Genetic Engineering is Unethical :: Genetic Engineering Essays

Genetic engineering is a technology that has been created to alter DNA of different species to try and make them more improved. This essay will discuss the eugenics, the religious point of view about genetic engineering, genetically modified food and the genetic screening of embryos. In this essay it will be said wether genetic engineering is ethical or unethical. During 1924 Hitler said that everyone needs to be blond hair, blue eyes and white. This is known as Eugenics, thanks to a new science known as biotechnology in a few decades? people can custom make their children. The DNA can be changed so that the child?s appearance is altered and if they had a disease the scientist can take out the disease that causes it. Just because scientists can take out a gene that causes the disease how do they know that another disease can be created? They don?t that?s why many people don?t believe in designer children. If we start genetically modifying people ?We are going to have? as much knowledge? as much power as God.? In a way scientists that genetically modify do not have the right to do it. Scientists are considered to be playing God because they have come up with the technology and change species DNA so they look or behaviour completely different. Humans have forgotten that they are not God they cannot change people. Genetically modifying food is an advantage for Australia because without genetically modified food we would not be able to maintain our role in agriculture. Genetically modified food grows faster, costs less and lasts longer. An argument put forward about genetically modified food is that because it is cheaper and more can be produced the poorer countries can have genetically modified food and hopefully less people will die. The problem with this is that to set up a place where food is genetically modified and to hire people to modify the food is very expensive and if they are poorer countries there is a big chance they can not afford it. The procedure of genetic screening embryos allows the finding of a defective gene in an embryo. In many countries there is already a widespread programme to screen for the chromosome abnormality. Since this technology can change the information at the level of individual?

Evidence-based practice Essay

Evidence-based practice (EBP) is a system of incorporating research findings into nursing practice so as to improve the therapeutic outcomes. (Polit, F. D & Beck, T. C, 2010). â€Å"The evidence based practice places particular emphasis on the use of evidence, in particular research findings, in clinical decision making†. (Parahoo, K, 2006). During past clinical exposures, the issues regarding post natal depression were found as a less explored one because of the complex involvement of both mental health nursing and maternal and child health nursing. â€Å"Postpartum psychosis is a manifestation of a life time vulnerability to affective disorders with child birth as the precipitating factor† (Spinelli, M. G, 2009).The focused clinical question discussed here, which is an important element in an evidence based practice is as follows; How effective is the education of nurses about postpartum depression in helping to identify and reduce postpartum depression among new moth ers in a maternal ward or community?. According to the PICOT strategy for formulating EBP questions, here, the population is ‘new mothers’, the intervention is education of nurses about postpartum depression and outcome is ‘identify and reduce postpartum depression’. The clinical settings chosen for this focused clinical question is maternal ward in a hospital as well as community settings. It is based on the general assumption that initial care will be given in a Hospital maternal ward followed by contact care given in community settings. Having a baby is a joyous moment, but for some women it also brings worries as well as stress. Many recent study reports highlight alarming rates of occurrence of post natal depression. About 10% of new mothers suffer from the most severe form of post natal depression.(Science Daily, 2010). It is evident that, being the closest aid of a post natal delivered woman, maternal and child health nurse can do a lot in identifying and reducing post natal depression. Here, an attempt is made to explore and analyse the educational aspect of nurses in alleviating the said problem. The online databases chosen for this assignment is CINAHL (Cumulative Index to Nursing and Allied Health Literature) . A systematic search stra tegy has been carried out using key words such as postnatal depression, postnatal emotional disturbance, puerperal depression, perinatal depression, psychosis, nursing care, nurse knowledge, nursing care, and education. More than 700 results were yielded initially when postnatal depression used as the key words. The  results were narrowed by choosing the publication dates between January 2000 and December 2010. Results were further sorted by re arranging them in a date descending order and a suitable article titled ‘Detection, treatment and referral of perinatal depression and anxiety by obstetrical providers’(Goodman ,J,H, Tyer-Viola, L, 2010) obtained. Key words were combined by using Boolean operator ‘AND’. The combination of key words postnatal depression and nursing interventions generated 4 results, and among them, two results with titles, ‘Improving the postnatal outcomes of new mothers’ (Morse C, Durkin S, Buist A, and Milgrom J, 2004) and Comparison of effects of nursing care to problem solving training on levels of depressive symptoms in post partum women’ (Tezel, A and Gozum, S, 2006) were found relevant for the focused clinical question.

What Can Raise Awareness Of Sustainable Consumption Of...

Introduction: Many consumers aren’t educated on the importance of sustainability of clothing and textiles. The media mistakenly represents sustainability and the influence it can have on the environment. This research paper will attempt to address the question of what could raise awareness of sustainable consumption of textiles for college students. Consumers should all be aware of how they can conserve the environment by preserving clothing which is a concept that many people have not acknowledged. This study is imperative to make this knowledgeable to pop culture and the developing generation consumers to settle all perceptions of sustainability. Sustainable fashion, also known as eco fashion, is the use of resources to construct fashion that is environmentally friendly. Sustainability in fashion is important because the goal is to preserve the environment and help improve instead of taking away from it with harsh resources. The purpose of the study was to examine the knowledge students have on sustainable fashions, in addition, examining how the awareness amongst peers and how the globalization of the awareness can change the fashion industry as a whole. Background: Early endorsers of Sustainability deemed that increased globalization and association of the world’s finances would automatically raise the economics’ well-being of all people in the world. An abundance of adopters began to have second thoughts after seeing the disarray caused by free trade agreements,Show MoreRelatedStrategic Analysis of Sabmiller16462 Words   |  66 PagesPietermaritzburg named George Raw. Neither of them knew anything about brewing, but they persuaded the local residents to help establish the Natal Brewery Syndicate. After purchasing a factory site, Frederick Mead returned to England to procure machinery and raise capital. In need of brewing expertise, Mead approached W.H. Hackblock, head of Morgans Brewery in Norwich. The two men became friends and Hackblock agreed to serve as chairman of Meads company, which was registered in 1890 as the Natal Brewery SyndicateRead MoreStrategic Analysis of Sabmiller16447 Words   |  66 PagesPietermaritzburg n amed George Raw. Neither of them knew anything about brewing, but they persuaded the local residents to help establish the Natal Brewery Syndicate. After purchasing a factory site, Frederick Mead returned to England to procure machinery and raise capital. In need of brewing expertise, Mead approached W.H. Hackblock, head of Morgans Brewery in Norwich. The two men became friends and Hackblock agreed to serve as chairman of Meads company, which was registered in 1890 as the Natal Brewery SyndicateRead MoreHemp Cultivation in China42289 Words   |  170 PagesShandong cultivation 57 Letters 59 Fiber hemp cultivars 66 Medical Cannabis review 74 New cannabinoid antiemetic 76 Ukranian seed 79 Tasmanian research 82 Interview 86 ICRS symposium 88 Colorado hemp act 92 Canada report 96 Austria report 98 German textiles 101 Book reviews 103 NAIHF 104 Debate Corner 106 Journal of the International Hemp Association, Volume 2, Number 2, 1995 58 DEAR MEMBERSHIP First, we owe our readers and authors an apology for all of the typographic errors and other mistakesRead MoreBackground Inditex, One of the Worlds Largest Fashion Distributors, Has Eight Major Sales Formats - Zara, Pull and Bear, Massimo Dutti, Bershka, Stradivarius, Oysho, Zara Home Y Kiddys Class- with 3.147 Stores in 70100262 Words   |  402 Pagesmanagement of environmental and social aspects in the supply chain Case studies from the textile sector Doctoral dissertation the international institute for industrial environmental economics Lund University, Sweden  IIIEE DISSERTATIONS 2009:2  Responsibility in the Supply Chain Interorganisational management of environmental and social aspects in the supply chain Case studies from the textile sector Beatrice KOGG Doctoral Dissertation May 2009 The International InstituteRead MoreChina in Africa Essay20116 Words   |  81 Pageswhich NAI is an active member, is presented through three contributions. Photo by Susanne Linderos News from the Nordic Africa Institute 3/2007  First, we bring you an interview with the AEGIS Chair, Professor Patrick Chabal of King’s College, London. Secondly we provide a summary of ongoing work relating to the evaluation of academic results in African studies in the European countries. Finally there is a report from this year’s European Conference on African Studies (ECAS 2) in LeidenRead MoreAn Impact Assessment of Science and Technology Policy on National Development of Nigeria61708 Words   |  247 Pagesof RIs Staff based on Activities 4.5 Awareness of the Existence of an ST Policy 4.6 Accessibility of ST Policy to the Public 4.7 ST as Determinants of Development Performance in Nigeria 4.8 Contribution of ST Policy to Competitiveness and Economic Growth 4.9 Role of ST Policy on National Development of Nigeria 4.10 Impact of Lack of Demand for Innovation 4.11 Evaluation of Impact of ST Policy in Addressing Societal Needs 4.12 Lack of Awareness and Contribution of Nigerians to ST Policy Read MoreUnited Arab of Emirates Country Notebook18844 Words   |  76 Pagesrainfall often reaches 350 mm (13.8 in). Rain in the coastal region falls in short, torrential bursts during the summer months, sometimes resulting in floods in ordinarily dry wadi beds. The region is prone to occasional, violent dust storms which can severely reduce visibility. The Jebel Jais mountain cluster in Ras Al Khaimah has experienced snow only twice since records began. C- Topography The United Arab Emirates consists mainly of sandy desert. It is bounded on the west by an immense SebekaRead Morepaul hoang answers72561 Words   |  291 Pagesinstallment, I have put together answers/solutions to all 217 case studies. I hope you will find these solutions as a useful starting point. As with all BM mark schemes, the solutions in this Answer Book should be used with caution and flexibility. Students who take an alternative approach to the suggested solutions should still be credited where appropriate; teachers should use their professional judgment in such cases. Since the Answer Book is 178 pages long, colleagues may find the use of ‘shortRead MoreUnited Arab of Emirates Country Notebook18844 Words   |  76 Pagesrainfall often reaches 350 mm (13.8 in). Rain in the coastal region falls in short, torrential bursts during the summer months, sometimes resulting in floods in ordinarily dry wadi beds. The region is prone to occasional, violent dust storms which can severely reduce visibility. The Jebel Jais mountain cluster in Ras Al Khaimah has experienced snow only twice since records began. C- Topography The United Arab Emirates consists mainly of sandy desert. It is bounded on the west by an immense SebekaRead MoreCase Study148348 Words   |  594 Pagesresponsible for the content of third party internet sites. ISBN: 978-0-273-73557-1 (printed) ISBN: 978-0-273-73552-6 (web) All rights reserved. Permission is hereby given for the material in this publication to be reproduced for OHP transparencies and student handouts, without express permission of the Publishers, for educational purposes only. In all other cases, no part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical

What Is a Free Radical in Chemistry

An atom or molecule with an unpaired electron. Because they have a free electron, such molecules are highly reactive. Examples Singlet oxygen, molecules with a free hydroxy group (-OH) Properties Free radicals are capable  of  starting rapid  chain-reactions  that  destabilize  the ions in other nearby  molecules  generating  more  free  radicals. In biological systems, free radicals are  deactivated  by  anti-oxidants,  uric  acid,  and  certain  enzyme  activities.

ITC Product Mix, BCG Matrix - 1040 Words

IMPERIAL TOBACCO COMPANY ITC is an Indian conglomerate ï  µ ï  µ ï  µ ï  µ ï  µ ï  µ Headquartered in Kolkata Currently headed by Yogesh Chander Deveshwar. Employs over 26,000 people at more than 60 locations across India and is listed on FORBES 2000. Annual turnover - over US$ 7 billion (44000 cr) Market capitalisation - US$ 45 billion (283,000 cr) Business Segments ï  µ Fast Moving Consumer Goods (FMCG) ï  µ Hotels ï  µ Paperboards ï  µ Paper Packaging ï  µ Agri Business History ï  µ Incorporated on August 24, 1910 under the name Imperial Tobacco Company of India Limited ï  µ Company was changed from Imperial Tobacco Company of India Limited to India Tobacco Company Limited in 1970 and then to I.T.C.†¦show more content†¦Ã¯  µ Dogs, more charitably called pets, are units with low market share in a mature, slow-growing industry. These units typically break even, generating barely enough cash to maintain the businesss market share. They depress a profitable companys return on assets. Dogs, it is thought, should be sold off. ï  µ Question marks (also known as problem children) are business operating in a high market growth, but having a low market share. They are a starting point for most businesses. Question marks have a potential to gain market share and become stars, and eventually cash cows when market growth slows. Question marks must be analyzed carefully in order to determine whether they are worth the investment required to grow market share. ï  µ Stars are units with a high market share in a fast-growing industry. They are successful question marks and become a market leader in a high growth sector. The hope is that stars become next cash cows. Stars require high funding to fight competitions and maintain a growth rate. When growth slows, if they have been able to maintain their category leadership stars become cash cows, else they become dogs due to low relative market share. BCG Matrix - ITC Stars †¢ Hotels †¢ Paperboards / Packaging †¢Agri business Cows †¢ FMCG - Cigarettes †¢ Matches / Incense Sticks ? †¢ FMCG Dogs Ansoff‟s Matrix Existing New Existing Market penetration New product development NewShow MoreRelatedStrategic Management5568 Words   |  23 Pagesin an organizational strategy: a. Six 5. The three important steps in SWOT analysis are: b. Opportunities, Threats, Strengths 6. GE matrix consists of how many cells? a. Nine cells 7. Which of these is the type of Games: d. All of the above 8. SBU stands for c. Strategic Business Unit 9. The BCG matrix is known as: a. Growth share matrix 10. ______________ specifies sales revenues and selling distribution and marketing costs. b. Sales budget ________________________________________ Read MoreBcg Matrix Analysis2570 Words   |  11 PagesBCG Matrix Model BCG Matrix Model The BCG matrix or also called BCG model relates to marketing. The BCG model is a well-known portfolio management tool used in product life cycle theory. BCG matrix is often used to prioritize which products within company product mix get more funding and attention. The BCG matrix model is a portfolio planning model developed by Bruce Henderson of the Boston Consulting Group in the early 1970s. The BCG model is based on classification of products (and implicitlyRead MoreAmul Ice Cream1721 Words   |  7 PagesIt gave the entire industry a unique dimension. The success of Amul can be attributed to its distinctive planning of marketing mix and providing satisfaction to consumer needs. The analysis of this case will highlight the key marketing strategies adopted by Amul to become a market leader. 4 P’s of Marketing Mix: Amul brought in many changes in its 4 P’s of marketing mix, which helped it carve a niche for itself in the market. ANALYSIS OF THERead MoreCrocs Marketing Plan14993 Words   |  60 PagesCrocs’ brand portfolio and new footwear products should attract new segments and increase the target market. Rather than entering new markets, Crocs should stick to its core business of creating quality footwear and use its Croslite material for the new types of footwear. A new fresh and cool brand called Gators will carry sneakers, athletic shoes and casual shoes to attract the teenager segment. Further reorganizing will result in expanding the Crocs product line to carry 350 styles. By further developingRead MoreCustomer Satisfaction on Marketing Mix of Lux Soap7469 Words   |  30 Pagesin the market. The objective of the study is to see customer satisfaction about marketing mix of LUX soap. 1.2 Significance This report is a requirement of the program for MBA program. We have tried our level best to make it as an excellent one. We used all the latest data and information. The report can help as the indicator of the level of satisfaction of the customers of the LUX soap and its marketing mix. It provides the true practice taking place in the marketing industry, which plays an importantRead MoreProject – Organization Dynamics11615 Words   |  47 Pagesvariables. How would you describe the environment, goals, culture, size, and technology for Aquarius? 2. Design a new organization structure that takes into consideration the contextual variables in the case and the information flows. 3. Would a matrix structure be feasible for Aquarius? Why or why not? Case Study 2: C C GROCERY STORES, INC. 1. 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Nosql Free Essays

Security Issues in NoSQL Databases Lior Okman Deutsche Telekom Laboratories at Ben-Gurion University, Beer-Sheva, Israel Nurit Gal-Oz, Yaron Gonen, Ehud Gudes Deutsche Telekom Laboratories at Ben-Gurion University, and Dept of Computer Science, Ben-Gurion University, Beer-Sheva, Israel Jenny Abramov Deutsche Telekom Laboratories at Ben-Gurion University and Dept of Information Systems Eng. Ben-Gurion University, Beer-Sheva, Israel Abstract—The recent advance in cloud computing and distributed web applications has created the need to store large amount of data in distributed databases that provide high availability and scalability. In recent years, a growing number of companies have adopted various types of non-relational databases, commonly referred to as NoSQL databases, and as the applications they serve emerge, they gain extensive market interest. We will write a custom essay sample on Nosql or any similar topic only for you Order Now These new database systems are not relational by definition and therefore they do not support full SQL functionality. Moreover, as opposed to relational databases they trade consistency and security for performance and scalability. As increasingly sensitive data is being stored in NoSQL databases, security issues become growing concerns. This paper reviews two of the most popular NoSQL databases Cassandra and MongoDB) and outlines their main security features and problems. Index Terms—NoSQL; Security; Cassandra; MongoDB; I. INTRODUCTION The recent advance in cloud computing and distributed web applications has created the need to store large amount of data in distributed databases that provide high availability and scalability. In recent years, a growing number of companies have adopted various types of non-relational databases, commonly referred to as NoSQL databases and as the applications they serve emerge, they gained extensive market interest. Different NoSQL databases t ake different approaches. Their primary advantage is that, unlike relational databases, they handle unstructured data such as documents, e-mail, multimedia and social media efficiently. The common features of NoSQL databases can be summarized as: high scalability and reliability, very simple data model, very simple (primitive) query language, lack of mechanism for handling and managing data consistency and integrity constraints maintenance(e. g. , foreign keys), and almost no support for security at the database level. The CAP theorem introduced by Eric Brewer [1], refers to the three properties of shared-data systems namely data onsistency, system availability and tolerance to network partitions. The theorem [2] states that only two of these three properties can be simultaneously provided by the system. Traditional DBMS designers have prioritized the consistency and availability properties. The rise of large web applications and distributed data systems, makes the partition-tolerance property inevitable, thu s imposing compromise on either consistency or availability. The main promoters of NOSQL databases are Web 2. 0 companies with huge, growing data and infrastructure needs such as Amazon and Google. The Dynamo technology developed t Amazon [3] and the Bigtable distributed storage system developed at Google [4], have inspired many of today’s NoSQL applications. In this paper we analyze the security problems of two of the most popular NoSQL databases, namely: Cassandra and MongoDB. Cassandra [5] is a distributed storage system for managing very large amounts of structured data spread out across many commodity servers, while providing highly available service with no single point of failure. Cassandra aims to run on top of an infrastructure of hundreds of nodes. At this scale, components fail often and Cassandra is designed to survive these failures. While in many ways Cassandra resembles a database and shares many design and implementation strategies therewith, Cassandra does not support a full relational data model; instead, it provides clients with a simple data model that supports dynamic control over data layout and format. Cassandra was designed to support the Inbox search feature of Facebook [6]. As such it can support over 100 million users which use the system continuously. MongoDB [7] is a document database developed by 10gen. It manages collections of JSON-like documents. Many applications can thus model data in a more natural way, as data can e nested in complex hierarchies and still be query-able and indexable. Documents are stored in collections, and collections are in turn stored in a database. A collection is similar to a table in relational DBMS, but a collection lacks any schema. MongoDB also provides high availability and scalability by using Shardings and Replica sets (see below). The increasing popularity of NoSQL databases such as Cassandra and MongoDB and the large amounts of userrelated sensitive information stored in these databases raise the concern for the confidentiality and privacy of the data and the security provided by these systems. In this paper we review the main security features and problems of these two database systems. We start with a brief overview of Cassandra and MongoDB functionality in section II. We then discuss security features of Cassandra and MongoDB in sections III and IV respectively. We conclude in section V. Since much of the discussion is based on open-source Internet documents, it naturally reflects the situation at the time this paper is written 2011 International Joint Conference of IEEE TrustCom-11/IEEE ICESS-11/FCST-11 978-0-7695-4600-1/11 $26. 00 Â © 2011 IEEE DOI 10. 1109/TrustCom. 2011. 70 541 How to cite Nosql, Essay examples

Evaluation And Analysis of The Law

Question: Discuss about the Essay for Evaluates and Analysis the Law? Answer: Introduction The present essay evaluates and analysis the law that was established in Williams v Roffey Bros Nicholls (Contractors) Ltd[1] and is impact on the doctrine of consideration. Williamss v Roffey Bros Nicholls (Contractors) Ltd is an English case[2]. The main issue that was catered in the present case was whether Roffey is liable to compensate William on the basis that no consideration was given by William to him?[3] The present essay evaluates the issue and analysis the decision that was laid down by Court of First Instance and Court of Appeal. The present essay analysis the decision of Williams case on the doctrine of consideration. The same is done by evaluating the meaning that is attributed to the term consideration. After the evaluation of the term the impact of the decision is understood by analysing two leading decision, that is Williams v. Roffey Bros Nicholls, Stilk v. Myrik and Williams v. Roffey Bros Nicholls, Foakes v. Beer. The decision lay down in William case makes a distinction from the decision laid down in Stilk v. Myrick case. The decisions of Williams have evaluated a new path to the doctrine of consideration and have redefined the law that is applied in Stilk v. Myrick keeping the principle unmoved and intact. But, the decision in Roffey Bros case brings down the flaws that were present in the Williams case. The comparison of cases brings down the impact of the William case on the doctrine of consideration. The assignment is concluded in the end followed by reference list. Decision The court of first instance decided in favour of William and granted him damages of 3,500. An appeal was made by Roffey. However, the appeal of Roffey was dismissed. It was submitted by the court that though the consideration is required for the establishment of contract (if considered in orthodox sense) but, when there is presence of promises then consideration comprises of practical benefits. Thus, based on the following facts, it was analysed in the leading case that when a contract is a varying contract, then in such situations, the court is very fast and swift in defining the consideration especially when there are factual benefits and which are provided by one party to another party[4]. Now, after evaluating the brief facts and the decision of the court it is now important to evaluate the impact of Williams case[5] on the doctrine of consideration. Consideration It is first important to evaluate the basic meaning that is attributed to the term Consideration. Consideration is something which is of value and which is provided by both the parties to the contract and which lures and induces the parties to form an agreement amid them. There is exchange of mutual promises amid the parties in exchange of something valuable and such mutual promises are enforceable in law[6]. In Currie v. Misa[7], Lush J defined consideration as A valuable consideration, in the sense of the law, may consist either in some right, interest, profit or benefit accruing to the one party, or some forbearance, detriment, loss or responsibility, given, suffered, or undertaken by the other.[8] Consideration is one of the main elements in establishing a contract apart from offer, acceptance, intention and capacity. Thus, every contact must be supported by consideration. Absence of consideration will render the contract void, that is, if one person makes a promise to another person to undertake an act or omission, however, if there is no promise that is made in return, then there is lack of consideration and such kinds of contracts are not enforceable in law because of lack of consideration[9]. This is mainly because the promisor is not gaining anything; rather, there is loss without anything in return. On the other hand, there is benefit that is accruing by the promise without any loss. But, if the promisee in exchange of the promise made by the promisor, made a promise in return, then there is consideration that is generated against the promise of the promisor, thereby making the contract enforceable in law[10]. After evaluating the meaning that is attributed to the term Consideration, it is now important to evaluate the impact of Williams case[11] on the doctrine of consideration. Impact of Williams v Roffey Bros on the doctrine of Consideration It is submit that the law established by Williams case is considered to be very important as it makes a departure from the traditional and ancient rules that are followed regarding consideration. The case is also relevant because it brings changes in the rules that are established in the leading case of Stilk v. Myrik[12]. Impact of the doctrine of consideration by comparing the law laid down in Williams v. Roffey Bros Nicholls, Stilk v. Myrik. In Williams case, the ancient doctrine of consideration was evaluated. It was analysed that the traditional doctrine of consideration comprises of pre-existing obligation of duty. That is, if suppose, there are two persons A and B and both are part of a contract, then, if A makes a promises and requires consideration from B in exchange of such promise, then, if B undertakes a promise which is something which is he is already bound to perform, then in such scenario, anything promised by B regarding such performance or its actual performance cannot be in any scenario be regarded as the consideration in exchange of the promise that is made by A[13]. This rule of pre-existing obligation of duty was referred in the leading case of Stilk and Myrick. As per the facts of the said case, there are eleven sailors who affirm to sail to the Baltic and return back. However, when all the eleven sailors reached the Baltic, two of them abandoned. The captain of the ship then agreed that the wages of the two sailors who has abandoned the ship will be distributed to the rest of the sailors; however, later on the captain of the ship refused to honour his promise and refused to pay the wages to the rest of the crew. The aggrieved sailors sued the captain of the ship[14]. However, the sailors were not successful in their claims. The main reason attributed for the denial of the claim was that there was no consideration that is made in return of the promise that is made by the captain of the ship. This is because the acts of the remaining sailors were not in exchange of the promise of the captain , rather, they were already obligated to return from the Baltic and their actions cannot be treated as a consideration in exchange of the promise. But, the decision was criticised severely and there were many arguments that were laid in order to abolish the doctrine of pre-existing duty[15]. It was in Williams, that a new approach was laid down to the pre-existing duty doctrine and made a divergence to the law laid down in Stilk v. Myrik. As already submitted the court of first instance decided in favour of William and granted him damages of 3,500. The main argument was that no consideration was given by Roffey Bros to Williams which was the main basis which decided the case in favour of Williams[16]. It is submitted that the main reason which can be attributed and which decided the case in favour of William was mainly because of the fact that William did not stop the work and continued with the same even when Roffey Bros neglected in payment and thus there was no violation of contract terms on the part of William. Also, since there was no delay on the part of William, this did not bother Roffey Bros to look for another substitute contractor to complete the work. This has saved the money and time of Roffey Bros and thus completed the work on time and thereby protected him from the penalty clause for late completion of the work[17]. This outlook of the decision in Williams has resulted in the introduction of a new test, called, Practical Benefit Test. The test was not previously considered as a good consideration. This is mainly because when Glidewell LJ made is final statements, the main emphasis of his was on whether in reality the promisor has acquired any benefit or not. He was not considering whether the promissee is at loss because of the benefits (legal benefits) that is attained by the proimisor or because of the promise made by him. The statements made by the Judge were to abolish the rule of consideration[18]. Mainly the decision of the Williams makes a distinction from the decision laid down in Stilk v. Myrick and questioned the ancient old doctrine of pre-existing duty principle. The decisions of Williams have evaluated a new path to the doctrine of consideration and which must be applied in future cases to come. Glidewell LJ while deciding the case has clearly established that his main motive was not to disobey with the decision that was laid down in Stilk v. Myrick, but his main intention was to redefine and curtail the law that is applied in Stilk v. Myrick keeping the principle unmoved and intact. The main attempt that was laid down by Glidewell LJ was to modernise the rule laid down in Stilk v. Myrick in order to fit the same in the modern society. He also attempts to bring all the rules of consideration under one roof so as to avoid the application of the principle laid down in Stilk v. Myrick in future cases to come[19]. It is thus submitted that the decision of William's was very important as it has laid down a very important precedent and was very influential in United Kingdom and the Commonwealth countries. As soon as the decision was laid down, the same was applicable instantaneously throughout England and Wales and New Zealand. The principle was later applied in several cases such as in Anangel Atlas Companika Naviera SA v. Ishikawajima-Harima Heavy Industries Co Ltd (No 2) (within six months of the decision of the case). In the said case Hirst J relied on the decision laid down in William's v. Roffey. The application of the principle has established that judges were taking the new approach that was adopted in William's v. Roffey and are taking the new approach by letting go the traditional doctrine of pre existing duty obligation principle[20]. Impact of the doctrine of consideration by comparing the law laid down in Williams v. Roffey Bros Nicholls, Foakes v. Beer. But, it cannot be said that the decision that was laid down in William's v. Roffey was perfect without any flaws. It was observed that the decision of William's v. Roffey was contrary to the decision that was laid down in Foakes v. Beer[21]. In Foakes case, a person promised not to raise any claim or interest on the debt of another person. However, it was held that the said contract was not enforceable in the court of law because the contract lacks consideration[22]. But the major issue arises because of the fact that the decision laid down in Foakes v. Beer was by the House of Lords and the decision in Williams was by the Court of Appeal. Though the time gap between the two decisions was of hundreds of years but still there is a difference in the authorities of the decision makers. Because of the difference in the degree of authority the decision laid down in Williams cannot supersede the decision of Foakes and thus cannot consider as a precedent. The same can only become the precedent provided the same is approved by the House of Lords. Thus, though the old age doctrine of pre-existing rules of consideration was under scanner but the same was arosed by the court which does not have a superseding authority over the House of Lords[23]. Another problem that was raised by the decision of Williams was that not all the court is willing to follow the principle laid down by the decision. The main argument was that if the decision of Williams was followed then it will disregard the decision laid down in Foakes. This was righty established in Re Selectmove Ltd[24] and it was analysed that the court are only willing to follow the rulings of the House of the Lords or the law laid down by the legislature and not any authority inferior to the same[25]. Conclusion It is thus submitted that the decision lay down in Williams though challenges the age old doctrine of pre-existing duty of consideration but the impact is not universally applicable and thus is not totally successful. It is against the ruling laid down in Foakes, thus, though the decision is realistic but still cannot be fully accepted. Mainly, the decision of Williams v. Roffey, raises a significant challenge to the traditional rule of consideration. But since these challenges are not approved by the House of Lords, thus, the challenges are still not of much significance. It can be submitted that two similar cases, that is, Foakes v. Beer and Williams v. Roffey has resulted in two different rulings, thus, it is correct to state that there is contradiction in the rules of consideration. If the traditional approach is followed, then, the House of Lords will submit that the rules laid down in Foakes must be followed. But, the challenges that are raised by the decision of Williams will submit that in reality the traditional rules of consideration are nothing but the initiation of the end of consideration. In Antons Trawling Co Ltd v. Smith (New Zeaand), the decision laid down in Williams has significantly made an impact upon the Court of Appeal and which desire to the introduction of the reliance based test against the doctrine of consideration. Thus, it is rightful in submitting that the challenges that are raised by Williams v. Roffey are very significant as it helped in varying the manner in which the doctrine of consideration functions. But, the challenges have not gone that far so as to clearly terminating the traditional rules. It is submitted that the decision of Williams has influenced the courts but not to much larger extend and the only significant decision that is influenced by the Williams v. Roffey decision can be analysed in the decisions of Antons Trawling Co Ltd v. Smith. Reference List Books/Journals/Articles Chen-Wishart M, Consideration: Practical Benefits and the Emperors New Clothes (ISBN-13: 9780198265, 1997). Inn G, THE MODERN LAW OF CONTRACT (Fifth Edition, 2002). Roach L, Card James' Business Law for Business, Accounting, Finance Students (OUP Oxford, 2012). Cases Currie v. Misa (1875). Foakes v Beer(1883-84) LR 9 App Cas 605. Re Selectmove Ltd[1993] EWCA Civ 8 Stilk v Myrick[1809] EWHC KB J58. Williams v Roffey Bros Nicholls (Contractors) Ltd (1989) EWCA Civ 5 Online Material B Hough, THE DOCTRINE OF CONSIDERATION: DEAD OR ALIVE IN ENGLISH EMPLOYMENT CONTRACTS? (2016) https://eprints.bournemouth.ac.uk/2898/1/78.pdf. Accessed on 16th January 2016. Case brief, Foakes v Beer, [1884] UKHL 1 https://casebrief.me/casebriefs/foakes-v-beer/. Accessed on 16th March 2016. Dr Robert N Moles, Consideration - in Acceptance of Contract (2016) https://netk.net.au/Contract/04Consideration.asp. ELawresourceUK, Stilk v Myrick[1809] EWHC KB J58 (2016) https://www.e-lawresources.co.uk/Stilk-v-Myrick.php. Accessed on 16th January 2016. Emily M. Weitzenbck , English Law of Contract: Consideration (2012) https://www.uio.no/studier/emner/jus/jus/JUS5260/v12/undervisningsmateriale/Consideration.pdf. Accessed on 16th March 2016. Francis Dawson, CONTRACT AS ASSUMPTION AND CONSIDERATION THEORY: A REASSESSMENT OF WILLIAMS V ROFFEY BROS (2011) 42 VUWLR https://www.nzlii.org/nz/journals/VUWLawRw/2011/9.pdf. Accessed on 16th March 2016. MacMillan Stone, Elements of the law of contract (2012) https://www.londoninternational.ac.uk/sites/default/files/programme_resources/laws/ug_subject_guides/elements_law_contract-subjectguide4chapters.pdf. Accessed on 16th March 2016. Swarb, Contract (2015) https://swarb.co.uk/williams-v-roffey-brothers-nicholls-contractors-ltd-ca-23-nov-1989/. Accessed on 16th March 2016. The Law Teacher, Traditional Rules of Consideration (2016) https://www.lawteacher.net/free-law-essays/consideration-law/traditional-rules-of-consideration.php Accessed on 16th March 2016. The Law Teacher, The principle of Williams v. Roffey (2016) https://www.lawteacher.net/free-law-essays/contract-law/the-principle-of-williams-v-roffey-contract-law-essay.php. Accessed on 16th March 2016. Westlaw, Williams v. Roffey Bros. Nicholls (Contractors) Ltd. [1990] 2 W.L.R. 1153 (2004) https://legal.thomsonreuters.com.au/product/au/files/720502512/williams_v_roffey_bros_and_nicholls.pdf. Accessed on 16th March 2016. [1] Williams v Roffey Bros Nicholls (Contractors) Ltd (1989) EWCA Civ 5. [2] Westlaw, Williams v. Roffey Bros. Nicholls (Contractors) Ltd. [1990] 2 W.L.R. 1153 (2004) https://legal.thomsonreuters.com.au/product/au/files/720502512/williams_v_roffey_bros_and_nicholls.pdf. Accessed 16th March 2016. [3] Mindy Chen-Wishart, Consideration: Practical Benefits and the Emperors New Clothes (ISBN-13: 9780198265, 1997). [4] Swarb, Contract (2015) https://swarb.co.uk/williams-v-roffey-brothers-nicholls-contractors-ltd-ca-23-nov-1989/. Accessed 16th March 2016. [5] Williams v Roffey Bros Nicholls (Contractors) Ltd (1989) EWCA Civ 5 [6] Emily M. Weitzenbck , English Law of Contract: Consideration (2012) https://www.uio.no/studier/emner/jus/jus/JUS5260/v12/undervisningsmateriale/Consideration.pdf. Accessed 16th March 2016. [7] Currie v. Misa (1875). [8] Lee Roach, Card James' Business Law for Business, Accounting, Finance Students (OUP Oxford, 2012). [9] MacMillan Stone, Elements of the law of contract (2012) https://www.londoninternational.ac.uk/sites/default/files/programme_resources/laws/ug_subject_guides/elements_law_contract-subjectguide4chapters.pdf. Accessed 16th March 2016. [10] Dr Robert N Moles,Consideration - in Acceptance of Contract (2016) https://netk.net.au/Contract/04Consideration.asp Accessed 16th March 2016. [11] Williams v Roffey Bros Nicholls (Contractors) Ltd (1989) EWCA Civ 5. [12] Stilk v Myrick[1809] EWHC KB J58. [13] B Hough, THE DOCTRINE OF CONSIDERATION: DEAD OR ALIVE IN ENGLISH EMPLOYMENT CONTRACTS? (2016) https://eprints.bournemouth.ac.uk/2898/1/78.pdf. Accessed 16th January 2016. [14] ELawresourceUK, Stilk v Myrick[1809] EWHC KB J58 (2016) https://www.e-lawresources.co.uk/Stilk-v-Myrick.php. Accessed 16th January 2016. [15] The Law Teacher, Traditional Rules of Consideration (2016) https://www.lawteacher.net/free-law-essays/consideration-law/traditional-rules-of-consideration.php Accessed 16th March 2016. [16] Swarb, n4. [17] Francis Dawson, CONTRACT AS ASSUMPTION AND CONSIDERATION THEORY: A REASSESSMENT OF WILLIAMS V ROFFEY BROS (2011) 42 VUWLR https://www.nzlii.org/nz/journals/VUWLawRw/2011/9.pdf. Accessed 16th March 2016. [18] Ibid. [19] The Law Teacher, Traditional Rules of Consideration (2016) https://www.lawteacher.net/free-law-essays/consideration-law/traditional-rules-of-consideration.php Accessed 16th March 2016. [20] Grays Inn, THE MODERN LAW OF CONTRACT (Fifth Edition, 2002). [21] Foakes v Beer(1883-84) LR 9 App Cas 605. [22] Case brief, Foakes v Beer, [1884] UKHL 1 https://casebrief.me/casebriefs/foakes-v-beer/. Accessed 16th March 2016. [23] The Law Teacher, n19. [24]Re Selectmove Ltd[1993] EWCA Civ 8 [25] The Law Teacher, The principle of Williams v. Roffey (2016) https://www.lawteacher.net/free-law-essays/contract-law/the-principle-of-williams-v-roffey-contract-law-essay.php. Accessed 16th March 2016.