Wednesday, January 29, 2020
Bone Cancer Essay Example for Free
Bone Cancer Essay Bone cancer is a disease that occurs on or inside a bone. Usually, bone cancer involves a tumor filled with abnormal cells that will occasionally appear on the exterior of the bone. Similar to other types of cancer, bone cancer can be life threatening. Doctors are not completely sure what causes cancer, but they continue the search to find an answer. There are five different types of bone cancer that can affect people from ages 10-60 years old. Bone cancer can occur in any bone in the body from the legs to the head. Unfortunately, symptoms of bone cancer are not always obvious. Most of the time, pain is the most apparent symptom. When recognizing symptoms at an early stage, doctors can complete testing and supply treatment to the patient. Treatment for bone cancer usually begins with surgery followed by chemotherapy or radiotherapy. Because of the need to kill all of the abnormal cells that are growing on or inside the bone, treatment for bone cancer can be very powerful. In most cases, treatment is very successful. Before starting cancer treatment, many patients rely on statistics for a survival rate, but statistics are simply averages. Each patient has a different circumstance with his/her disease. There are 206 bones in the human body. Each bone serves several purposes. The bones of the body act as the structure that helps to support and protect many internal organs. The bones also serve as a muscle attachment that connects to the muscle to help during movement. But, most importantly, the bones of the body produce and store cells in the bone marrow. Cells make up the body tissue. However, some cells can become abnormal. Given that healthy cells make up body tissue, unhealthy cells grow and destroy body tissue and can often spread to other parts of the body. This abnormal growth of cells is called cancer. There are more than 100 types of cancer known to man, and 5 out of 100 are bone cancer. The most common type of bone cancer is Osteosarcoma, which commonly affects people from ages 10-25 years old. Osteosarcoma develops in new tissue usually in the arms, legs, or around the knee joint. Chondrosarcoma is another type of bone cancer. It usually develops in the cartilage of the pelvis, upper part of legs and arms, and the shoulder. Chondrosarcoma affects people from ages 50-60 years old. Ewingââ¬â¢s Sarcoma is a bone cancer that is known to begin in immature nerve tissue in the bone marrow. It attacks the pelvis, femur, and tibia. Ewingââ¬â¢s Sarcoma usually affects people from 10-20 years old. The last two types of bone cancer are Malignant Fibrous Histiocytoma and Fibrosarcoma. Both of these types of bone cancer are very rare and usually develop in the arms and legs or around the knee joint. Malignant Fibrous Histiocytoma and Fibrosarcoma are known to affect middle aged people. Bone cancer can sometimes be hard to detect. Symptoms of bone cancer can develop very slowly if at all. Often, one will develop swelling or tenderness in the affected area. Sometimes, a slightly visible lump may be felt through the skin. Bone cancer can also interfere with body movements like walking or hiking. Broken bones can also result from bone cancer. In one case, a victim of bone cancer recently started seeing symptoms of bone cancer. She developed a strong pain in her knee joint that enabled her to walk. The victim experienced a large amount of swelling around the joint. When she consulted a physician, the patient found that she had a fracture and a cancerous tumor in her knee. Even though the above symptoms can also lead to other injuries or diseases besides bone cancer, it is strongly recommended that one should consult a physician if in doubt. When diagnosing bone cancer, a doctor must first complete some tests. According to a summary of tests and procedures by Medicine Net on line, a doctor will first ask about a patientââ¬â¢s personal and family medical history in order to find out if there is any history of cancer in the family. Next, the doctor will order blood tests and x-rays. The exact size, shape, and location of a bone tumor can be seen through an x-ray. Then, a CAT scan (Computed Axial Tomography) will be completed to show whether the cancer has begun to spread to other parts of the body. A CAT scan will give detailed pictures of the cross section of the body. There are also similar tests like an MRI (Magnetic Resonance Imaging) and an Angiogram (x-ray of the arteries), but a biopsy is the ultimate test that will make sure that cancer is present in the body. After the victim was told that she had bone cancer, she experienced a biopsy in Seattle, Washington. The Medicine Net on line explained that during a biopsy, doctors test a sample of the bone tumor and determine through a microscope whether or not the tumor is cancerous. The many different tests of bone cancer are very critical to the outcome of the disease. The tests are used for staging the bone cancer. For example, if a patient of bone cancer had a CAT scan, and it showed that the bone cancer was not spreading, the doctors could stage the patientââ¬â¢s cancer as controlled. There are three types of treatment for bone cancer: surgery, chemotherapy, and radiotherapy. The treatment preference depends upon the type, location, size, and extent of tumor along with a patientââ¬â¢s needs. Sometimes, a combination of the three treatments is used on a patient. Because cancer can recur in the original affected area, surgeons often remove the tumor, tissue, and some healthy bone surrounding the tumor. In some cases, especially in children, a metal device will be implanted in place of the bone that was removed by a surgeon. This metal device functions to save a limb and lengthen as the child grows. Another type of treatment is chemotherapy. The National Cancer Institute, which covers both chemotherapy and radiotherapy, states that chemotherapy uses several drugs such as Cyclophosphamide, Vinblastine, and vincristine to kill cancer cells. Chemotherapy is a very intense treatment that can be given by mouth or by injection into a muscle or blood vessel. Chemotherapy is so powerful that there has to be a treatment period followed by a recovery period, which is usually when one has fully recovered from the intense drugs used in chemotherapy. Recovery periods can vary with each person. The last treatment for bone cancer is radiotherapy. This type of treatment uses high-energy rays to damage cancer cells and stop them from growing. Radiotherapy can sometimes be used in place of surgery to remove the bone cancer. Another use for radiotherapy is to kill cancer cells remaining in the affected area after treatment. All treatments for bone cancer are very strong. The treatments are so strong that they kill not only cancer cells but also some healthy cells. The five bone cancers are a very small proportion of the 100 or more cancers known to man. However, the National Cancer Institute is developing and sponsoring clinical trials on bone cancer patients in many hospitals and cancer centers. The National Cancer Institute is trying to find new effective treatments and methods for bone cancer. The future for bone cancer patients is very promising. Doctors and scientists are hoping to discover the cure for cancer in the next ten years.
Tuesday, January 21, 2020
gatillus Unattainable Illusions in The Great Gatsby :: Great Gatsby Essays
Unattainable Illusions in The Great Gatsby à à à à The work of Fitzgerald is the product of the "Jazz" era, a time when all gods had been declared dead, all wars fought, and all faiths in men had been shaken.à Fitzgerald's style is a combination of American idealism and nihilistic pessimism.à In The Great Gatsby, whose originally proposed title was 'Among the Ash-Heaps and Millionaires,' we also find a narrator and style that make moral judgements through the narrator Nick, a constant overseeing moral vision that is symbolized by the ever-watchful "eyes" of Doctor T.J. Eckleburg.à Despite the glittering appearances and material ostentation of West Egg, something is perceived as being not quite right with the conventional American dream and those who achieve it.à Nonetheless Nick opens the novel by remembering his father's advice:à "Reserving judgments is a matter of infinite hope.à I am still a little afraid of missing something if I forget that, as my father snobbishly suggested, and I snobbishly repea t, a sense of the fundamental decencies is parcelled out unequally at birth"à (Fitzgeraldà 1). à The main character Gatsby, despite the appearance that he has achieved the American dream, is actually a man alone who tries to turn back the clock and win his true love Daisy.à However, despite the glittering parties and material luxuries of Gatsby's world, Fitzgerald's style admits a serious stream of cynicism that is pervasive throughout the novel.à When Daisy tells Nick her baby might be a girl she says "And I hope she'll be a fool-that's the best thing a girl can be in this world, a beautiful little fool"à (Fitzgeraldà 17).à This cynicism and world of false appearances are significant to Fitzgerald's style, especially because the author discovered in his own existence that all that glitters is not necessarily gold.à As much as Gatsby loves Daisy, she is far from a paragon of virtue.à As much as Gatsby is admired for his material success only two people attend his funeral.à The cynicism and nihilism in the novel are products of an era that was discovering that even the "American dream" is an illusion.à In Fitzgerald's style this is true even for heroes like Gatsby, a man who is described at the beginning of the novel as being in control of life to the point where he even owns a piece of nature: "Something in his leisurely movements and the secure position of his feet upon the lawn suggested that it was Mr.
Monday, January 13, 2020
Business of Being Born Essay
There is a culture of ââ¬Å"women-onlyâ⬠that runs rampant in spaces for pregnant women. Much of the talk is about how valuable women find the support of other women. It also excludes men from the process and experience of pregnancy, as much as they can experience it. Overall the film focuses on the fact that women have been told theyââ¬â¢re not responsible for their birth. Katsi Cook, a Mohawk women and Native womenââ¬â¢s health activist said she ââ¬Å"believes that the relationship of trust and respect between a woman and her midwife empowers the woman to ask questions and obtain the information she needs to make real choices about her health and life. (The Motherââ¬â¢s Milk Project, 611) In the film, Ricki Lake wanted to explore womenââ¬â¢s ââ¬Å"rite of passage,â⬠by giving the power back to the women. Thereââ¬â¢s this idea since hospitals are a business that once they ââ¬Å"facilitateâ⬠an intervention has been started and it becomes a domino effect after that. When these interventions have started, the questions: ââ¬Å"whatââ¬â¢s best for the baby? â⬠ââ¬Å"Is the baby going to benefit from this or not? â⬠need to be well thought out. According to Overview of Maternity, ââ¬Å"medical evidence shows that the routine use of unnecessary interventions put mothers and babies at risk. In the film Marsden Wagner M. D. , stated that there is no history of worthy obstetrical practices and careful studies of the long-term effects of the interventions. The United States has gotten away from midwifery starting in 1955, only 1% of births took place at home. The culture shift portrayed midwives as ââ¬Å"vestige of the old country. â⬠Midwives were understood as dirty, ignorant and illiterate. Now midwives are often perceived as unprepared. Once doctors started graduating from medical school, business took over the birthing process. Births then went into the hospitals and midwives did not follow. The concept of normal changed. Midwives often lack available and affordable malpractice insurance; because of this midwives are then perceived ââ¬Å"inferiorâ⬠to physicians. Overview of Maternity states ââ¬Å"Midwives recognize birth as a normal, natural process and support the use of less invasive techniques, such as position changes, waiting, hydrotherapy, and perinatal support, that carry fewer risks to mothers and babies and are usually more effective. â⬠Another effect the culture has on the lack of midwives is when the culture as a whole insinuates that birth s scary and dangerous. Yes, there will always be some sort of risks when it comes to birth. However, that is where I believe technology has had a positive effect on birth. More than less, we are now able to detect the dangers ahead of time. The film associates the amount of trust we put into hospitals and technology is reflected upon our infant-mortality rate. Our neonatal statistics are not the greatest. In the film midwives and hospitals are not looked to blame. It is our diverse population that distorts those statistics in where we stand in the world. The argument presented in this film to revitalize midwifery focused generally on the idea of pain suffered during birth was the only way to feel accomplished and provide love for their baby. However, I completely disagree. Women that undergo C-sections and even families that adopt can have the same amount of love for their children as the women that endure pain during birth do. Normal births are not medical issues, yet they may turn into life threatening issues within seconds. Not all women are the same, they have different difficulties, and some even have disabilities that impact their birthing process. Which then increases the risks. According to Overview of Maternity, ââ¬Å"Research shows that midwives are the safest birth attendants for most women, with lower infant and maternal mortality rates and fewer invasive interventions such as episiotomies and surgical births (cesareans). â⬠Optimum outcome of the mother and child is based on how open to suggestions we are with midwives and patient satisfaction. The validity of your options must always be questioned. The safety of the birthing process is going to vary depending on the training, patient choice, and circumstances on geographical constraints.
Sunday, January 5, 2020
The Journey Of One s Life Begins And Ends With The Self...
The journey of oneââ¬â¢s life begins and ends with the selfââ¬â¢s pursuit of personal identity, to answer the question ââ¬Å"Who Am Iâ⬠. The self attempts to sustain a stable association with its varying selves and the external world by constructing identities that are identified and explained through the roles, social comparisons, successes and failures, and judgments of others in oneââ¬â¢s external environment. The self is highly focused on itself, how it presents its self to others, and the impressions it makes upon them. The interaction between self-concept, self-esteem, self-efficiency, and the external environment evokes an outward representation of the self in the social world in which frequently commands affirmation, recognition, understanding, and readjustment. Social settings affect self-awareness and discrepancies in the environment (social status, age, gender) inspire distinct behaviors lead by self-interests and biases. Because the self is focused on how i t appears to others, it reshapes and redefines itself to fit various situations (Myers, 2010). Further understanding of the self is offered in the social experiences that have affected my personal development. The Self in the Social World An individualââ¬â¢s sense of self helps manage oneââ¬â¢s thoughts and actions (Myers, 2010). Information that is processed in reference to the self is generally remembered better than information that is less personally relevant (the self-reference effect) (Myers). Oneââ¬â¢s self-concept includes theShow MoreRelatedFreire s Theory Of The Oppressed And The Oppressor Collins, Brooks, And Kidd1628 Words à |à 7 PagesAs society continues to evolve people maintain their quest to accept full humanity, in this process individuals question not only who their authentic self is, but what is keeping them from accepting that version of themselves. A question which Freire addresses in his Pedagogy of the Oppressed as he emphasizes how liberation transcends time, and atmosphere. Instead he chooses to illustrate a process which is embodied by acceptance of the oppressor, activism, fellowship, solidarity, and reflectionRead Moreââ¬Å"One Out of Manyâ⬠by V.S. Naipaul1552 Words à |à 7 PagesOption 2 Short Stories Read ââ¬Å"One Out of Manyâ⬠by V.S. Naipaul (in the Anthology, A World of Difference, pp. 261-94). Discuss the ways in which the author explores the concept of freedom in the story. ââ¬Å"One Out of Manyâ⬠, a short story by the famous Trinidad-born British writer V. S. Naipaul, first published in his anthology In a Free State in 1973, is a story which concerns a young Indian man from Bombay who starts a new life and struggles with his own personal identity in the city of Washington DRead MoreThe Awakening Symbolism Essay1756 Words à |à 8 PagesAwakening to depict the feminist ideas involving women s longing for sexual and personal emancipation through the development of the main character, Edna Pontellier, as she recognizes the extent of her passion and ultimately the disappointment after the realization of her inevitable limitations in life. Symbolism is used to tell the story of Edna s journey toward self-discovery and the pursuit of her desires and freedom while defying Victorian society s expectations and her limited domestic female roleRead More On the Road: Jack Kerouacs Rejection of the Middle Class American Dream1597 Words à |à 7 PagesKeroua c was one of a group of young men who, immediately after the Second World War, protested against what they saw as the blandness, conformity and lack of cultural purpose of middle-class life in America. The priorities of people of their age, in the mainstream of society, were to get married, to move the suburbs, to have children and to accumulate wealth and possessions. Jack Kerouac and his friends consciously rejected this pursuit of stability and instead looked elsewhere for personal fulfillmentRead MoreCareer Goals : Career Choice3343 Words à |à 14 Pagesbegan their journey towards making their career dream true by taking the necessary courses, passing their examinations, and did what was required to enter the field of their choosing. Some are unsure of the career path they would like to follow and opinions of others on what they should do can lead to a road of uncertainty and confusion. Lastly, for various reasons there are people who are going through a period transitioning f rom one career choice to another. Regardless of which stage in life the individualRead MoreTennessee Williams : Understanding A Namesake3723 Words à |à 15 Pagescourse, like so many re-search pursuits, did not end up being the case. Instead, I found it to be far more frustrating and complex at times than I expected when I fully realized the gravity of this manââ¬â¢s work. Itââ¬â¢s beyond sexual politics, or commentary on issues we as an audience find applicable. What I have come to realize, is that this is a lifeââ¬âitââ¬â¢s a life in dialogue, and scenes, and productions. Through every story and character, Williams was cementing his identity the only way he knew how. ThroughRead MoreThe Invisible Man by Ralph Ellison2489 Words à |à 10 Pagesââ¬Å"I AM AN invisible man.â⬠A story of obstacles of durable struggle, but hope, and everlasting search for voice in a narrow-minded society; The Invisible Man by Ralph Ellison depicts the dehumanization and feeling of being ostracized in society, of one man. Imagine a time when everyone you encounter have a racial thought or credibility toward your own races, never considering the fact that who you are as a person does not matter worth a dime. You are better determines on shade of your skin which hideRead MoreCharacter analysis of Territory by David Leavitt2930 Words à |à 12 Pagesaccept her sonââ¬â¢s homosexual identity and his on-going struggle with internalized homophobia. The story opens with twenty-three year old Neil visiting his mother, Mrs. Campbell, at his childhood home. As they prepare for the first arrival of Neilââ¬â¢s lover, Wayne, the anticipation triggers anxieties both Neil, causing him to have painful flashbacks of the past. As these images reveal, Neil has lived with feelings of shame, embarrassment and guilt over his sexual identity, as well as an exposure to theRead MoreAn Intern At The University Public Relations Program2695 Words à |à 11 Pageswith each one, bu t the most interesting pattern I came across was that each of these organizations had their own preconceived notion on the definition (or application) of public relations. Some of these differences were simply minor details in strategy; others were based on completely different viewpoints altogether. With different industries came different points of emphasis, which inevitably led to different responsibilities at each. No matter the difference between each organization s views, IRead MoreEssay on Jack Kerouacs On the Road and Allen Ginsbergs Howl3843 Words à |à 16 PagesKerouacs On the Road and Allen Ginsbergs Howl Works Cited It was a 1951 TIME cover story, which dubbed the Beats a ââ¬ËSilent Generation, ââ¬â¢ that led to Allen Ginsbergââ¬â¢s retort in his poem ââ¬ËAmerica,ââ¬â¢ in which he vocalises a frustration at this loss of self- importance. The fifties Beat Generation, notably through Jack Kerouacââ¬â¢s On the Road and Allen Ginsbergââ¬â¢s Howl#61482; as will here be discussed, fought to revitalise individuality and revolutionise their censored society which seemed to produce everything
Saturday, December 28, 2019
Friday, December 20, 2019
Boom Period in the 1920 America - 852 Words
Boom Period in the 1920 America By the end of the First World War America was regarded as the most powerful and richest country in the world. In the 1920à ´s the United States economy was booming with success and increasing prosperity, in which a great deal of Americans, though certainly not all, shared. This period was also known as the roaring twentiesà ´. With a plentiful supply of raw materials (e.g. oil and coal) and the policy of isolation and containment in place, America soon became even more powerful and wealthier. America had great regional diversity, with each region contributing something different to the economy. In the South there was vast areas of farmland, cattle ranches andâ⬠¦show more contentâ⬠¦Cheap labour from an influx in immigrants helped the idea of mass production and the increase in factories and new industry. It was not only the car industry that expanded during the 1920s. With the help of the motor car industry, other industries started to grow, including the steel, rubber, glass, leather and oil industry. The construction industry grew due to the increase in traffic on the roads. Other consumer goods used the idea of mass production, causing a boom in the economy; radio sets, telephones, refrigerators, vacuum cleaners, washing machines and ovens were all being rapidly manufactured to serve the needs of the public. These new goods were attractive to the Americans, resulting in sales rocketing. The ability to buy these goods, was greatly helped by the introduction of credit facilities - hire purchase. This allowed people who could not afford the whole cost of the product to obtain it by paying for it in instalments over a certain period of time. Mail order also increased the market for goods into the more remote areas of America. Also, throughout the 1920s there was a great feeling of consumer confidence among the American people. Consumer spending was rocketing, and the stock-market was booming as share prices increased. Advertisements on the radio, in magazines,Show MoreRelatedEssay about The Roaring Twenties of the United States1474 Words à |à 6 Pages By the end of the First World War America was regarded as the most powerful and richest country in the world. In the 1920à ´s the United States economy was booming. This is a period of prosperity, when the countryà ´s economy is doing well and the people are sharing in it. This period was known as the roaring twentiesà ´. In this period many jobs were made more secure, many families had more to eat, electricity was widespreadRead MoreUsing the four passages and your own knowledge, assess the view that the impact of the First World War was the main reason for the booming economy in the USA in the 1920ââ¬â¢s1661 Words à |à 7 Pagesthe USA in the 1920ââ¬â¢s (40 Marks) I believe that the First World War did not have as much of a significant impact on the American economy as mass production, infact i however see that instead of benefiting the economy the War in fact had the reverse effect to that of which interpretation A and C suggest that the war was the most important factor of the 1920ââ¬â¢s American economic boom. Firstly, the biggest reason as to why mass production was the main reason for the economic boom was that the AmericanRead MoreEssay on Economic Expansions in 1920s1452 Words à |à 6 PagesDuring the 1920s, there was a rise in economy of the United States. The people of the United States and its territories enjoyed a prosperous life, as the economy grew 7 percent per year between 1922 and 1927. In this period, also referred as ââ¬Å"Roaring Twentiesâ⬠, there was high economic growth with increase in the living standards of Americans. According to the textbook, ââ¬Å"Nation of Nationsâ⬠, the reasons for the economic expansions in the nineteenth century were due to the boom in the industrial sectorRead MoreEssay on The Cause of the Economic Boom in the 1920s778 Words à |à 4 PagesThe Cause of the Economic Boom in the 1920s By the end of the First World War America was regarded as the most powerful and richest country in the world. In the 1920à ´s the United States economy was booming. This was a period of prosperity, when the countrys economy was doing well and some of the people were sharing in it. A long-term cause of the American boom in the 1920à ´s was Americas natural advantage and regional diversity. The South was mainly used for farmingRead More Causes of the Great Depression Essay1143 Words à |à 5 PagesDepression Throughout the 1920ââ¬â¢s, new industries and new methods of production led to prosperity in America. America was able to use its great supply of raw materials to produce steel, chemicals, glass, and machinery that became the foundation of an enormous boom in consumer goods (Samuelson, 2). Many US citizens invested on the stock market, speculating to make a quick profit. This great prosperity ended in October 1929. People began to fear that the boom was going to end, the stock marketRead MoreAmerica in the 1920s729 Words à |à 3 PagesAmerica in the 1920s, also known as the Roaring 20s or New Era, was a time of great changes and huge growth. America was being a more modern nation, and a return to normalcy was being seen after the Progressive Movement and First World War. Politically, the American government was seemingly conservative, but experimented with different approaches to public policy and foreign diplomatic policy. Economically, it was a time of tremendous growth and ne w forms of organization. Socially, the American popularRead MoreThe New York Stock Market1635 Words à |à 7 PagesThe stock market is filled with individuals who know the price of everything, but the value of nothing,â⬠is a relevant quote relating to the stock market during the 1920s quoted by Phillip Fisher, one of the most influential investors. The booming years of the 1920s, stocks and bonds were being sold at higher values than people could invest. Customers, banks and investors took money out of their pink piggy banks and embarked on investing in the New York Exchange Stock Exchange, nicknamed ââ¬Å"Big Boardâ⬠Read MoreThe Essence Of The 1920 S1659 Words à |à 7 PagesThe Essence of the 1920ââ¬â¢s in The Great Gatsby ââ¬Å"The Roaring Twenties was the period of great American prosperity which was built on shaky foundations.â⬠For decades, the 1920ââ¬â¢s have been interpreted as a period of economic prosperity and social change in which the novel The Great Gatsby was born. In the early 1920ââ¬â¢s, the United States experienced a period of immense reorganization of social and economical life; therefore, this post- World War I era became referred to as ââ¬Å"The Roaring 20ââ¬â¢sâ⬠, ââ¬Å"The JazzRead More The Economic Boom of the 1920s Essay1170 Words à |à 5 PagesThe Economic Boom of the 1920s After the First World War America was a completely different country. The twenties was a very unusual time period in American History. The twenties were a time of fun and partying. There are many reasons why it was called the Roaring Twenties. Most of the American people were living a great life and were able to afford luxury items, even though this didnt apply to every one many believed that it was excellent and exciting a time of great hopes. In the twentiesRead MoreEssay on Life Changes of Americans in the 1920s568 Words à |à 3 PagesLife Changes of Americans in the 1920s In the 1920s many American lives were improved greatly, but some lives were as bad as they had been before. The economy was booming, with cars being mass produced, and many other consumer goods such as radios, were widely available. Also more jobs became available, and many people recieved a par rise. However there were bad things such as racism about. Many ethnic minority groups were treated poorly. The most racist group around
Wednesday, December 11, 2019
Constitutional Law Parliamentary Sovereignty
Question: Evaluate the accuracy of Alders assessment of Parliamentary Supremacy today. Your analysis must include not only domestic challenges to the doctrine but, in addition, the impact of any international law which has been incorporated into UK law? Answer: Introduction: Parliamentary sovereignty is a vital concept in the aspect of constitutional law. According to this concept, the parliament is supreme over all other organs of the government. The government has three organs which includes executive, judiciary and legislative. Now according to this theory the legislature enjoys the superior power among these three organs. According to this theory, the parliament can make create any law freshly, and it does not depend on any precedent or executive actions. The theory can collide with the theory of separation of power theory that generally limits the power of the legislature. This theory also restricts the scope of judicial review by which the judiciary can judge the validity of any legislations passed by the legislature. The United Kingdom is the state where the parliamentary sovereignty is very prominent. In UK, there are two kinds of sovereignty which includes legal and political aspect. In the aspect of UK, parliament is not politically sovereign. If the parliament constructs any unwanted or impractical laws, that will not applied in the practical sense. But that does not include the concept that parliament is not a legally sovereign entity. In the light of the case of Madzimbamuto v Lardner-Burke, it was claimed by Lord Reid that certain things are considered to be impractical or unconstitutional for the parliament of UK. But that thing does not mean that Parliament has no authority to do the act. If the action is taken by the parliament, the court merely does not invalidate the law or the authority of the parliament. Alders evaluation in regards to Parliamentary Supremacy: The principle of parliamentary supremacy states that parliament posses the ultimate power to enact any law, and the decision cannot be overridden by any other authority or organ of government. In the case of, Jackson v A-Git was stated that this is the most important doctrines in the British Constitution. Alder in his book state that state that the classic theory of parliamentary supremacy was given by A.V. Dicey. Parliamentary supremacy considered to be legal but opposed to the principle of political theory because it defines that the parliament is above al. In the case of Pickin V British Railway Boardstates that for the action of parliamentary supremacy the valid laws might be predestined as unconstitutional in the broader political aspect. According to Alder judges, recognised the constitutional law and politics are not separated with each other. R v Secretary of State for Foreign and Commonwealth Affairs is the important case in this aspect which states that the exclusive power of Parliament drives from its representative character. Jackson v A-G the important case on which Lord Hope describe that the principle of parliamentary sovereignty is an ineffective principle that has no validity if the parliament passes unambiguous, unconstitutional or unacceptable principle that the people of the country will not try to recognise as law. Dicey distinguishes the political and legal sovereignty. According to Dicey legal sovereignty, includes that the power of the lawmaker is absolute and conditional. But the political sense that that the law must be maintained which is recognised by the populations of the nation. Alder criticised the view of Dicey and state that Dicey by his theory indicates that the electorate even though today it might somewhat be the monetary or expert network with advantaged access to politicians. The internal and external political limits on the lawmakers are described by Dicey. The internal limits refer to the inherent rules and practice with the parliament. In the Parliament, an amalgamation of the conventions needs the Queen to consent to the entire legislations. The political and ethical pressures imposed by the conventions are also the part of internal limits partially. The external limits comprise of all the matters which deals with the people on whom the law is going to apply. But in reality according to Alden, the parliament cannot pass any law according to its wish. Alder in his book specifies that the version of Dicey in regards to the doctrine of parliamentary supremacy is in question. The theory states that the concept required external requirements and under the common law legal system the ultimate guardian of the Constitution is court. So, it can be confirmed that the concept of parliamentary supremacy is obsolete if it lose the public support. The theory of Alder is a modern concept. He describes the concept of parliamentary supremacy on the light of UK. He claimed that. As UK has no written constitution, so the foundation of parliamentary sovereignty is not a clear concept. Alder criticized that it is not desirable that all the legal power is confined to just an organ of the government. So, the alteration in the theory is required. The parliamentary sovereignty theory is based on the test of time and its applicability and adaptation. The theory based on the political ideology. If the ideology is changing, the concept of the doctrine will also change. In the case of R (Factortame Ltd) v Secretary of State for Transport, it was decided by Lord Bridge that the parliamentary supremacy concept can be modified by the parliament itself. According to revival theory, this concept is extracted from common law constitutionalism. So, therefore the courts are obeying the rule made by the parliament. In the case of Jackson v. A-G, it c ase claimed that this concept can be established by common law in the absence of the higher authority. In his theory, Alder described the challenges of parliamentary sovereignty. There were several arguments that indicate the fact that the parliament can also be legally limited. Alder claimed that the basis of this doctrine relied upon the acceptance from the subjects of a nation. Primarily this doctrine was developed as a historical response to the then political situation. It is initiated to reduce the dictatorship of the monarch. But the approached changed every day. The old conceptualisation of this doctrine is become obsolete now. Dicey provide his theory at the Victorian period that may be suitable for that occasion. The citizen of England was to some extent benefited by that system. The reason is that it relieves them from the mismanagement of the spoil empire. But presently this theory is out of date. The doctrine seems to be unreal, narrow-minded, rationally tattered. Certain internal and external forces made this theory outdated for the present situation. The forces can be c lassified as domestic and as well as the international sources. The sources include global economy, decentralization, delegation, membership in EU, related international obligation and increasing the power of the executive organ of the parliament. Alder claimed that there was no relevance of the doctrine in the modern context. The reason is that there is no political agreement that the parliament must hold the supreme legal authority. There is no such legally resonating also. Alder identifies the major challenges to the theory. The main question arises in this context is that if the UK parliament made any law regarding the independence of the certain territory, later on whether the parliament enjoys the right to amend the decision? In the decision of Blackburn v. A-G, Lord Denning states that if any principle become totally out of the line, that principle needs the reconsideration. Evaluation of the theory of Alder in the modern context: The theory developed by Alder in regards to parliamentary supremacy is very relevant in the modern context. He opposed the view of Dicey. He explained that the parliamentary supremacy is not absolute, and it depends on the acceptability of the subjects. He claimed and identified different domestic issues regarding the applicability of parliamentary supremacy theory as a whole. The relevance of the theory can be judged by defining the lope holes of the doctrine of parliamentary supremacy. The British administration by the asset of Royal Prerogative has an authority to go into any international treaty that can join the nation. On the other hand, the principle of parliamentary supremacy entails that no modification of the privileges of British people without the consent of Parliament. These privileges can be modified merely by other legislation of Parliament. Accordingly, if the United Kingdom does not desire to be in contravention of its international responsibilities, the Parliament needs to fit in international law under the law the United Kingdom. The ascendancy of International law was decided in the case of ECJ in Costa v. ENEL in 1964. It reflects the detail that international law is greater to domestic laws. On the other hand, International law takes priority in the situation of a clash with requirements of domestic law. Furthermore, these requirements were prepared, so International laws are higher still to that domestic law that were ratified later. It was decided before the privileges of persons within the United Kingdom can be modified just by legislations of Parliament. For that reason, the Parliament needs to pass a law that included the requirements of Lisbon Treaty to the United Kingdom law, to that these requirements are in action in the territory of United Kingdom.In consideration of the principle of parliamentary supremacy taken into deliberation, particularly two sections of that Act is supposed to be scrutinised. On the other hand, the Lisbon Treaty launched a significant condition that openly corroborates the privilege of Member States to remove from the European Union. It is mentioned in Article 50of TEU. These stipulations highlight the disagreement that United Kingdom remains abide by the EU law as extended as the Parliament desires to stay in the EU. Consequently, it should be confirmed that the amalgamation of that Lisbon Treaty into the United Kingdom regulation must put the principle of parliamentary supremacy under supplementary damage and in hypothesis this principle still triumph in the domestic law of theUnited Kingdom. uropean Communities Act 1972 put into practice the Trea Dicey considered Parliament as protector of elementary rights and as elected council of citizens most excellently placed to the equilibrium of human rights with the community interest. Conventionally the judges establish that elementary rights might beshortenedby Parliament in the interest of the public. In the case of Entick v Carrington the decision was taken by the court. TheHuman Rights Act 1998comprises theEuropean Convention on Human Rightsand is a legitimate foundation. Section 3 of theHuman Rights Act 1998needs courtsas far as probableto interprets the domestic law as well-matched with the right of Convention. The judges obtain a purposive outlook to do so as mentioned in the case of Ghaidan v Godin-Mendoza. Section 4 of the Human Rights Act 1998permits the High Court and other courts to set aside legislations that are unsuited with Conventional rights so far. Section 10 of theHuman Rights Act 1998let the administration formulate delegated legislationcorrective instructions, which Parliament have to support. There is no compulsion to do that, but the political force to do that has the guide to some conflicting it has turned out to be a constitutional conference for the matter to be cured when recognized in this method. Section 19 of theHuman Rights Act 1998needs a Minister to construct declaration of compatibility for the fresh law on this permits the court to assume the Act is supposed to be interpreting in a companionable manner. An administration may also make a decision to carry on with legislation that is not well-suited. Section 6 of theHRAmakes it unlawful for public authority act in way incompatible with Convention privileges; this might be superseded by legislation and but never includes aperson works out purpose in association with events in Parliament. Decentralization has a negligible effect on the Parliamentary Supremacy Doctrine. TheScotland Act 1998permits the Scottish assembly to construct on non-reserved regions like health and education but not on the reserved areas like, as overseas policy, defence r the matters constitution. It performs in the same way to a central constitution, wherever the Scottish assembly is a secondary parliament and could not make law for England Wales. Theadministration of Wales Act 1998gives authority to the Welsh legislature to create delegated legislation, not legislations and theadministration of Wales Act 2006expands these to some extent improved legislative power mentioned as assembly power. The European Court of Justice renownedthat all members have partial sovereign privileges, although within restricted fieldsas mentioned in the case of Costa v ENEL. If the United Kingdom violates a conventional compulsion, it will be assumed that it violates international law and countenance action in ECJ. If a pact necessitates a modification of law, legislative body must approve the employed legislation and judges will merely implement if the agreement compulsion has been passed in domestic law as mentioned in the case of Blackburn v Attorney-General. TheEuropean Communities Act 1972put into practice theTreaty of Accession 1972. Section 2(1) of the European Communities Act 1972gives the consequence in the United Kingdom to straight appropriation. Section 2(4) needs United Kingdom judges to provide precedence to directly effectual EU legal rules. EU law can be unswervingly effective if it is obvious, accurate and unqualified. InLitster v Forth Dry Docks, where the national legislation had been put into practice to provide outcome to an EU command it was understand by applying purposive approach, in spite of the decision being opposing to the factual connotation of that Act. On the other hand, the judges will not acquire a purposive study if it generates abendof domestic law as mentioned in the case of Webb v EMO Air Cargo. State accountability may happen from breakdown to enact any Act, which provide the generous result to EU law or faulty completion and can guide to the judges presentation compensation for the loss. EU law can also weaken the role of assembly as the protector of privileges. To declare the doctrine of parliamentary supremacy, the legislation European Union Act 2011needs a reminder before the United Kingdom concur treaty alteration or additional transport of authority to the European Union. The Act also creates Parliamentary preeminence a constitutional principle. Conclusion: After all the discussion, it can be confirmed the theory of A.V. Dicey regarding the parliamentary sovereignty is not suitable fully in the modern context. Alder criticized the theory and stated that the parliamentary supremacy depends on the acceptance or desire of the people or subjects. The theory of Alder is more acceptable in the modern concept. The parliamentary supremacy is a concept that creates the issue to those international laws that are incorporated in the law of United Kingdom. The paper identifies several domestic as well as international aspects where the theory creates the problem in modern context. So, the theory of parliamentary supremacy, as provided by Dicey, cannot be acceptable fully in the contemporary world. References Alder J and others,General Principles Of Constitutional And Administrative Law(Palgrave Macmillan 2002) Alder J,Constitutional And Administrative Law(10th edn, Palgrave Macmillan 2015) Aldous G and Alder J,Applications For Judicial Review(Butterworths 1985) Barnett H,Constitutional Administrative Law(Routledge-Cavendish 2006) Clment D, 'The Royal Commission On Espionage And The Spy Trials Of 1946-9: A Case Study In Parliamentary Supremacy' (2000) 11 Journal of the Canadian Historical Association Davis F, 'Parliamentary Supremacy And The Re-Invigoration Of Institutional Dialogue In The UK' (2012) 67 Parliamentary Affairs Doig A, 'NEXT STEPS TO THE SUPREMACY OF PARLIAMENT?' (1996) 49 Parliamentary Affairs Flaherty M, 'The Empire Strikes Back: Annesley V. Sherlock And The Triumph Of Imperial Parliamentary Supremacy' (1987) 87 Columbia Law Review Hatchard J and Slinn P,Parliamentary Supremacy And Judicial Independence(Taylor Francis 2003) Kurland P and Casper G,Landmark Briefs And Arguments Of The Supreme Court Of The United States, Constitutional Law(University Publications 1975) MacKay R, 'Coke: Parliamentary Sovereignty Or The Supremacy Of The Law?' (1924) 22 Michigan Law Review McCullough H, 'PARLIAMENTARY SUPREMACY AND A CONSTITUTIONAL GRID: THE CANADIAN CHARTER OF RIGHTS' (1992) 41 Int Comp Law Q Parpworth N and Pollard D,Constitutional And Administrative Law(Oxford University Press 2006) Rose-Ackerman S and Lindseth P,Comparative Administrative Law(Edward Elgar 2010) RUSSELL C, 'Parliament, The Royal Supremacy And The Church' (2000) 19 Parliamentary History Young A,Parliamentary Sovereignty And The Human Rights Act(Hart Pub 2009) Blackburn v A-G(1971) 1 WLR Costa v ENEL[1964] ECR Entick v Carrington[1765] EWHC KB J Jackson v A-G (2006)(2006) 1 AC Litster v Forth Dry Docks[1988] UKHL Madzimbamuto v Lardner-Burke(1969) 1 AC Pickin V British Railway Board[1974] AC R (Factortame Ltd) v Secretary of State for Transport[1996] QB R v Secretary of State for Foreign and Commonwealth Affairs(2008) 4 All ER Webb v EMO Air Cargo(1994) 4 All ER
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