themselves in the mirror and felt self-conscious about their appearance or felt that they needed to change something about themselves to feel socially accepted. Physical appearance tends to influence many children, teenagers, and adults in their eating habits. More than that people have to realize that obesity does not only impact their physical appearance, but it is a health hazard. Between 1977 and 2000 Americans have doubled their intake of sugar, which has led to a global epidemic of obesity. The food industry is good at selling half-truths since they are making America an â€Å"obesogenic† environment. The sugar industry and large food companies are the prime culprits behind America’s obesity and diabetes epidemic. According to former President Bill Clinton, â€Å"We’ve got to change the way we produce and consume food.† Instead, we’re leading the way on producing the world’s dea dliest diet and exporting it to other countries. Healthy-eating activist want the government to tax sugary sodas, mandate expanded nutrition labels and restrict portion sizes (Kiener, Robert). To increase the amount of healthy people in this country, we need to take small steps. Therefore, the government should start by regulating foods with high sugar content. What is obesity? According to the Merriam-Webster dictionary, it states that the definition of obesity is, â€Å"A condition characterized by the excessive accumulation and storage of fatShow MoreRelatedIs Kroger A Wide Diversity Of Strengths For The External Environment?851 Words   |  4 Pagesvariety of goods, it gives Kroger a wide diversity of strengths for the external environment. Some of the strengths are the fact that Kroger has an online market. Customers can order jewelry, deli and bakery products, floral, and more with the click of a button. This puts them higher up on the competition list for the advanced te chnology and convenience provided to gain loyal customers. Another strength is that Kroger has stores spanning across thirty five states, which is more than half the nationRead MoreRaise Wages Not Expenses1680 Words   |  7 Pageshistory it seems that money rules and people get caught up in the dollar sign. Workers involved in the fast food business especially feel that they deserve more than the current national minimum wage of $7.25. The campaign to raise the national minimum wage to $15 is an unreachable idea. Why is it unreachable? Jason Leavitt explains in the article â€Å"In Defense of the Fast Food Industry† that â€Å"[the] real reason wages can’t go up is because they can’t.† The reason wages cannot rise that high isRead MoreEssay on Best War Ever1127 Words   |  5 PagesAmerica and World War II, the author explains and clarifies the truth about the many myths in and about the war. There are many reasons as to why the war was seen as something positive and as a â€Å"good† thing for our nation. Motives such as the media and Hollywood’s glamorization of the war, economic growth within the nation after the Great Depression, and government agenda all had part in this crazy misconception we all know as â€Å"The Good War†. Even to this day, the war and life in America during theRead MoreFood And Drug Act Of 19061565 Words   |  7 PagesEveryday you consume things may it be food, drinks, or prescription drugs. Most people will just absent mindedly intake these products subconsciously knowing that they are monitored by government organizations ensuring your safety. It has not always been that was and has progressed greatly throughout the years. although all consumer safety organizations may not be reputable, they do much more good than harm. Consumer safety is something that is extremely important to the American family, and hasRead MoreFood And Drug Act Of 19061565 Words   |  7 PagesEveryday you consume things may it be food, drinks, or prescription drugs. Most people will just absent mindedly intake these products subconsciously knowing that they are monitored by government organizations ensuring your safety. It has not always been that was and has progressed greatly throughout the years. although all consumer safety organizations may not be reputable, they do much more good than harm. Consumer safety is something that is extremely important to the American family, and hasRead MoreModern Sharecropping and Organic Farming in the African-American Community1380 Words   |  6 Pageshave food and that is difficult when famers are sometimes very far away. So, growers began taking their produce to plants where the food was processed, almost to an unrecognizable condition in many cases, and sold in cans, bags and wrappers to the people in the city who could not get fresh produce. This has helped expand the so called obesity epidemic over the past fifty years until over half of all Americans are considered overweight or obese. Another problem is that transportation of goods drivesRead MoreGenetically Modified Foods1787 Words   |  7 PagesPart 1 Genetically Modified Food ‘With genetically modified foods I believe we have reached the thin edge of the wedge, we are messing with the building blocks of life and its scary’ - Malcom Walker, Chairman and Chief Executive of Iceland Foods (Quotes from Scientists). Genetically modified organisms or GMOs are plants or animals made by splicing the gene and inserting DNA from different species of plants, animals, bacteria, and viruses. These genes would not naturally result in a cross breed.Read MoreCase Study - Selling Hope1730 Words   |  7 PagesCase study: Selling Hope Case Summary State lotteries consider as a marketing challenge. As a legal monopoly, they have no competitors which are a major aim of much advertising. The company only remain two objectives which are recruiting new players and encouraging existing player to increase their activity. To aid them in product development and advertising, marketers use variety research tools to learn people’s preferences and responses to proposed games. They also engage in target marketingRead MoreChanges And Problems Of The History Of Television Advertising1366 Words   |  6 Pagesads protect them. For instance: Adverts cannot be seen as a lie because they acknowledge truth about themselves; ads cannot manipulate as they boast about their manipulation; and ads cannot be objects to adverts as they admit their being and take themselves lightly. In addition, ads are also self-referential because in accord with ads is the increase blending of ads and culture. In result of this, the industry creates adverts which appear to enhance our lives. With this; adverts seemingly appear toRead MoreEssay on Term African Slave Trade1700 Words   |  7 Pagescent of the total were landed during a century and a half, 1701-1850. 2 I suppose one could find a similar spike in the sugar trade of the Americas, as well as the Rum exports from the colonies and the firearm exports from Europe. A variety of Opinions One conclusion that might be drawn is that, in reducing the estimated total export of slaves from about twenty million to about ten million, the harm to African societies is also reduced by half. This is obvious nonsense. nbsp;nbsp;nbsp;nbsp

Forbidden and Dangerous Love Free Essays

essay Josephine Sellberg English Mrs. Giraud 1/9/10 Forbidden and Dangerous Love The story †Pyramus and Thisbe† is about two lovers, Pyramus and Thisbe. Because their love is forbidden, they are forced to do dangerous things to satisfy it. We will write a custom essay sample on Forbidden and Dangerous Love or any similar topic only for you Order Now In the story, Pyramus and Thisbe’s parents have forbidden their love for each other. The teenagers live on either side of a wall that separates them. The two lovers one day decide that they want to be together and not have a wall between them. They decide to do a dangerous thing and sneak away from home into the dark fields. What drives the action in this story is Pyramus and Thisbe’s love that just gets stronger because it is forbidden. They take a dangerous risk when they sneak out into the wild when it’s dark and lions are around. When something is forbidden it can make it even more â€Å"attractive† and that is what happens with Pyramus and Thisbe’s love. Pyramus, â€Å"the handsomest youth† and Thisbe, â€Å"the fairest maiden† are the two lovers in the story; they want to get married, but their parents will not let them (1). One thing, however, they cannot forbid is their love for each other. In fact, their love â€Å"burned more intensely for being covered up† (1). They converse by signs and glances. Pyramus and Thisbe find a crack in the wall that separates them, allowing them to talk to each other. Amazing â€Å"what will not love discover† (1). Every night, when it is time to say farewell, the lovers are forced to â€Å"press their lips upon the wall† (1). They can never give each other a real goodnight kiss or a hug when they need one. The wall do not only separate them it separates their love. They just have to do something about it; it is just too hard for them to restrain their affection. This decision leads to dangerous plans. Danger moves the story forward due to Pyramus and Thisbe’s choices and plans. The two lovers decide to take the chance and sneak out. They were going to sneak out in the middle of the night beyond the â€Å"watchful eyes of their parents† (2) Pyramus has some knowledge of the danger because he brings a sword which he later uses to kill himself. They were going to meet in the fields the next night and be together. Thisbe is at the meeting place first and has to wait for Pyramus to come. She sees a lion and flees, and finds refuge under a rock. She drops her veil, which the lioness tosses around with her bloody mouth. When Pyramus approaches the meeting place, he sees footsteps of a lion and his lover’s bloody veil. He thinks that he has been the cause of her death and then he kills himself with the sword. As soon as Thisbe recognizes her lover she knows that she was not going to live her life without Pyramus, so she also kills herself. Pyarmus and Thisbe’s plan to sneak out ends up to be dangerous and nothing like they thought it would be like. Pyramus and Thisbe’s â€Å"forbidden love† for each other make them do dangerous things. Their love even gets stronger because of the fact that it is forbidden, and nothing can tear them apart. The story ends telling that even death cannot separate the two lovers. Pyramus and Thisbe were born to be together and that was how it was going to stay. When something is forbidden, it can be more interesting or attractive to a person. Something forbidden can make a person want to explore it even more, and take a risk just to explore it. When there is something we really want is withheld, our behavior and judgment can easily be clouded. How to cite Forbidden and Dangerous Love, Papers

Advance Issues in Accounting Ethical Practice

Question: Discuss about theAdvance Issues in Accounting for Ethical Practice. Answer: Introduction This study deals with unethical issue that is present in accounting. In this given case, a recent event had been selected in Queensland Brisbane where it is noted that red roosters are under paying their employees by the owners (Martinov-Bennie Mladenovic, 2015). In the books of accounts, the accountants are showing that the workers were paid in accordance to the standard wages rates. This give rise to an unethical issue that is present in the financial reports and biased so that the company can avoid the tax Ethical Practice that could have Adopted to Produce More Positive Outcome A seven News Investigation had revealed the fact that Red Rooster franchises have been underpaying their staff members especially who is migrant workers (Apesb.org.au. 2017). Red Rooster is a fast food chains where the young human resources have been ripped off. According to Fair Work Commission Officers, it is viewed that they had acted firmly to simultaneously raid seven of the take-away outlets on Brisbane Southside that reports that the workers were underpaid for their work (Kuan, 2014). Accounting Professional and Ethical Standard Board Limited issued APES 110 Code of Ethics for Professional Accountants (Accounting Professional and Ethical Standards Board (APESB). 2013). In this particular case, it is understood that several red roosters have been under paid by the owners but in the books, it was clearly mentioned by the accountants that they are paying the workers according to the standard wage rates (Jaber Fadda, 2016). In this case, there is unethical practices prevails in the company named as Roosters as they are involved in paying less wages to the employees and misrepresent the financial figures. The accountant involved is committing unethical practices of showing the actual standard wage rates of the employees in the financial report that is not true and leads to an ethical issues. The accountants do so to avoid tax and it leads to biasness of actions that needs to be avoided as soon as possible (Apesb.org.au. 2017). According to the fundamental principles as mentioned in the APES 110 Code of Ethics for professional accountants, it is needed for the members to comply with the given principles and these are explained under with proper justification: Integrity- An accountant should remain straightforward as well as honest in making the decisions and maintaining cordial professional and business relationships at the same time (Hossain et al., 2016). Objectivity- An accountant should not allow biasness in their action, disagreement of attention or any kind of undue power of others for overriding the specialized or industry judgments (Apesb.org.au. 2017). Professional competence and due care- An accountant need to have professional knowledge as well as ability at the level that is essential for ensuring that a client or employer receives knowledgeable qualified Services that is based upon the current expansion in performing, method and legislation where they have to act diligently by following the technical and the professional standards (Apesb.org.au. 2017). Confidentiality- An accountant should be maintaining confidentiality of information that is obtained as a result of maintaining specialized as well as trade relationships and should not make effort in disclosing the information to any of the third parties without any special authority. They cannot use the information for their individual benefit of the Member on in that case third parties (George, Jones Harvey, 2014). Professional behavior- An accountant need to fulfill with the applicable laws as well as regulations and try to avoid any achievement that discredits their occupation at any point of time. In this particular case, an accountant should be abiding by the above-mentioned fundamental principles at the time of preparing the financial report for the company named as Roosters (Apesb.org.au. 2017). Accountants should be mentioning the wage rate that is actually paid to the employees of Rooster as it is accordance with the ethical principles. As mentioned the professional competence and due care, it is essential for the accountant to mention the same figures in the financial reports. The accountant should be using their knowledge and skill where they can provide professional services to the client through use of professional standards (Freeman Evans, 2016). The ethical practices that should be adopted by the accountant of Roosters are that they should start correcting the misinterpreted figures that they had shown in the previous years as this is resulting in unethical practices (Apesb.org.au. 2017). The accountants here need to follow the principles where it is clearly mentioned that there should no manipulation of accounting figures and no hiding of data to avoid taxes and generate profits for the business. It is thereby advisable to the accountants to present the correct figures of wages that are actually paid to the workers and Roosters should not be involved in unethical practices as it will hamper the goodwill of the business in real time (Clayton Staden, 2015). Importance and Role of Ethics in Business Especially in Accounting Practices It is necessary to maintain ethical standards in business entity that has an intention to survive in the market as well as improve over the organizational competencies as well as efficiencies. In this particular case, accountants working under Roosters should be developing total efficiencies of the employees to write the actual wage rates that are paid to the employees and should not misinterpret the figures in the financial reports. The accountant should follow the ethical standards that will help business in achieving future success rates. This can be done by training as well as guiding the human resources in a way so that they build their competence in all feature of trade (Chaplin, 2016). In this time business stress upon maintaining the ethical standards in an effective way On the contrary, it is necessary to understand as well as uphold the business ethics as it help in overall business activities so the professional accountants should be abiding by the ethical standards. Ethics is a term that relates directly with the morality, integrity and honesty. Addition to that, ethics means the fundamental concepts of right human conduct that takes into consideration differentiation between right and wrong activities where the accounting professional need to follow the principles (Carey, PMonroe Shailer, 2014). The accounting profession takes up various purpose of secretarial like recording of trade events that are of monetary nature and classifying the form of profit and loss statement where the activities are performed for maintaining proper accounting ethics of accountants (Carey, 2015). Professional accountants needs to be showing ethical behavior and they needs to be impartial as well as loyal to Roosters at the time of preparing the financial reports with sincerity. In this case, the professional accountants fail to do so and misinterpret the figures but they need to correct it by following the ethical fundamental principles such as professional competence and due care (Apesb.org.au. 2017). The accounting information is extracted from the financial statements that have great value as well as significant where it can be properly relied upon. It mainly depends upon the success or failure of a business where the accountants engages in manipulating the accounting figures so that they hide the real information. It is necessary for the professional accountants of Roosters to properly present the figures and do not engage in manipulating the data to avoid tax for the business (Apesb.org.au. 2017). In this case, the accountants ha actually changed the figures of employees payment and there is difference between what is written in the pay slip and what is paid to the workers for their work. Here, it is understood that the accountants adopts unethical practices as they changed the accounting figures to avoid taxes and make profits for Roosters. It is advisable to the accountants of Roosters to abolish the previous unethical practices and engage in correcting the figures in the financial statement to bring reliability of financial information. Accounting professionals are advisable to provide with accurate information to the business authorities without changing any figures that shows less wage rate that paid is workers (Ball, Tyler, Wells, 2015). Accounting ethics needs to be applied in every single activity of process as it will help in getting complete, accurate as well as consistent information that can be obtainable to the potential users of financial declaration in the company named as Roosters (Accounting Professional and Ethical Standards Board (APESB) 2013). Conclusion From the above case, it is understood that the owner of Roosters are involved in unethical practice as they were paying less wages to their employees that was not even mentioned by the accountants, rather they are showing as per the standard wage rates. This unethical practice should be avoided by the professional accountants by following the ethical standards as mentioned in APES 110 Code of Ethics. This standard clearly mentions that professional accountants should be engage in manipulating any accounting information in the company reports at any point of time. Therefore, the unethical case can be resolved when the professional accountant of Roosters follows the professional competence and due care in their auditing activities. Reference List Accounting Professional and Ethical Standards Board (APESB). (2013). APES 110 Code of Ethics for Professional Accountants. Apesb.org.au. (2017).Accounting Professional and Ethical Standards Board. [online] Available at: https://www.apesb.org.au [Accessed 29 Apr. 2017]. Ball, F., Tyler, J., Wells, P. (2015). Is audit quality impacted by auditor relationships?. Journal of Contemporary Accounting Economics, 11(2), 166-181. Carey, P. J. (2015). External accountants business advice and SME performance. Pacific Accounting Review, 27(2), 166-188. Carey, P. J., Monroe, G. S., Shailer, G. (2014). Review of post-CLERP 9 Australian auditor independence research. Australian Accounting Review, 24(4), 370-80. Chaplin, S. (2016). Accounting Education and the Prerequisite Skills of Accounting Graduates: Are Accounting Firms Moving the Boundaries?. Australian Accounting Review. Clayton, B. M., Staden, C. J. (2015). The Impact of Social Influence Pressure on the Ethical Decision Making of Professional Accountants: Australian and New Zealand Evidence.Australian Accounting Review,25(4), 372-388. Freeman, M., Evans, E. (2016). Professional Associations, Accreditation and Higher Education: Foundations for Future Relations. Relevance And Professional Associations IN 2026. George, G., Jones, A., Harvey, J. (2014). Analysis of the language used within codes of ethical conduct.Journal of Academic and Business Ethics,8, 1. Hossain, S., Monroe, G. S., Wilson, M., Jubb, C. (2016). The Effect of Networked Clients' Economic Importance on Audit Quality. Auditing: A Journal of Practice Theory, 35(4), 79-103. Jaber, R. J., Fadda, M. M. A. (2016). Awareness Level of Professional Independence Requirements, through Assimilation of Fundamental Principles of Professional Ethics, by Jordanian CPA Auditors, in Auditing Process: Field Study. International Journal of Economics and Finance, 8(9), 11. Kuan, K. T. C. (2014). Auditor independence: an analysis of the adequacy of selected provisions in CLERP 9 (Doctoral dissertation, Queensland University of Technology). Martinov-Bennie, N., Mladenovic, R. (2015). Investigation of the impact of an ethical framework and an integrated ethics education on accounting students ethical sensitivity and judgment.Journal of Business Ethics,127(1), 189-203.

Karate Essays - Shrin-ry, Tatsuo Shimabuku, Isshin-ry,

Karate Outline Thesis Statement: Isshinryu may be the youngest karate to come from Okinawa, but it is as rich with spirit as the earlier forms. I. Background on Isshinryu founder. A. Birth date and location. B. Teachers and influence C. Creation II. Description of Emblem and patch. A. Origin B. Explanation and meaning C. Symbolism III. Kata A. Brief overview B. History C. Explanation D. Benefits IV. Ranking sytem A. Kyu ranks B. Dan ranks C. Promotion requirements Isshinryu Karate was developed and introduced in 1954 by Tatsuo Shimabuku on the island of Okinawa. His karate was the offspring of two different systems, Goju-Ryu and Shorin-Ryu. Goju-Ryu being the ?Hard? method, and Shorin-Ryu being the ?Soft? method. He introduced katas from other forms into his own form, and developed features unique to his newly created style. The ranking system, also unique to his style, was made up of 7 kyu ranks and 10 degrees of black belts. A vision Shimabuku had in a dream also played a major role in the development of his style. The vision that helped him ?mold? his karate into one form is represented on a patch presently worn on the gi?s of his followers and their students. Isshinryu may be the youngest karate to come from Okinawa, but it is as rich with spirit as the earlier forms. Shinkichi Shimabuku, founder of Isshinryu, was born on the island of Okinawa on September 19, 1908 (Armstrong 7). Upon reaching the age of six, Shimabuku would travel on foot, six miles down an old farm road to reach his uncle?s house. His uncle, Chioyu, a Shorin-ryu Master, was reluctant to teach young Shimibuku. Instead, Chioyu made him perform menial chores around the dojo. After two years of chores and six mile walks, Shimabuku developed the patients and physical condition to begin karate training. His uncle taught Shimabuku his system and started him off on his martial career. During his years of adolescence Shimabuku changes his name from Shinkichi to Tatsuo meaning ?Dragon Boy?. It was common during the 1920?s for a young boy to change his name during his adolescence years. With the motivation from his uncle, Shimabuku sought out the famous Chotoku Kyan, another Shorin-ryu master. After developing an excellent kicking ability, his next sensei was Chojin Miyagi! , known for his vigorous training habits. Miyagi teaches Shimabuku Naha-te, known today as the Goju-ryu style. His fourth teacher was a man by the name of Motobu, a famous brawler in Okinawa. Motobu furthers Shimabuku?s in Shorin-ryu and grants him the title of Master (8). Lastly, Yabiku Moden, helps polish Shimabuku?s training by teaching him the art of the Bo, Sai, and Tee-fa (9). With the teachings of some of Okinawa?s legendary teachers, Tatsuo Shimabuku sets of to begin a life in the martial arts. Late one evening at his home in Chun Village, Shimabuku was awakened by his dream of the ?Mizu-gami?, the sea goddess. With this symbol, Tatsuo realizes the unification of his training that the Mizu-gami represents. It was on that evening that Isshinryu was born (Armstrong 27). Later, his vision was produced on a patch worn by all students of Isshinryu Karate. The emblem of Isshinryu karate symbolizes the Mizu-gami. Its oval shape was originally designed to represent the unique vertical fist in Isshinryu karate. The symbol depicts a woman whose lower half appears to take the form of a sea dragon. Her left hand is held open in the universal sign of peace while her right hand forms an Isshinryu fist. In Oriental mythology, the dragon in the sky is a sign of good luck while the gray background and churning seas is a sign of unknown dangers. Three stars are located at the top of the emblem representing three virtues. These virtues consist of mind, body, and spirit whic! h all must be developed to reach total harmony (Tyurin). With this vision and sensei?s knowledge of the martial arts, he sets off to create the Isshinryu system. What would a martial arts system be without Kata? According to the Martial Arts Dictionary, by Louis Frederic, the word ?kata? is defined as Form?, ?Sequence, but there is much more to kata than form and sequence (104). To really grasp the meaning of kata, the true essence of karate, one must be involved in one or more forms of the martial arts. In the Isshinryu system there are 16 katas: 1. Seisan 9.Kusan-Ku Sai 2. Seiuchin 10. Tokomen Karate Essays - Shrin-ry, Tatsuo Shimabuku, Isshin-ry, Karate Outline Thesis Statement: Isshinryu may be the youngest karate to come from Okinawa, but it is as rich with spirit as the earlier forms. I. Background on Isshinryu founder. A. Birth date and location. B. Teachers and influence C. Creation II. Description of Emblem and patch. A. Origin B. Explanation and meaning C. Symbolism III. Kata A. Brief overview B. History C. Explanation D. Benefits IV. Ranking sytem A. Kyu ranks B. Dan ranks C. Promotion requirements Isshinryu Karate was developed and introduced in 1954 by Tatsuo Shimabuku on the island of Okinawa. His karate was the offspring of two different systems, Goju-Ryu and Shorin-Ryu. Goju-Ryu being the ?Hard? method, and Shorin-Ryu being the ?Soft? method. He introduced katas from other forms into his own form, and developed features unique to his newly created style. The ranking system, also unique to his style, was made up of 7 kyu ranks and 10 degrees of black belts. A vision Shimabuku had in a dream also played a major role in the development of his style. The vision that helped him ?mold? his karate into one form is represented on a patch presently worn on the gi?s of his followers and their students. Isshinryu may be the youngest karate to come from Okinawa, but it is as rich with spirit as the earlier forms. Shinkichi Shimabuku, founder of Isshinryu, was born on the island of Okinawa on September 19, 1908 (Armstrong 7). Upon reaching the age of six, Shimabuku would travel on foot, six miles down an old farm road to reach his uncle?s house. His uncle, Chioyu, a Shorin-ryu Master, was reluctant to teach young Shimibuku. Instead, Chioyu made him perform menial chores around the dojo. After two years of chores and six mile walks, Shimabuku developed the patients and physical condition to begin karate training. His uncle taught Shimabuku his system and started him off on his martial career. During his years of adolescence Shimabuku changes his name from Shinkichi to Tatsuo meaning ?Dragon Boy?. It was common during the 1920?s for a young boy to change his name during his adolescence years. With the motivation from his uncle, Shimabuku sought out the famous Chotoku Kyan, another Shorin-ryu master. After developing an excellent kicking ability, his next sensei was Chojin Miyagi! , known for his vigorous training habits. Miyagi teaches Shimabuku Naha-te, known today as the Goju-ryu style. His fourth teacher was a man by the name of Motobu, a famous brawler in Okinawa. Motobu furthers Shimabuku?s in Shorin-ryu and grants him the title of Master (8). Lastly, Yabiku Moden, helps polish Shimabuku?s training by teaching him the art of the Bo, Sai, and Tee-fa (9). With the teachings of some of Okinawa?s legendary teachers, Tatsuo Shimabuku sets of to begin a life in the martial arts. Late one evening at his home in Chun Village, Shimabuku was awakened by his dream of the ?Mizu-gami?, the sea goddess. With this symbol, Tatsuo realizes the unification of his training that the Mizu-gami represents. It was on that evening that Isshinryu was born (Armstrong 27). Later, his vision was produced on a patch worn by all students of Isshinryu Karate. The emblem of Isshinryu karate symbolizes the Mizu-gami. Its oval shape was originally designed to represent the unique vertical fist in Isshinryu karate. The symbol depicts a woman whose lower half appears to take the form of a sea dragon. Her left hand is held open in the universal sign of peace while her right hand forms an Isshinryu fist. In Oriental mythology, the dragon in the sky is a sign of good luck while the gray background and churning seas is a sign of unknown dangers. Three stars are located at the top of the emblem representing three virtues. These virtues consist of mind, body, and spirit whic! h all must be developed to reach total harmony (Tyurin). With this vision and sensei?s knowledge of the martial arts, he sets off to create the Isshinryu system. What would a martial arts system be without Kata? According to the Martial Arts Dictionary, by Louis Frederic, the word ?kata? is defined as Form?, ?Sequence, but there is much more to kata than form and sequence (104). To really grasp the meaning of kata, the true essence of karate, one must be involved in one or more forms of the martial arts. In the Isshinryu system there are 16 katas: 1. Seisan 9.Kusan-Ku Sai 2. Seiuchin 10. Tokomen

Israels Right to Self-Defense

Israels Right to Self-Defense Free Online Research Papers The present Article examines the legality of Israels military intervention in Lebanon in the summer of 2006 from a jus ad bellum perspective. More specifically, it examines whether Israel could lawfully invoke the right of self-defense, taking account of the factual circumstances, the justification given by Israel and the reaction of the international community. The Article focuses mainly on the controversy regarding the legality of self-defense against attacks by non-state actors. In this regard, it is noted that while the restrictions on this type of self-defense may have been eased in recent years, Israels intervention should not be considered a new precedent towards a broad right of self-defense against terrorist groups or other types of non-state actors. I. Introduction On July 12, 2006, Hezbollah militants attacked an Israeli military patrol, capturing two soldiers and killing three. Israel subsequently invoked the right of self-defense and engaged in military operations to retrieve the captured soldiers while carrying out air strikes against several targets in Lebanon, such as the Rafik Hariri International Airport in Beirut. The incident escalated in the following days, when aerial bombardments by the Israeli Defence Forces (IDF) were answered by a rainstorm of Katyusha rockets targeting Haifa and other cities in northern Israel. As the IDF crossed the Blue Line, the United Nations (U.N.)-monitored border demarcation between the two countries, Israeli troops and Hezbollah militants clashed in the worst fighting in southern Lebanon since 1982. For over a month the world held its breath until, finally, a frail ceasefire was put in place at the order of the U.N. Security Council on August 14, 2006. [FN1] In all, some 116 Israeli soldiers and 43 Isra eli civilians lost their lives between July 12, 2006 and August 14, 2006. On the Lebanese side, some 1,109 peoplemostly civilians were killed, as well as twenty-eight Lebanese soldiers. [FN2] Scores of people on both sides were injured or forced to flee their homes. The dramatic events of July and August 2006 raise important questions of jus ad bellum regarding the legality of self-defense in response to attacks by non-state actors. [FN3] Chief among these questions is whether state involvement in these attacks is needed to trigger Article 51 of the U.N. Charter, [FN4] which spells out the right of self-defense and, if so, what degree of state involvement is required. The International Court of Justice (ICJ) has addressed this question in its advisory opinion on the legality of the â€Å"Palestinian Wall† [FN5] and in its judgment in the Case Concerning Armed Activities on the Territory of the Congo (Dem. Rep. Congo v. Uganda), [FN6] but it has been notoriously unable to provide a coherent answer to this polemic, to the discontent of some of its judges. Legal scholars are highly divided on the topic, although a growing number of authors have suggested that the legal restrictions on self-defense *267 ought to be eased. [FN7] States, on the other hand, do not seem to stumble over these thorny questions. Indeed, as they did in response to the 9/11 attacks, many states supported Israels self-defense claim without further ado, notwithstanding the fact that many were critical of the disproportionate character of Israeli attacks and the heavy loss of civilian life on the Lebanese side. Against this background, the present Article assesses the merits of Israels invocation of Article 51 of the U.N. Charter. Given the fact that the initial attack emanated from Hezbollah and not from the Lebanese government, it is hard to fit Israels recourse to force into the traditional legal parameters of self-defense. We will therefore not only examine the legality of Israels actions but also their significance for the development of jus ad bellum, taking into account the reaction of the international community. I start from the widely accepted premise that custom, constituted of state practice and opinio iuris, is crucial for the determination of the scope of the legal prohibition on the use of force. [FN8] Thus, Israels state practice in the present case will be tested against the opinio iuris expressed by Israel, Lebanon and numerous other states in the debates of the U.N. Security Council. [FN9] In the end, while the *268 international community generally affirmed the applicabi lity of the right of self-defense to Israels actions, I argue that this should not be interpreted as creating a broad legal right to exercise self-defense against attacks by non-state actors. Rather, given the circumstances in Lebanon, Article 9 of the Draft Articles on State Responsibility (Draft Articles) [FN10] may provide an alternative route to legally justify Israels recourse to self-defense under Article 51, while leaving in place the need for a certain degree of state involvement in armed attacks. The present analysis does not address the legality of Israels actions under international humanitarian law, [FN11] nor does it deal with the parallel military action in the Gaza strip during the same period. Part II summarizes the events of July 12, 2006 as well as the responses of Israel, Lebanon and the wider international community. Part III examines whether the conditions for the recourse to self-defense were met and focuses in particular on the question of whether and to what extent â€Å"armed attacks† require the involvement of a state to legally justify self-defense under Article 51 of the U.N. Charter. Part IV contains concluding remarks. II. The Outbreak of Hostilities and Reaction of the International Community On the morning of July 12, 2006, Hezbollah fighters attacked an Israeli border patrol between the towns of Zarit and Shtula. [FN12] Making use of a â€Å"dead zone† in the border fence, not visible from any of the IDF outlook posts, they crossed the border and ambushed an Israeli patrol with a combination of pre-positioned explosives and anti-tank missiles. Simultaneously, Hezbollah also launched a diversionary attack, firing Katyusha rockets and mortars at Israeli military positions and border villages. The latter attack wounded five civilians. In the ambush itself, three Israeli soldiers were killed, two were wounded and two were abducted. The IDF responded with artillery fire, air strikes, and a naval bombardment. Moreover, in its first military ground operation in *269 southern Lebanon since the withdrawal of Israeli troops in 2000, the IDF summoned a mission to rescue the captured soldiers and engaged in fierce fighting with Hezbollah gunmen. Shortly after the Zarit-Shtula incident, Israeli Prime Minister Ehud Olmert made a statement in which he argued that the Hezbollah attack was â€Å"not a terrorist attack, but the action of a sovereign state that attacked Israel for no reason and without provocation.† [FN13] He pointed out that Hezbollah is a member of the Lebanese government, stressing that Lebanon was responsible for this â€Å"act of war . . . on the sovereign territory . . . of the state of Israel† and would bear the consequences of its actions. [FN14] In accordance with the reporting obligation of Article 51 of the U.N. Charter, Israel submitted a letter to the Security Council, stating that â€Å"[r]esponsibility for this belligerent act lies with the Government of Lebanon, from whose territory these acts have been launched into Israel. Responsibility also lies with the Government of the Islamic Republic of Iran and the Syrian Arab Republic, which support and embrace those who carried out this at tack.† [FN15] The statement denounced the â€Å"ineptitude and inaction† of the Government of Lebanon to exercise its jurisdiction over its own territory, despite calls thereto in several Security Council resolutions. The statement goes on to reiterate that Israel â€Å"reserves the right to . . . exercise its right of self-defense when an armed attack is launched against a Member of the United Nations.† [FN16] To this end, it would take â€Å"appropriate actions to secure the release of the kidnapped soldiers and bring an end to the shelling that terrorize[d] [its] citizens.† [FN17] The next day, however, Lebanon called for an urgent meeting of the Security Council to discuss the crisis. [FN18] Lebanon declared that it was â€Å"not aware of the events that occurred and are occurring on the international Lebanese border† and did not endorse them. [FN19] Lebanon refuted responsibility for the actions of Hezbollah and strongly condemned â€Å"the Israeli aggressions that targeted and are targeting the vital and civil Lebanese infrastructure.† [FN20] *270 Israels actions against Lebanon were only discussed in the margin during the Security Council meeting of July 13, 2006, which instead focused on the situation in the Gaza strip at the time (a draft resolution was defeated due to a United States veto). [FN21] However, the next day the Council did convene to discuss the Israeli-Lebanese situation. [FN22] During the debate it became clear that most of the fifteen Council members supported Israels invocation of self-defense in principlethe United States, Japan, the United Kingdom, Denmark, Slovakia, Greece, France, Peru, and Argentina all referred to Israels right of self-defenseeven though they refrained from speaking out on Lebanons possible responsibility for the Hezbollah attacks. Only China and Qatar identified Israels response as â€Å"armed aggression† against Lebanon. [FN23] On the other hand, most Council members also showed sympathy for the Lebanese authorities and stressed the need for the Lebanese government to ex ercise full control over all of its territory. Virtually all Council members expressed concern at the targeting of civilians and civilian infrastructure in Lebanon and called for restraint, with several countries, such as Russia and France, expressly condemning the disproportionate nature of Israels campaign. [FN24] In the following days, Israels claim continued to receive implicit and explicit support from several corners, although often in combination with deep concern at the loss of civilian life. Thus, on July 16, 2006, the Group of Eight (G8), meeting in St. Petersburg, issued a declaration acknowledging Israels right to self-defense while calling for restraint. [FN25] Two days later, the U.S. Senate adopted a resolution â€Å"[c]ondemning Hezbollah and Hamas and their state sponsors and supporting Israels exercise of its right to self-defense.† [FN26] Likewise, Australian Prime Minister John Howard affirmed that Hezbollah had forced Israel into self-defense. [FN27] Even U.N. Secretary-General Annan, albeit highly critical of Israels excessive and disproportionate use of force, acknowledged Israels right to defend itself under Article 51 of the U.N. Charter. [FN28] The open debate in the Security Council of July 21, 2006 shows a similar picture. Notwithstanding deep concern or outright condemnation of the disproportionate use of force, a majority of participants agreed as a matter of principle that Israel had the right to defend itself against the attacks by Hezbollah. [FN29] This position was held by the United States, the twenty-five *271 member states of the European Union, Japan, Russia, Canada, Australia, Norway, Switzerland, Brazil, Argentina, Peru, Guatemala, and Ghana. On the other hand, the twenty-two member League of Arab States [FN30] condemned the Israeli aggression, as did China, Iran, Cuba, and Venezuela. Other countries, such as India and Indonesia, condemned the disproportionate character of Israels action, without addressing the self-defense question. [FN31] Thus, it appears the international community steadily grew more critical of Israels use of force against Lebanon, especially after the killing of four U.N. peacekeepers in an Israeli artillery and aerial attack on July 25, 2006 [FN32] and the Qana massacre [FN33] of July 30, 2006 in which twenty-eight Lebanese civilians lost their lives. Still, a majority of states, including eleven out of fifteen Security Council members, backed the invocation of Article 51 of the U.N. Charter. [FN34] Let us now turn to the merits of the casus belli. A. Israels Self-defense Claim An examination of Israels self-defense claim can be broken down in three parts. First, we must establish whether the Zarit-Shtula incident qualifies as an â€Å"armed attack† in the sense of the U.N. Charters Article 51 ratione materiae. This means that we must assess whether Hezbollahs acts were â€Å"of such gravity† that they would qualify as an armed attack if they had been carried out by regular armed forces. Secondand this is the most difficult point to tackle from a legal perspectivewe must look into the Lebanese governments involvement in the activities of Hezbollah to verify whether the incident qualifies as an armed attack ratione personae. A third and final aspect concerns the necessity and proportionality of Israels response. A preliminary remark must be made. Several officials and media sources have questioned Israels motives in going to war against Lebanon. Some have suggested that Israel had long pre-planned its military campaign and was waiting to be provoked; others have pointed out that Israel pursued *272 wider goals than merely the return of its abducted soldiers. [FN35] Whether or not these suggestions are true is irrelevant from a jus ad bellum perspective. This follows from the Nicaragua case, where Nicaragua argued that the U.S. justification of self-defense merely served as a pretext for its contested activities. The Court rejected this argument, declaring that self-defense can be legally invoked if the appropriate conditions are met â€Å"even though there may be possibility of an additional motive, one perhaps even more decisive.† [FN36] Hence the answer: yes, self-defense may be a pretext, as long as the basic conditions are met. But were these conditions met on July 12, 2006? 1. Ratione Materiae Our first question concerns whether the â€Å"scale and effects† of the initial attack by Hezbollah were sufficient to trigger the right of self-defense. In the Nicaragua case, the ICJ famously distinguished between the â€Å"most grave† forms of the use of force from other â€Å"less grave† forms. [FN37] Only the former qualify as â€Å"armed attacks† in the sense of Article 51. This is also evident from the ICJs reference to the Definition of Aggression, [FN38] adopted by the U.N. General Assembly in 1974, which the Court used as a yardstick to determine the existence of an armed attack. [FN39] Articles 2 and 3(g) of the Definition require that armed force be of sufficient gravity to constitute aggression. [FN40] As a result, a de minimis threshold has to be reached. An armed attack must involve at least a use of force producing (or liable to produce) serious consequences, epitomized by territorial intrusions, human casualties or considerable destruction of property. [FN41] Use of force below this threshold may well trigger a states right to take countermeasures, but it does not justify recourse to self-defense. On the other hand, a single incident such as the mining of a single vessel may be sufficient to bring into play the inherent right of self-defense. [FN42] Single incidents may also be â€Å"accumulated† so as to determine whether the threshold has been reached. [FN43] In Nicaragua, the ICJ excluded â€Å"mere frontier incidents† from the concept of â€Å"armed attack.† [FN44] Many scholars criticized this distinction as *273 artificial, arguing that some â€Å"frontier incidents† may be trivial, while others may be extremely grave. [FN45] However, the concept of frontier incidents may be useful to avoid escalation of minor incidents. It does not a priori rule out the possibility that trans-border incursions could singly or collectively amount to armed attacks. The ICJ did not provide much guidance to distinguish mere frontier incidents from armed attacks, but only referred in general terms to â€Å"scale and effects† and circumstances and motivations. [FN46] The implication seems to be, as Gray notes, that â€Å"the Court would include within ‘frontier incident’ episodes where there was no intent to carry out an armed attack, including accidental incursions and incidents where officials disobeyed orders.â €  [FN47] Given this understanding, the premeditated and well-organized character of the Hezbollah ambush, the ongoing nature of the abduction, combined with diversionary rocket attacks suggest that this was a deliberate â€Å"armed attack† rather than a mere â€Å"incident.† Considering the serious consequences of the attackwhich included territorial intrusions, human casualties, and destruction of propertyone could argue that, even though it was a relatively small-scale event, the ratione materiae criterion was fulfilled. The outcome of this analysis would be different if one were to follow the alternate version of the incident, proclaimed by the Lebanese police and later by Hezbollah. According to this version, the Israeli soldiers were captured when Hezbollah attacked an Israeli commando force trying to infiltrate the village of Ayta ash-Shab, well inside Lebanese territory. [FN48] This account seems somewhat at odds with the apparently premeditated nature of Hezbollahs attac k. [FN49] All major news agencies, including Al Jazeera, as well as the European Union and the G8, have characterized the abduction as a â€Å"cross-border† attack. Likewise, the report of the United Nations Interim Force in Lebanon (UNIFIL) states that Hezbollah â€Å"crossed the Blue Line into Israel and attacked an IDF patrol,† [FN50] and Security Council Resolution 1701 speaks of â€Å"Hezbollahs attack on Israel.† [FN51] Therefore, we see that the answer to the question posed at the start of this section is that the attack by Hezbollah was sufficient to trigger the right to self-defense. *274 2. Ratione Personae The ratione personae aspect is more difficult to assess. The problem is that considerable controversy exists as to when attacks carried out by non-state actors qualify as â€Å"armed attacks† in the sense of Article 51. The text of the Article does not explicitly restrict the scope of â€Å"armed attacks† to acts of state agents, yet it has traditionally been interpreted in this way. [FN52] Thus, the U.S. Senate Foreign Relations Committee long ago declared that â€Å"the words ‘armed attack’ clearly do not mean an incident created by an irresponsible group of individuals, but rather an attack by one state upon another.† [FN53] On the other hand, literature also suggests that self-defense can be exercised against attacks by non-state actors when there is a certain degree of state involvement in the attacks, a situation which is sometimes labeled â€Å"indirect military aggression.† [FN54] In addressing this controversy, the International Court of Justice has applied the reasoning of Article 3(g) of the Definition of Aggression, which was taken to reflect customary international law. Thus, the Court extended the notion of â€Å"armed attack† to â€Å"the sending by or on behalf of a state of armed bands, groups, irregulars or mercenaries, which carry out acts of armed force against another State of such gravity as to amount to (inter alia) an actual armed attack conducted by regular forces, or its substantial involvement therein.† [FN55] Nevertheless, the application and interpretation of this phrase has become increasingly contested. This is a consequence of evolutions in state practice, recent resolutions adopted by the Security Council, and, last but not least, subsequent ICJ jurisprudence. As a result, there are currently three broad lines of reasoning. [FN56] On the one hand, some argue that self-defense can only be exercised when attacks by non-state actors can be imputed to a State in accordance with established rules on state responsibility. On the other extreme, some argue that state involvement has become irrelevant and that one should only look at the gravity of the attack to determine the appropriateness of self-defense. In between, a third position claims that state involvement remains a precondition albeit under a lower threshold than that of state responsibility. Hereafter, we will examine these positions in the context of the Israeli-Lebanese conflict. It is argued that Israels actions fail to meet th e ratione personae threshold, not only if one sticks to the general rules on state *275 responsibility, but also when a somewhat lower state involvement standard is adopted. Subsequently, an alternative route is suggested to act against states failing to prevent cross-border attacks by non-state actors by falling back on a somewhat neglected rule of state responsibility, dealing with conduct carried out in the absence or default of official authorities. i. State responsibility As mentioned above, the ICJ in the Nicaragua case used Article 3(g) of the Definition of Aggression as a yardstick for the legality of self-defense against attacks by non-state actors. This article refers to the â€Å"sending by or on behalf of a State of armed bands, groups, irregulars or mercenaries, which carry out acts of armed force against another State . . . or its substantial involvement therein.† [FN57] Although the wording â€Å"sending by or on behalf of† seems to imply agency, the additional reference to â€Å"substantial involvement therein† suggests that this yardstickwhich the Court held to be part of the primary rules of the jus ad bellumis not necessarily identical to the secondary rules concerning state responsibility, but may actually be broader. Indeed, the phrase â€Å"substantial involvement† was the result of long debates regarding the degree of state involvement needed to establish â€Å"aggression.† [FN58] Some delegations w anted to include â€Å"support,† â€Å"acquiescence,† and â€Å"encouragement of organization† of armed bands. Others wanted to reserve â€Å"aggression† to cases of â€Å"open and active participation.† [FN59] The implication of the Courts reference to Article 3(g) therefore seems to be that self-defense may go beyond situations where attacks by non-state actors are imputable to a state and also covers situations where a state is â€Å"substantially involved† in their activities. At the same time, however, the ICJ took a narrow view of such involvement and discarded the idea that â€Å"the provision of weapons or logistical or other support† could amount to an armed attack. [FN60] Although the giving of sanctuary to non-state actors did not arise on the facts in Nicaragua, it is assumed that the Court implicitly rejected that acquiescence or the inability to control armed bands operating on a states territory could constitute an arme d attack. [FN61] In the end, the Courts narrow interpretation seemed to de facto limit self-defense to attacks that are actually attributable to states. This position was heavily attacked by Judge Schwebel and Judge Jennings as well as by several scholars. Judge Jennings, for example, pointed out that, â€Å"it becomes difficult to understand what it is, short of direct attack by a states own forces, that may not be done apparently without a lawful response in the form of . . . self-defence.† [FN62] *276 If ever there was a gap between the Courts interpretation of Article 3(g) of the Definition of Aggression and the rules on state responsibility, it seems to have been closed in two recent ICJ cases. Thus, in the Palestinian Wall advisory opinion, the Court stated that Article 51 U.N. Charter recognized, â€Å"the existence of an inherent right of self-defense in the case of armed attack by one State against another State.† [FN63] Since Israel had not claimed that the attacks it suffered were in fact â€Å"imputable to a foreign state,† the right of self-defense could not be invoked to justify the building of the â€Å"Palestinian Wall.† [FN64] And in DRC v. Uganda, the Court invoked the wording of Article 3(g) Definition of Aggression, albeit dropping the reference to â€Å"substantial involvement.† [FN65] The Court seemed to follow the view that the deplorable attacks against Uganda by armed groups acting from Congolese territory were due to the Demo cratic Republic of the Congos (DRC) inability to control events along its border and concluded that the attacks were â€Å"not attributable† to the DRC. Given the absence of state responsibility, the preconditions for the exercise of self-defense were deemed absent, meaning that the Court â€Å"did not need to enquire† whether Ugandas actions had abided by the standards of proportionality and necessity. Given the jurisprudence of the ICJ, it is little wonder that Israel traveled the road least contested and invoked state responsibility. Indeed, while reporting to the Security Council, Israel took the position that Lebanon was responsible for Hezbollahs attack and that, as a result, this was not a terrorist attack, but rather the action of a sovereign state. [FN66] If this were true, then there would be no doubt that Israel could lawfully invoke Article 51 of the U.N. Charter. However, one would first need to demonstrate that Hezbollahs actions could be attributed to the Lebanese government in accordance with the stringent rules on state responsibility, enshrined in the International Law Commissions authoritative Draft Articles on State Responsibility. [FN67] In principle, Draft Article 4 limits state responsibility to acts carried out by state organs exercising legislative, executive, judicial or other functions, as long as they are acting in their official capacity. [FN68] Draft Article 7 makes clear that this also covers occasions where agents exceed their authority or contravene their instructions. In this context, Israel emphasized the fact that Hezbollah is part of the Lebanese government. [FN69] Hezbollah has indeed participated as a political party in Lebanese elections since 1992 and at the time of the crisis it held fourteen seats in the 128-member Parliament. It was, *277 moreover, a minority partner in the Cabinet, where it held two minister posts (Energy and Water, and Labour). It had also endorsed a third Cabinet position, namely that of Fawzi Salloukh, minister for Foreign Affairs. Nevertheless, to conclude from this participation that the July 12 attack was carried out by state agents is not acceptable. The mere fact that Hezbollah held two minister posts obviously does not imply that all Hezbollah militants would become state agents. This might be different if Hezbollah were leading the government, as Hamas did at the time in the Occupied Palestinian Territories. In such a situation, one could argue that the military wing of Hezbollah would become an extension of the governments security apparatus, implying that its actions would be imputable in the sense of Draft Article 4. Yet, in the present context, Draft Article 4 does not apply. This means that we have to look at the exceptions to the rule that states are only responsible for acts of their organs. Three main exceptions exist. The first two are laid down in Draft Article 8, according to which the conduct of a person or a group of persons shall be considered an act of a state if the person or group of persons is in fact acting on the specific instructions of the state or is under the direction or control of the state in carrying out the conduct. [FN70] With regard to the latter exception, the ICJ suggested that the litmus test is the existence of â€Å"effective† control or direction. [FN71] The third exception deals with situations where a state explicitly acknowledges and adopts conduct by non-state actors as its own (Draft Article 11; both requirements have to be fulfilled cumulatively). This situation surfaced in the Tehran case where the ICJ held that the Iranian policy of placing pressure upon the United States by not ending the hostage-crisis in the U.S. embassy and various Iranian authorities compliance with this policy transformed the occupation of the U.S. embassy into acts of Iran. [FN72] None of these exceptions apply in the present situation. As the Secretary-General remarked, it was clear that the Lebanese government had no advanced knowledge of the attack. [FN73] The Lebanese government immediately distanced itself from Hezbollahs attack and informed the Security Council that it was not aware of the events and did not endorse them. [FN74] Moreover, whereas Israel accused Iran and Syria of â€Å"supporting and embracing† those who carried out the attack, it did not accuse Lebanon of supporting Hezbollah, let alone of â€Å"effectively controlling† Hezbollah. Instead, Israel merely spoke of Lebanons â€Å"ineptitude and inaction† in exercising jurisdiction over its own territory, blaming the government for not implementing Security Council Resolution *278 1559. [FN75] The latter resolution had called for the withdrawal of all foreign forces from Lebanon as well as the disbanding and disarmament of all Lebanese and non-Lebanese militias. [FN76] I t had partially been implemented as a result of the withdrawal of most Syrian forces from Lebanese territory. [FN77] However, the Lebanese government had failed to dismantle Hezbollah, thus allowing the country to become a â€Å"hotbed of violence and a cesspool of terrorism.† [FN78] Israel argued that it was compelled to act â€Å"not against Lebanon, but against the monster that Lebanon had allowed to hold it hostage.† [FN79] Like virtually all U.N. Members during the Security Council debates of July 14 and 31, Israel supported the position that the Lebanese government should extend its sovereign jurisdiction over the whole of its territory, a position that formed the basis for Resolution 1701. [FN80] In other words, the Lebanese government was not seen as the problem, but as part of the solution. Now that we have established that the July 12 attack was not imputable to the Lebanese government in the sense of Draft Articles 4, 8 or 11, does this mean that self-defense was excluded in the present context? If one adheres to the proposition that the exercise of self-defense against attacks by non-state actors requires state responsibility, the answer would at first sight be affirmative. However, the latter position is increasingly criticized for rendering self-defense against attacks by non-state actors virtually always impossible. [FN81] First, it is highly unlikely that a state would explicitly acknowledge an attack and adopt it as its own in the sense of Draft Article 11, knowing that doing so would make it the possible target of a counterattack. Second, in most situations of alleged â€Å"indirect military aggression,† states are involved by indirectly providing assistance, training, financial and logistical support, rather than by giving specific instructions or exerc ising effective control over attacks. In such circumstances, a state sponsor commits an internationally wrongful act. For example, the Declaration on Friendly Relations proclaims that â€Å"no state shall organize, assist, foment, finance, incite or tolerate subversive, terrorist or armed activities directed towards the violent overthrow of the regime of another state, or interfere in civil strife in another state.† [FN82] Nonetheless, the state victim of an attack by non-state actors would only be allowed to resort to peaceful countermeasures. The state supporting the attack would effectively be shielded from the use of military force. *279 In an age where terrorism is universally recognized as one of the most serious threats to international peace and security, [FN83] a strict insistence on the need for state responsibility seems untenable. Such a position has also been challenged by several judges of the ICJ. In relation to the Palestinian Wall advisory opinion, for example, Judge Kooijmans, Judge Buergenthal, and Judge Higgins all emphasized that nothing in the text of Article 51 stipulates that self-defense is available only when an armed attack is made by a state. [FN84] Both Judge Kooijmans and Judge Buergenthal suggested that Security Council Resolutions 1368 and 1373 marked a new approach to self-defense, regretting that the Court had by-passed these new elements. [FN85] Judge Higgins has written separately to reiterate her earlier criticism of the Courts reliance on the Definition of Aggression in the context of the Nicaragua case. [FN86] Criticism had grown stronger by the time of the DRC v. Uganda case, where the role of irregular forces was at the heart of the dispute. Several judges regretted that the Court had not taken the opportunity â€Å"to clarify the state of the law on a highly controversial matter, marked by great controversy and confusionnot the least because it was the Court itself that ha[d] substantially contributed to this confusion by its Nicaragua judgment. . . .† [FN87] Judge Kooijmans and Judge Simma were mainly concerned with a phenomenon â€Å"which in present-day international relations has unfortunately become as familiar as terrorism,† namely the almost complete absence of government authority in the whole or part of the territory of a state. [FN88] Both suggested that in such circumstances one should only look at the scale and effects of an attack to determine the applicability of Article 51. Judge Koroma, on the other hand, argued that a states â€Å"massive support for arme d groups, including deliberately allowing them access to its territory† could be characterized as an â€Å"armed attack.† [FN89] Finally, Judge ad hoc Kateka rejected the idea that â€Å"the provision of arms, coupled with ‘logistical and other support†Ã¢â‚¬â„¢ could not qualify as an armed attack. [FN90] These separate and dissenting opinions acquire a particular meaning if we look at recent evolutions in state practice and opinio iuris. Here we notice a trend of abandoning the need for state imputability in two different scenarios, namely cases where a state supports the activities of non-state actors and cases where a state is unable to prevent non-state actors from carrying out attacks. Research Papers on Israel's Right to Self-DefenseTwilight of the UAWCanaanite Influence on the Early Israelite ReligionUnreasonable Searches and SeizuresPETSTEL analysis of IndiaHonest Iagos Truth through DeceptionNever Been Kicked Out of a Place This NiceMarketing of Lifeboy Soap A Unilever ProductCapital PunishmentThe Effects of Illegal ImmigrationThree Concepts of Psychodynamic

8 Powerful Reasons Why Nursing Isnt for Everyone

8 Powerful Reasons Why Nursing Isnt for Everyone Nurses are so often taken for granted as â€Å"just† the people assisting the real doctors in their work. But nursing is actually an incredibly difficult and taxing job, one filled with quiet heroes. Here are just 8  of the many reasons why nursing attracts the toughest and most dedicated people to the profession. 1. It’s a matter of life and death.As a nurse, you literally (and routinely) hold people’s lives in your hands. How many other jobs have that same awesome responsibility?2. You need endless knowledge.There are so very many medical terms you must be familiar with to be a nurse. And it’s not just the terminology. You also have to hold an enormous amount of information in your head, or risk dangerous consequences: doctors’ orders, patients vitals and other data, etc. You also have to keep up with trends, do continuing education, and push yourself to keep learning so you don’t fall behind the cutting edge.3.  You are surrounded by p eople in their lowest moments.It’s unbelievably difficult to watch another human being suffer- let alone pass away. You may think nurses get used to both these things; they don’t. They become very adept at doing their job in the face of suffering and loss, but that doesn’t mean a nurse isn’t affected.4. You come last.As a nurse, you have to put almost everyone’s needs before your own: doctors, patients, even putting your job ahead of your family time when your schedule requires. You have to smile, be endlessly patient, be empathetic, but take care not to get too attached. You might even have to eat breakfast while commuting- because it might just be the only meal you get all day.5. You don’t get paid enough.Even though nursing is a field in which it’s always possible to take on extra shifts or opportunities, you probably are not getting compensated at a truly fair rate for all you do. You don’t get holidays. You miss out on lot s of your family and social life opportunities, particularly when things run late or you’re on call. A lot of hospitals are also now cutting back on hiring and instead having their nurses work extra overtime. It can be pretty thankless!6.  You rarely get the respect you deserve.As a nurse, particularly since it’s a predominantly female profession, you get less respect than you deserve. Nursing is constantly devalued compared to more predominantly male professions. You do a huge share of the work in the care situation, and get almost none of the credit. And you have to be caring and compassionate in the face of occasional maltreatment, disrespect, and outright rudeness.7.  It’s very strenuous.The taxing hours worked, the being on your feet constantly, all these things add up to being sore and tired almost all of the time. Nurses also do a huge amount of heavy lifting and often develop back problems.8. Everyone’s a patient.As a nurse, you’re guar anteed to be bombarded with texts and photos of all your friends’ and family’s ailments asking you for free medical advice. It will be difficult to figure out where to draw the line in your off hours.Don’t be discouraged, though- nursing is a profession that needs heroes, and if you’re drawn to it, you can change lives. The good outweighs the bad, if you’re willing to muddle through it to get to the rewarding parts!

An Investigation of Role and Importance of Trust in Establishing Literature review

An Investigation of Role and Importance of Trust in Establishing Online retail Relationship in Fashion Sector - Literature review Example Trust is regarded as the chief strategic asset of a firm when it aims to bring about operational changes subjected to market uncertainness (Park and Srinivasan, 1999). It is perceived to be the central constituent in professional relationships. The value and meaning of trust have changed over time, but its intrinsic outcomes remain beneficial. Organizational scholars provide great importance to the issues of trust. The issues are legitimated by the changes in economic exchange relations, organizations forms and social societal structure (Bijlsma and Koopman, 2003). Tom Tyler (1996) had stated that trust factor is imperative for organizational success. Trust existing within the workplaces of an organization helps to create voluntary-corporation among the workers. The performance and productivity level of an organization considerably depends on the extent of cooperation among the workers. Gradual changes in societies and organizations have enhanced the importance of the matters relating to trust (Parker, 2012). Trust is considered as a solution to specific risk-related problems arising between different individuals. Trust within organizations is mandatory for motivating professional associations and driving rapid business imp rovement. Experts are of the opinion that strategic cooperation and collaboration between different firms become easier with the presence of trust between them (Hahn and Kim, 2009). The attitudes of the employees within workplaces are also determined by the same. Employee satisfaction from jobs and their commitment towards work tasks are largely influenced by their trust towards the firm. Brand value of a company in the market is largely dependent on the stakeholder's trust towards the same. Researchers point out that satisfaction derived by the consumers from the consumption of goods or services of a company is directly proportional to their trust towards the same (Winch and Joyce, 2006).