Sunday, January 26, 2020

The Section 41 Approach In Sexual Offence Trials Law Essay

The Section 41 Approach In Sexual Offence Trials Law Essay Historically, the prejudicial effect of rape myths and sexual history evidence has been problematic for the courts in sexual offence trials. In 1999, Parliament enacted s.41 of the Youth Justice and Criminal Evidence Act to place stringent restrictions on sexual history evidence. However, these provisions have caused some difficulties for the courts. While the landmark case of A(2) resolved some of the issues, it will be put that the law remains vexed and, once again, in dire need of reform. A new approach is required which does not exclude evidence from consideration by the jury. Instead, rape myths need to be attacked directly, so they can be eradicated, and their impact neutralized. This discourse will be prefaced by a discussion of the events leading up the 1999 Act, followed by a cursory overview of the approach taken by s.41 in order to highlight some of the primary problems with the legislation. Subsequently, the House of Lords decision in A(2) will be scrutinized, followed by consideration of some suggestions for reforming the law. Traditionally, the investigation and prosecution of rape and other sexual offences has been rife with difficulties, especially in the area of evidential requirements. Aggressive questioning of female complainants about personal sexual matters was commonplace, and sexual history evidence was considered relevant to consent and credibility. Over time, myths and stereotypes developed which exerted prejudicial effects on the fairness of trials. In R v Riley, evidence of previous voluntary sexual relations with the accused was admissible in order to assert that it was more likely that the complainant consented to the incident in question.  [2]   In 1975, the Heilbron Committee considered legislative reforms, examining the impact of sexual history evidence. Their report recommended that it should only be admissible in very limited circumstances, that there should be some limited judicial discretion along with an inclusionary rule based on striking similarity. Unfortunately, when drafting s.2 of the Sexual Offences Act 1976, these proposals were largely ignored. The complainants sexual behaviour with someone other than the defendant should only be referred to when it would be unfair to exclude it, based on the judges discretion.  [3]   However, the practical application by the courts was too permissive with too much judicial discretion, resulting in sexual history evidence being admitted too freely.  [4]   Amidst growing disquiet, in 1998 the Home Office scrutinized the practical application and the failures of the 1976 Act. The White Paper Speaking Up for Justice exposed numerous inherent weaknesses which necessitated reform.  [5]  This report was criticized by Diane Birch and Neil Kibble for contributing to the shortcomings of Parliaments response in 1999. The YJCEA debates on the draft bill reflected a lack of consensus on the ideal approach to rape shield legislation, including prevalent concerns about over-restrictiveness and the dangers of excluding relevant evidence.  [6]  The wider jurisprudence was surveyed, including approaches in Australia, Canada, and Michigan. The landmark Canadian case R v Seaboyer  [7]  , where McLachlin J. coined the term twin myths, challenged the provisions of s.276 of the Criminal Code composed of a rule of exclusion with three exceptions.  [8]  Resultantly, the Canadian Supreme Court held that s.276 unconstitutionally violated the right to a fair trial. The impact of these developments played a central role in the YJCEA debates in the UK, as à ¢Ã¢â€š ¬Ã‚ ¦they were cited as evidence that legislative straitjackets had been attempted and failed.  [9]   Parliaments response was s.41 YJCEA 1999, which engendered a more restrictive and structured approach to attacking the twin myths that sexual experience may indicate a propensity to consent and a lack of veracity.  [10]  The aim of the legislation was to strike a balance between protecting claimants from the prejudice of sexual history evidence while securing the defendants right to a fair trial. The blanket rule of exclusion under 41(1) restricts evidence or questions about any sexual behaviour without leave of the court, which will only be granted where both conditions of the two-part test are satisfied; under s.41(2)(a) where either ss.(3) or (5) applies, and the unsafe verdict test, under s.41(2)(b). Any questions or evidence pertaining to the actual incident can be adduced, such as questions about what the complainant said or did before or during the incident, including humiliating questions. Also, anything not about sexual behaviour, and not including sexual history evidence can be adduced. The rape shield legislation targets other sexual behaviour outside the charge, legitimately seeking to exclude sexual history evidence that is not related to the incident. There is a closed list of four narrow gateways (or exceptions) within which evidence may be regarded as critical. Notably, within a matter of days of coming into effect, the legislation warranted a challenge to the House of Lords to consider whether they were broad enough to prevent injustice.  [11]   The non-consent gateway may admit evidence pursuant to s.41(3)(a), if it is not an issue of consent, such as mistaken identity  [12]  , honest belief in consent, motive to fabricate, or alternative explanation. The consent gateway, may admit evidence about an issue of consent, which is about sexual behaviour which took place at or about the same time as the subject matter of the charge (res gestae)  [13]  , or it is so similar to behaviour that took place as part of the incident that it cannot be explained as coincidence (similar fact). The fourth gateway applies only when the prosecution has adduced evidence about the sexual behaviour of the complainant, whereby the defence can only go as far as is necessary to enable that evidence to be rebutted or explained.  [14]   Upon passing through a gateway and surmounting the two-part test, two further requirements arise. Under s.41(4), questions or evidence intended to impugn the credibility of the complainant are restricted. As well, under s.41(6) evidence or questions must relate to a specific instance of sexual behavior.  [15]   These provisions have raised numerous fundamental concerns. Unlike other jurisdictions, the leave requirement does not apply to the prosecution, making s.41 a one-sided rule of exclusion that only applies to the defence.  [16]  Lord Hope recognized the dangerous threat this posed to the equality of arms principle enshrined in Article 6(3)(d) of the Convention.  [17]  For instance, under s.41, the prosecution would be permitted to adduce evidence of the complainants virginity to illustrate that it was unlikely that she consented to the alleged acts. On the other hand, the defence is prevented from adducing contrary evidence that the she has experience with multiple partners to show that she is more likely to have consented. Allowing one but not the other seems imbalanced, and raises the broader question whether the true rationale for s.41 is on excluding irrelevant evidence or protecting against humiliation of complainants in cross-examination.  [18]   The vague definition of sexual behaviour under s.42(1)(c) has resulted in some difficulties,  [19]  though it is considered controversially wider now, since it covers evidence of previous or subsequent sexual behaviour with the accused and with third parties. As will be seen, this was a fair trial flashpoint in A(2).  [20]  Professor Birch has argued that equating the accused with third parties creates the danger of redefining the defendant as a stranger, thereby giving potency to the old myth that real rape is committed by strangers.  [21]  For example, relevant evidence of a previous romantic relationship between the defendant and the accused which included sexual relations a few days before the incident in question may be excluded unless it can pass through the narrowly drawn res gestae gateway. If it cannot (and does not satisfy the unsafe test), Thre is no discretion to include it even though it may be highly relevant to the defence case. The restrictive gateways approach has created integral concerns regarding the exclusion of relevant evidence, where its prejudicial effects compromises the fairness of trials. Combined with restrictions on judicial discretion, the shortcomings of using only three fixed exceptions to try and predict every eventuality is exacerbated further. Neil Kibble, in his 2004 report, stated that other jurisdictions like Canada and Australia have already rejected this pigeon-holing approach on the ground that even if judges get it wrong you cant address the problem effectively by eliminating their discretion.  [22]   The shortcomings of s.41 reached critical mass in the landmark case of A(No.2) which involved a rape trial, where the accused alleged an ongoing sexual relationship with the complainant three weeks prior to the incident in question, with the last occasion being one week prior. The trial judge had sought to admit evidence of the previous relationship as relevant to consent, but was unable to do so through one of the gateways. Thus, following the decision of the Court of Appeal,  [23]  the House of Lords intervened, to examine whether excluding such evidence under s.41 would contravene the defendants right to a fair trial pursuant to Article 6(3)(d) ECHR. One of the touchstone issues identified included the extent to which the defence could refer to matters outside the central facts in order to provide the court with fundamental evidence, the absence of which may result in an unjust verdict. Lord Hutton stated that the right of a defendant to call relevant evidence, where the absence of such evidence may give rise to an unjust conviction, is an absolute right which cannot be qualified by considerations of public interest, no matter how well-founded that public interest may be.  [24]   Their Lordships contemplated whether a sexual relationship between the accused and the complainant was relevant to the issue of consent such that to exclude it under s.41 would contravene the defendants right to a fair trial. Reaching a decision required the importation of a residual discretion to decide whether leave should be granted to the defence to adduce evidence of the relationship if it was so central to the issue of consent, that to exclude it would threaten the Article 6 Right to a fair trial. This was achieved by employing s.3 HRA 1998 by reading and giving effect to the similarity exception within s.41(3)(c) in a way that was compatible with Convention rights. Their Lordships qualified their decision by stating that while the aims of the provisions were legitimate, the approach raised questions about proportionality regarding sexual behaviour with the accused. Thus, it was agreed that such evidence could be sufficiently relevant to necessitate its admission in the interests of fairness. Thus, s.41 was rescued from the clutches of repeal, some residual discretion for trial judges was restored, and the gateways relaxed in the interests of fairness. In some respects, the law seemed come back around full circle to where it was before the 1999 Act, based on fairness tempered with judicial discretion.  [25]   However, along with this flexibility came a degree of uncertainty, as it created the danger that the rationale could be broadly applied in any case where the judge adopted the view that fairness under Article 6 may be threatened. Cases such as R v Rooney,  [26]  R v Martin,  [27]  R v R (2),  [28]  and R v White  [29]  indicate how the courts have struggled in the aftermath of A(2). In 2006, a Government White Paper looked at the effectiveness of s.41, whereby National statistical data revealed that s.41 had little or no effect on attrition, while rape conviction rates continued to fall. The report also found that the Crown Court Rules regarding s.41 were frequently ignored or avoided, and recommended that reforms were necessary in order to increase the effectiveness of the legislation.  [30]   A way needs to be found to bring rape myths out in the open so they can be eradicated, and their impact neutralized. Diane Birch stated that if juries can only be trusted to adjudicate on cases of rape within relationships by being kept in the dark about the relationship, there is something fundamentally wrong with jury trial.  [31]   The law should equip judges and juries with the tools needed to effectively attack rape myths in order to mitigate the prejudice of sexual history evidence, like other areas of law such as bad character have done, with enhanced judicial training and jury directions. Interestingly, Vera Baird, QC, the Solicitor-General, recently announced that jury directions are being developed that would instruct juries to ignore rape myths in an effort to increase conviction rates in the UK (amongst the lowest in Europe).  [32]   Consideration should be given to amending the current gateways to widen the scope of factors considered, and additional gateways should be added such as implementing a safety-valve type of residual discretion in order to admit evidence falling outside of the exceptions, similar to the approach taken by s.276 of Canadian Criminal Code after the ruling in R v Seaboyer.  [33]  This should reflect a recognition of the value of contextual factors as explanatory evidence, in line with Lord Huttons mindset argument approach in A(2). The culmination of what has been discussed thus far establishes that the aims of s.41 YJCEA 1999 are legitimate, as rape myths have threatened the fairness of trials for centuries. However, it has been argued that the approach taken by s.41 does not strike an effective balance between protecting the complainant from the ravages of sexual history evidence versus securing the defendants right to a fair trial under the Convention. The restrictive gateways are incapable of foreseeing every eventuality, and thus create the potential for relevant evidence to be excluded from consideration by the jury. The House of Lords decision in A(2) addressed this issue, and was required to import in some residual judicial discretion in order to resolve the dilemma and prevent repeal of the Act. However, this decision created some uncertainty, which has left the law unresolved and in a muddle. The suggestions for reform center around one underlying theme: the law needs to move towards enabling judges and juries to squarely attack the rape myths, and be able to handle sexual history evidence with the sensitivity required so as to mitigate prejudice while not risking the fairness of trials. A fine balance must be struck between the flexibility of some limited judicial discretion and the certainty provided by the legislative restrictions of s.41 in order for the law to operate effectively. The former must not come at the expense of the latter.

Saturday, January 18, 2020

Hals Woodworking

HAL’S WOODWORKING SWOT ANALYSIS Table of Contents SWOT Diagram†¦Ã¢â‚¬ ¦ †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 3 Introduction†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 4 Strengths†¦ †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 4 Weaknesses†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦. 5 Opportunities†¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦.. 5 Threats†¦. †¦Ã¢â‚ ¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦ 5 Conclusions and Recommendations.. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦6 References†¦.. †¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦Ã¢â‚¬ ¦7 |   | Strengths|   | |   |   | Weaknesses|   | | | | |   | |   | | | |   | †¢| Family owned business|   | | †¢| Local presence| |   | †¢| Local community presence|   | | †¢| Limited Internet website|   | †¢| Service oriented tradition.   | | †¢| Small online selection|   | †¢| Established tradition|   | | †¢| No internet business knowledge| †¢| Has established customer base. | | †¢| Limited staff | |   | †¢| Management is committed to company. | | †¢| Limited budget| |   | †¢| Qualified and knowledgeable staff| | †¢| Don't have a detailed plan yet. |   | | | |   | | †¢| We would be a small player. |   |   | | | |   | |   | | | |   | | | | |   | |   | | | |   | | | | |   | |   | | | |   | | | | |   | |   | | | |   | | | | SWOT SWOT |   | |   | | | |   | | | | |   | |   | | | |   | |   |   |   |   | |   |   |   |   |   | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |   | Opportunities|   | |   |   | Threats|   | | | | |   | |   | | | |   | †¢| Increased internet exposure|   | | †¢| Increased competition from brick and| †¢| Increased sales| |   | |   | mortar stores like Home Depot. | †¢| Larger customer base|   | | †¢| Increased competition from online| †¢| Profit margins will be good. |   | |   | retailers such as Amazon. |   | †¢| Coul d seek better supplier deals. | | †¢| Competition can easily enter market. | †¢| Opportunity to expand|   | | †¢| Vulnerable to reactive attacks by major|   | | | |   | |   | competitors. | |   | | | | |   | | †¢| Price competition| |   | | | |   | | †¢| Risk of losing family owned reputation|   | | | |   | |   | | | |   | | | | |   | |   | | | |   | | | | |   | |   | | | |   | | | | |   | |   | | | |   | | | | |   | |   | | | |   | |   |   |   |   | |   |   |   |   |   | Introduction This SWOT (strengths, weaknesses, opportunities, threats) analysis evaluates the desirability of expanding Hal’s Woodworking website beyond its current state. The current website includes information about the company and some store information, such as locations and hours. Management is considering expanding the web site to include online shopping.Through the analysis of the strengths, weaknesses, opportu nities, and threats I have determined that expanding Hal’s Woodworking is good idea since it has many strengths that will overcome its weaknesses. Expanding will be necessary for the company to stay in business for the long term. But Hal’s Woodworking also needs to focus on their weaknesses and threats to avoid being run out of business by large chain retailers such as Home Depot and Amazon. Strengths Hal’s Woodworking has various strengths that could make the expansion of selling products on a website successful.Hal’s Woodworking has strong local community presence that through the expansion of the website will allow the company to reach customers who they can’t reach now by moving from local to worldwide. The company also has strong reputation of being providing high qualified service through knowledgeable staff. That strength could be translated to the website if the inventory that the company offers on the website is tailored by the staff that knows the product. In doing that the customer could either buy it from the online store or go to the store with the knowledge of what they want.That could lead to a no hassle experience for their valued customers and new customers. Weaknesses Hal’s Woodworking has various weaknesses that could hinder the success of expanding to shopping on their website. The store is local and will only showcase a limited selection of their products online. Being a local presence the price points for the products will not compete with the bigger websites like Amazon and Home Depot. But if the company wants to compete, lower prices will be needed which will cause a decline on profit margins for the products offered by the company.With no solid plan in place Hal’s Woodworking needs some expert advice before entering the ecommerce world. Opportunities Hal’s Woodworking will have various opportunities that could help the company succeed in expanding its website. Currently the compan y offers classes and workshops for the homeowner and hobbyist each month and regularly schedules seminars that are underwritten and taught by manufacturers. If the company could offer those videos on the website it could add even more value to high-end specialty tools currently being considered for the website.In expanding to selling online it will lead to increased exposure and the increased web presence which could lead to increased sales that could help the company to eventually expand. Threats Hal’s Woodworking will have various threats that could threaten the company expansion of its website. In order to reach their valued customers, it will be a threat for them to compete with big time companies like Amazon and Home Depot since these big companies already promote products at low prices. This will leave Hal’s woodworking susceptible to price changes and could leave the company with low profit margins if Hal’s decides to compete on price.Lastly, Hal’s Woodworking risks losing their family owned reputation if it strays from what has made them successful. Conclusion and Recommendations In order for Hal’s Woodworking to succeed the company could create and expand partnerships with other tool manufacturers. This could allow the company to be able to bid for lower prices of products and eventually sell those products to consumers at a lower cost. Another recommendation includes having promotions, free products, or loyalty discounts for regular costumers that visit the website.This will help retain current customers and help gain new customers. Lastly an online membership could help the company monitor customer trends. With a solid plan in place and expert advice, Hal’s Woodworking could successfully sell products on a website if the company uses its established reputation. Although the company can’t compete with the cheap prices from big companies it can offer superior service which the company is known for. Refe rences Schneider, Gary P. Electronic Commerce. Boston, MA: Course Technology Cengage Learning, 2013. Print.

Friday, January 10, 2020

History of Chess

The precursors of chess originated in India during the Gupta Empire,[2][3][4][5] where its early form in the 6th century was known as chatura? ga, which translates as â€Å"four divisions (of the military)†: infantry, cavalry, elephantry, and chariotry, represented by the pieces that would evolve into the modern pawn, knight, bishop, and rook, respectively. [6] Chess was introduced to Persia from India and became a part of the princely or courtly education of Persian nobility. 7] In Sassanid Persia around 600 the name became chatrang, which subsequently evolved to shatranj, due to Arab Muslim’s lack of ch and ng native sounds,[8] and the rules were developed further. Players started calling â€Å"Shah! † (Persian for â€Å"King! â€Å") when attacking the opponent's king, and â€Å"Shah Mat! † (Persian for â€Å"the king is helpless† – see checkmate) when the king was attacked and could not escape from attack.These exclamations persisted in chess as it traveled to other lands. The game was taken up by the Muslim world after the Islamic conquest of Persia, with the pieces largely keeping their Persian names. The Moors of North Africa rendered Persian â€Å"shatranj† as sha? erej, which gave rise to the Spanish acedrex, axedrez and ajedrez; in Portuguese it became xadrez, and in Greek zatrikion, but in the rest of Europe it was replaced by versions of the Persian shah (â€Å"king†).Thus, the game came to be called ludus scacchorum or scacc(h)i in Latin, scacchi in Italian, escacs in Catalan, echecs in French (Old French eschecs); schaken in Dutch, Schach in German, szachy in Polish, sahs in Latvian, skak in Danish, sjakk in Norwegian, schack in Swedish, sakki in Finnish, sah in South Slavic languages, sakk in Hungarian and sah in Romanian; there are two theories about why this change happened: 1. From the exclamation â€Å"check† or â€Å"checkmate† as it was pronounced in various languages. 2.From the first chessmen known of in Western Europe (except Iberia and Greece) being ornamental chess kings brought in as curios by Muslim traders. The Mongols call the game shatar, and in Ethiopia it is called senterej, both evidently derived from shatranj. Chess spread directly from the Middle East to Russia, where chess became known as (shakhmaty, treated as a plural). The game reached Western Europe and Russia by at least three routes, the earliest being in the 9th century. By the year 1000 it had spread throughout Europe. [9] Introduced into the IberianPeninsula by the Moors in the 10th century, it was described in a famous 13th century manuscript covering shatranj, backgammon and dice named the Libro de los juegos. Chess spread throughout the world and many variants of the game soon began taking shape. [10] Buddhist pilgrims, Silk Road traders and others carried it to the Far East where it was transformed and assimilated into a game often played on the intersection of the li nes of the board rather than within the squares. [10][11] Chaturanga reached Europe through Persia, the Byzantine empire and the expanding Arabian empire. 12] Muslims carried chess to North Africa, Sicily, and Iberia by the 10th century. [10] The game was developed extensively in Europe, and by the late 15th century, it had survived a series of prohibitions and Christian Church sanctions to almost take the shape of the modern game. [13] Modern history saw reliable reference works,[14] competitive chess tournaments[15] and exciting new variants which added to the game's popularity,[15] further bolstered by reliable timing mechanisms (first introduced in 1861), effective rules[15] and charismatic players. [16]

Thursday, January 2, 2020

A Doll’s House Nora Essay - 896 Words

When the door slams at the end of â€Å"A Doll’s House† by Henry Ibsen, No one would not believe the woman walking out of her house is the same one who appeared at the beginning of the play. The main character in this play is Nora. Nora goes through a complete transformation, changing from a child like and dependant woman to a self strong woman pushing to become independent. Ibsen portrays the roles of society in the Victorian times in this play. Throughout her whole life, Nora’s husband and father have always controlled her; she has never been able to be independent, and the treatment she receives is not equal to the males around her, and the people around her belittle and patronize her to no end. Finally it goes too far and Nora realizes†¦show more content†¦Torvald berates Nora about her physical appearance, saying, Has my little sweet tooth been indulging herself in town today by any chance? ... (Act 1). Nora often sneaks macaroons, because she can not eat them in front of Torvald for fear of his disapproval. Torvald is very particular about Noras figure, as he wants her to stay small, dainty, and delicate. This is Ibsen showing the â€Å"role† of the male in that society. He has to always be in control, and for Torvald, his and Nora’s image are the most important things in the world, whether it was Nora’s figure or the fact that Nora forged her father’s signature to obtain the secret loan, which angers Torvald a great deal. In the beginning, Nora acts and speaks like a child saying things like â€Å"Pooh!†(Act 1). Ibsen showshow he thinks dependant and uneducated woman are naive and almost childlike. Nora and Torvald’s relationship is almost exactly how her and her father’s relationship had been, with the man completely controlling Nora, and Nora acting like an obedient child. Nora had not been independent with her father and when she marries Torvald she is also completely dependant on him for everything she wants or needs. Both Nora’s father and Torvald coddle Nora and treat her like a delicate doll so she is never fully is independent. At one point in the play Torvald even admits he finds Nora more attractive because of her dependence on him. Christine Linde isShow MoreRelated A Doll’s House - Nora Essay1498 Words   |  6 PagesNora is the central character in the book A Doll’s House and it is through her that Ibsen develops many of his themes To what extent is loyalty shown by the lead female characters characters? What are the consequences of this? Within these two books loyalty is a minor theme and one that is easily missed, indeed it is narrow. However, it is still one which weaves a thread through both of the books encompassing major and minor characters, the material and the abstract. In commencing this Read MoreNora and Torvald in The Dolls House1384 Words   |  6 Pagesother persons emotions and needs, truthfully expressing ones views, and supporting each other during times of adversity. In Henrick Ibsens play, A Dolls House, he uses the character development of Nora Helmer, the protagonist, and Torvald Helmer, the antagonist, to emphasize the importance of communication in a healthy relationship. A Doll’s House was published in 1879 in Norway. Women of that time were expected to be good mothers and wives. They were expected to take care of the domestic responsibilitiesRead MoreAnalysis Of Nora Helmer In A Dolls House702 Words   |  3 Pages In Hedrick Ibsens, A Dolls House, Nora Helmer is deceptive to nearly every character in the play. Not only does she forge her fathers signature, but also lies to her husband about it, refuses to reveal where she obtained it from and continues to add more lies on to avoid being discovered and having to face her consequences. Her constant deceitful actions are committed initially to prove herself as reliable and independent, unlike how women were seen as in her era, but escalated to simply toRead MoreEssay on Willy and Nora in A Dolls House600 Words   |  3 PagesWilly and Nora in A Dolls House Henrik Ibsens, A Doll House, is about how a family, particularly Nora Helmer, deals with an old secret that is about to become known to her husband Torvald Helmer. At the start of the play Nora is talking with Torvald. Nora begins to acting like Torvalds little squirrel in attempt to get money from him. At that time it is not known what she wants the money for, but Nora says it was for Christmas presents. The actual reason for the money is so she canRead MoreDifferences Of Nora And Torvald In A Dolls House1258 Words   |  6 PagesIn A Dolls house, there are many characters with a wide variety of different personalities and objectives. Even though there are many similarities between characters, there are just as many differences. Out of all the characters Torvald and Nora are the ones with the biggest differences in personality and opinions. Even though they are married and most of the time seem to have the perfect home life, it becomes easier to deduce throughout the drama that they are two completely different people thatRead MoreEssay On The Relationship Of Nora And Torvald In A Dolls House1010 Words   |  5 Pagesrelationship of Nora and Torvald in A Doll’s House by Henrik Ibsen. A Doll’s House follows the life of Nora Helmer as she breaks free from the mold society has put her, and other women, in. From the beginning, it is prominently shown to the reader that Nora’s husband, Torvald, has a lack of trust and respect towards Nora. As time progresses, the absence of trust and respect towards Nora manifests, causing Nora’s feelings towards Torvald to change as well as affect the way A Doll’s House ends. As Nora maturesRead MoreHow Significant Is the Change in Nora in a Dolls House1376 Words   |  6 Pagessignificant is the change in Nora in A Dolls House Nora is the character in A Doll House who plays the 19th woman and is portrayed as a victim. All of the aspects of this quote can be applied to the play A Doll House, in Nora’s character, who throughout much of the play is oppressed, presents an inauthentic identity to the audience and throughout the play attempts to discovery her authentic identity. The inferior role of Nora is extremely important to her character. Nora is oppressed by a varietyRead MoreA Dolls House- Why Nora Shouldnt Leave1908 Words   |  8 PagesNora Helmer Exposed: Her Wrong Decision to Leave A Doll’s House by Henrik Ibsen was first performed in 1879 when European society strictly enforced male supremacy over women. 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Ibsen uses the conversation between Nora and Krogstad to enhanceRead MoreEssay about The Rebellion of Nora in Ibsens A Dolls House1357 Words   |  6 PagesThe Rebellion of Nora in A Dolls House      Ã‚  Ã‚   A Dolls House, by Henrik Ibsen, was written during a time when the role of woman was that of comforter, helper, and supporter of man. The play generated great controversy due to the fact that it featured a female protagonist seeking individuality.  Ã‚   A Dolls House was one of the first plays to introduce woman as having her own purposes and goals. The heroine, Nora Helmer, progresses during the course of the play eventually to realize that she must