Article 21 of the Constitution of India After Maneka Gandhi’s Case Essay

INTRODUCTION To a great extent, the Supreme Court of India finds its strength in Article 21 of the Constitution, for the reason that much of its judicial activism has been based on interpreting the scope of this Article. Majority of the PIL cases have been filed under this Article only. The Supreme Court is now known as an activist court. There has been no change in the words used in Article 21, but there has been a change in the way it has been interpreted. The scope of the Article has expanded considerably post the Maneka Gandhi decision. This will be critically analysed in the following few pages. ARTICLE 21 The Article reads- â€Å"No person shall be deprived of his life or personal liberty except according to procedure established by law.† Constituent Assembly Debate Over Article 21 India’s constitutional system was rooted in the traditions of British parliamentary sovereignty and legal positivism. Thus, the emergence of a strong Supreme Court challenging parliamentary legislation via substantive due process was unlikely given this traditional historical context. But aside from the historical legacy of British rule and legal positivism, two specific historical factors directly influenced the Constituent Assembly to explicitly omit a due process clause in the section on Fundamental Rights. The first was the influence of United States Supreme Court Justice Felix Frankfurter on Constitutional Adviser B.N. Rau, who traveled to Britain, Ireland, the United States and Canada in 1947 to meet with jurists regarding the drafting and framing of the Indian Constitution. The second factor was the tumultuous and chaotic period of communal violence that gripped Northern India as a result of the partition of Muslim Pakistan from Hindu India, which led the framers of the Indian Constitution to remove the due process clause from their draft constitution for the protection of individual liberty.1 The Constituent Assembly of India originally included a due process clause in the Fundamental Rights provisions associated with preventive detention and individual liberty in the initial draft version adopted and published in October of 1947. At this point, a majority of members of the Constituent Assembly favored inclusion of a due process clause, because it would provide procedural safeguards against detention of individuals without cause by the government. However, Rau had succeeded in qualifying the phrase liberty with the word â€Å"personal,† effectively limiting the scope of this clause as applying to individual liberties, and not property rights. After this draft version was published, Rau embarked upon a multi-nation trip to the United States, Canada, and Ireland to meet with jurists, constitutional scholars, and other statesmen. In the United States, Rau met with American Supreme Court Justice Felix Frankfurter, a student of Harvard Law professor James Bradley Thayer, whose writings about the pitfalls of due process as weakening the democratic process had already impressed Rau prior to the visit. In his meeting with Rau, Frankfurter indicated that he believed that the power of judicial review implied in the due process clause was both undemocratic and burdensome to the judiciary, because it empowered judges to invalidate legislation enacted by democratic majorities. 2 Frankfurter had a lasting impression on Rau, who upon his return to India, became a forceful proponent for removing the due process clause, ultimately convincing the Drafting Committee to reconsider the language of draft Article 15 (now Article 21) in January 1948. In these meetings Rau apparently was able to convince Ayyar, the crucial swing vote on the committee, of the potential pitfalls associated with substantive interpretation of due process, which Frankfurter had discussed extensively with Rau. Ayyar, in ultimately upholding the new position on the floor of the Assembly in December 1948, supported removing the due process clause on the grounds that substantive due process could â€Å"impede social legislation.† With the switch in Ayyar’s vote, the Drafting Committee endorsed Rau’s new preferred language-replacing the due process clause with the phrase â€Å"according to the procedure established by law,† which was apparently borrowed from the Japanese Constitution.3 Protection of Life and Personal Liberty Gopalan’s Case Immediately after the Constitution became effective, the question of interpretation of the words â€Å"life and personal liberty† arose before the court in the case A.K. Gopalan v. State of Madras.4 In this case, the Petitioner had been detained under the Preventive Detention Act, 1950. The petitioner challenged the validity of his detention on the ground that it was violative of his Right to freedom of movement under Article 19(1)(d), which is the very essence of personal liberty guaranteed by Article 21 of the Constitution. He argued that (i) the words ‘personal liberty’ include the freedom of movement also and therefore the Preventive Detention Act, 1950 must also satisfy the requirements of Article 19(5). (ii) It was further argued that Article 21 and Article 19 should be read together as Article 19 laid out the substantive rights while Article 21 provided procedural rights. (iii) It was also argued that the words â€Å"procedure established by law† actually meant â€Å"due process of law† from the American Constitution which includes principles of natural justice and the impugned law does not satisfy that requirement. Thus the main question was whether Article 21 envisaged any procedure laid down by a law enacted by a legislature, or whether the procedure should be just, fair and reasonable. On behalf of Gopalan, an argument was made to persuade the Supreme Court to hold that the courts could adjudicate upon the reasonableness of the Preventive Detention Act, or for that matter, any law depriving a person of his personal liberty. Majority Decision in Gopalan The Supreme Court ruled by majority that the word ‘law’ in Article 21 could not be read as meaning rules of natural justice. These rules were vague and indefinite and the Constitution could not be read as laying down a vague standard. The Court further interpreted the term ‘law’ as ‘State made law’ and rejected the plea that the term ‘law’ in Article 21 meant jus naturale or principles of natural justice. Justice Fazl Ali’s Dissenting Judgment Justicle Fazl Ali in his dissenting judgment observed that preventive detention is a direct infringement of the right guaranteed in Art. 19 (1) (d), even if a narrow construction is placed on the said sub-clause, and a lawrelating to preventive detention is therefore subject to such limited judicial review as is permitted by Art. 19 (5). There is nothing revolutionary in the view that â€Å"procedure established by law â€Å"must include the four principles of elementary justice which inhere in and are at the root of all civilized systems of law, and which have been stated by the American Courts and jurists as consisting in (1) notice, (2) opportunity to be heard, (3) impartial tribunal and (4) orderly course of procedure. These four principles are really different aspects of the same right, namely, the right to be heard before one is condemned. Hence the words â€Å"procedure established by law â€Å", whatever its exact meaning be, must necessarily include the principle that no person shall be condemned without hearing by an impartial tribunal. Relationship among Articles 21, 22 and 19 An attempt was made in Gopalan to establish a link between these three Articles. The underlying purpose was to persuade the Court to adjudge the reasonableness of the Preventive Detention Act. It was therefore argued that when a person was detained, his several rights under Article 19 were affected and thus, the reasonableness of the law, and the procedure contained therein (regarding reasonable restrictions), should be justiciable with reference to Arts. 19(2) to (6). Rejecting the argument, the Court pointed out that the word ‘personal liberty’ under Article 21 in itself had a comprehensive content and ordinarily, if left alone, would include not only freedom from arrest or detention, but also various freedoms guaranteed by Art. 19. However, reading Articles 19 and 21 together , Article 19 must be held to deal with a few specific freedoms mentioned therein and not with freedom from detention whether punitive or preventive. Similarly, Art. 21 should be held as excluding the freedoms dealt with in Article 19. The Court ruled that Arts. 20 and 22 constituted a comprehensive code and embodied the entire constitutional protection in relation to life and personal liberty and was not controlled by Article 19. Thus, a law depriving personal liberty had to conform with Arts. 20 and 22 and not with Art. 19, which covered a separate and distinct ground. Article 19 could be invoked only by a freeman and not one under arrest. Further, Article 19 could be invoked only when a law directly attempted to control a right mentioned under it. Thus, a law directly controlling a citizen’s right to freedom of speech and expression could be tested under the exception given under Art. 19(2); and a law that does not directly control the fundamental freedoms under Article 19, could not be tested under the clauses (2) to (6) of Article 19. This judicial approach meant that a preventive detention law would be valid, and be within the terms of Article 21, so long as it conformed to Article 22. Due Process of Law The V Amendment of the US Constitution lays down inter alia that â€Å"no person shall be deprived of his life, liberty or property, without due process of law.† The use of the word ‘due’ in this clause is interpreted to mean ‘just’, ‘proper’ or ‘reasonable’ according to judicial review. The courts can pronounce whether a law affecting a person’s life, liberty or property is reasonable or not. The court may declare a law invalid if it does not accord with its notions of what is just, fair and reasonable. Thus, this clause known as the ‘due process clause’ has been the most significant single source of judicial review in the US. It was contended in Gopalan that the expression procedure established by law in Art. 21 was synonymous with the American concept of ‘procedural due process’, and therefore, the reasonableness of the Preventive Detention Act, or for that matter, of any law affecting a person’s life or personal liberty, should comply with the principles of natural justice. The Supreme Court rejected this contention giving several reasons: i) The word ‘due’ was absent from Article 21. ii) The fact that the words ‘due process’ were dropped from draft Article 15 (present Article 21), signified the intention of the Constituent Assembly, that was to avoid the uncertainty surrounding the due process concept in the USA. iii) The American doctrine generated the countervailing but complicated doctrine of police power to restrict the ambit of due process, i.e., the doctrine of governmental power to regulate private rights in public interest. If the doctrine of due process was imported into India, then the doctrine of police power might also have to be imported, and which would make things very complicated. The ruling thus meant that to deprive a person of his life or personal liberty- i) There must be a law ii) It should lay down a procedure iii) The executive should follow this procedure while depriving a person of his life or personal liberty. Criticism Gopalan was characterized as the ‘high-water mark of legal positivism.’ Court’s approach was very static, mechanical, purely literal and was coloured by the positivist or imperative theory of law, which studies the law as it is. Article 21 was interpreted by the majority to mean that Art. 21 constituted a restriction only on the executive which could not act without law and that it was not applicable against legislative power, which could make any law to impose restraints on personal liberty, however arbitrary they may be. GOPALAN TO MANEKA: 1950-1977 Gopalan held the field for almost three decades. It can be observed during this period from the court decisions that the two major points settled in the case [that is, firstly that Articles 19, 21 and 22 are mutually exclusive and independent of each other, and secondly that Article 19 was not to apply to a law affecting personal liberty to which Article 21 would apply] got diluted to a great extent until finally in Maneka Gandhi’s case this position was reversed. The decisions immediately proceeding Gopalan’s case were decided on the same basis. For example, in Ram Singh v. Delhi5, where a person was detained under the Preventive Detention Act for making speeches prejudicial to the maintenance of public order, at a time when public order was not contained under Article 19(2), the Supreme Court refused to assess the validity of preventive detention under Article 22 with reference to Article 19(1)(a) read with Article 19(2) stating that even if a right under Art. 19(1)(a) was abridged, the validity of the preventive detention order could not be considered with reference to Art. 19(2) because of the Gopalan decision that legislation authorizing deprivation of personal liberty did not fall under Art. 19 and its validity was not to be judged by the criteria in Art. 19. The beginning of the new trend can be found in RC Cooper v. Union of India6, where Article 31(2) which had been amended to dilute the protection to property, the Court established a link between Article 19(1)(f) (right to property) and Article 31(2). But the draconian Gopalan ruling found its way back and reached the lowest point in ADM Jabalpur v. Shivkant Shukla7, remembered as the black day in Indian Constitutional history. In this case the political dissenters of the Indira Gandhi government were arrested and Shivkant Shukla contended that this was in violation of their right to life and personal liberty and so the writ of habeas corpus should be issued. Court held that during the period of emergency, a person could be detained and his right to life and personal liberty under Article 21 could be suspended, and such suspension could not be challenged and the writ of habeas corpus could not be issued during the emergency. This case showed that Article 21 could not play any role in providing any protection against any harsh law seeking to deprive a person of his life or liberty. It is the dissenting judgment of Fazl Ali J that was subsequently applied in the decision in Maneka Gandhi’s case and the cases after that, regarding the right to life and personal liberty. MANEKA GANDHI’S CASE In Maneka Gandhi v. Union of India8 and ever since, the Supreme Court has shown greater sensitivity to the protection of personal liberty. The court has reinterpreted Article 21 and overruled its Gopalan decision and which, in the words of MP Jain, can be regarded as a highly creative judicial pronouncement on the part of the Supreme Court. In this case, Maneka Gandhi’s passport was impounded by the Central Government under the Passport Act in the interest of the general public, as was provided under S. 103(c) of the Passport Act. This was challenged on the ground of being arbitrary to Article 21 and also because this was done without affording her a chance to be heard. The Court observed that as the right to travel abroad falls under Article 21, principles of natural justice must be observed and the right of hearing should be given, even though not expressly provided for under the statute. Some of the main propositions laid down by the court in this case are as follows: 1. The court reiterated the proposition that Articles 14, 19 and 21 are inter-related and not mutually exclusive. This means that a law prescribing a procedure to deprive a person of their personal liberty, should conform to the provisions under Article 19. Moreover, the procedure established by law under Article 21 must meet the requirements of Article 14. According to K. Iyer, J, no Article in the Constitution pertaining to a Fundamental Right is an island in itself. Just as a man is not dissectible into separate limbs, cardinal rights in an organic constitution have a synthesis. Here, the dissenting judgment of Justice Fazl Ali in Gopalan’s case was followed. 2. The court emphasized that the expression ‘personal liberty’ was of the widest amplitude covering a variety of rights which go to constitute the personal liberty of man. Some of these attributes have been raised to the status of distinct fundamental rights and given additional protection under Article 19. 3. The most significant aspect of Maneka’s decision is the reinterpretation by the court of the expression ‘procedure established by law’ used in Article 21. It now means that the procedure must satisfy certain requisites in the sense of being fair and reasonable. The procedure cannot be arbitrary, unfair or unreasonable. The reasonableness must be projected in the procedure contemplated by Article 21. IMPACT OF MANEKA GANDHI’S DECISION Article 21 which had lain dormant for nearly three decades was brought to life by the Maneka Gandhi decision. Since then Article 21 has been on its way to emerge as the Indian version of the American concept of due process. It has become the source of many substantive rights and procedural safeguards to the people. Some of the broad fields of this impact will be discussed as below: 1. Interpretation of the Word Life In Francis Coralie9 the Supreme Court, following the principle laid down in Maneka Gandhi’s case, has interpreted the meaning of life as has been interpreted by the US Supreme Court in Munn v. Illinois10, and held that the expression ‘life’ under Article 21 does not connote merely physical or animal existence but embraces something more. As recently as 2006, the Supreme Court has observed that Article 21 embraces within its sweep not only physical existence but also the quality of life. These cases only reflect a part of the scope and ambit of the word ‘life’ under Article 21, which has been extended widely by the Supreme Court over the years proceeding Maneka. There have been a number of areas in which the Supreme Court has related some of the Directive Principles of State Policies to the word ‘life’ under Article 21 and made it enforceable as a fundamental right. A classic example of this is the large number of environment related cases filed by MC Mehta. 2. Personal Liberty It does not mean merely the liberty of body, i.e., freedom from physical restraint or freedom from confinement within the bounds of a prison. The expression ‘personal liberty’ is not used in a narrow sense but as a compendious term to include within it all those variety of rights of a person which go to make personal liberty of a man. To begin with, the expression ‘personal liberty’ in Art. 21 was interpreted so as to exclude the rights mentioned under Article 19. The view was expressed in Kharak Singh v. State of Uttar Pradesh11 that while Art. 19(1) dealt with particular species of that freedom, ‘personal liberty’ in Art. 21 would take in the residue. This view was followed in Gopalan’s case as well. But the minority view expressed by Justice Subba Rao adopted a much wider concept of ‘personal liberty’. He differed from the majority view that Art. 21 excluded what was guaranteed by Art. 19. He pleaded for an overlapping approach of Arts. 21 and 19. In a recent judgment of 2009, Suchita Srivastava v. Chandigarh Administration12, the Supreme Court asserted the strict boundaries of ‘personal liberty’ but that such liberty must also accommodate public interest. A woman’s right to make reproductive choice has been held to be a dimension of ‘perso nal liberty’ within the meaning of Art. 21. 3. Law Ordinarily, the word law in Article 21 denotes an enacted law, i.e., a law made by the Legislature. But in AK Roy v. Union of India13, the question was whether an ordinance in the context of National Security Ordinance, 1980, promulgated by the President to provide for preventive detention in certain cases and connected matters, a law? The petitioner argued that since this was made by an executive it was not law and could not, thus, deprive a person of their ‘personal liberty’. The Supreme Court held that an ordinance passed by an executive is well within the meaning of ‘law’ and must therefore, also be subject to Fundamental Rights, just like an Act of the Legislature. 4. Procedure After Maneka Gandhi, it is now established that the procedure for purposes of Art. 21 has to be reasonable, fair and just. The Supreme Court has reasserted in Kartar Singh v. State of Punjab14 that the procedure contemplated by Art. 21 is that it must be ‘right, just and fair’ and not arbitrary, fanciful or oppressive. In re The Special Courts Bill, 1978, the Special Courts Bill proposed that a special court would be constituted to try certain persons holding high political offices during the emergency of 1975-1977. The special Court was to be presided over by a sitting or retired Judge of a High Court, to be appointed by the Central Government in consultation with the Chief Justice of India. The accused could appeal to the Supreme Court against the verdict of the special Court. For the procedure to be just, fair and reasonable, the Court suggested certain modifications: There should be a provision for transferring a case from one special court to another so as to avoid the possibility of a trial where a judge may be biased against the accused Only a sitting High Court Judge ought to be appointed, for the retired Judge would hold the office as a Judge of the special court during the pleasure of the government, and the â€Å"pleasure doctrine was subversive of judicial independence.† Instead of mere consultation, the Chief Justice’s concurrence should be there, which would inspire confidence not only of the accused but also of the entire community in the special Court. CRIMINAL JUSTICE AFTER MANEKA Arrest In Joginder Kumar v. State of Uttar Pradesh15, the Supreme Court has observed that an arrest can cause incalculable harm to a person’s reputation and self-esteem. Arrest should be made not merely on suspicion but only after a reasonable satisfaction reached after some investigation as to the genuineness and bona fides of the complaint and a reasonable belief to the person’s complicity and even as to the need to effect arrest. Speedy Trial Speedy trial has not been mentioned as a fundamental right in the Constitution. Yet the Court has declared this as a fundamental right in Hussainara Khatoon v. Home Secretary, State of Bihar (I).16 In this case, the undertrials were in prison for a long period of time, awaiting their trials. Bhagwati, J. held that although, unlike the American Constitution speedy trial is not specifically enumerated as a fundamental right, it is implicit in the broad sweep and content of Article 21 as interpreted in Maneka Gandhi’s case. This position was reiterated in Hussainara Khatoon(No. 2) and Hussainara Khatoon(No. 3). In a significant judgment in Abdul Rehman Antulay v. RS Nayak17, the Supreme Court has laid down guidelines for the speedy trial of an accused: i) Fair, just and reasonable procedure implicit in Article 21 of the Constitution creates a right in the accused to be tried speedily. Right to speedy trial is the right of the accused. The fact that a speedy trial is also in public interest or that it serves the societal interest also, does not make it any-the-less the right of the accused. ii) Right to Speedy Trial flowing from Article 21 encompasses all the stages, namely the stage of investigation, inquiry, trial, appeal, revision and retrial. That is how, this Court has understood this right and there is no reason to take a restricted view. iii) The concerns underlying the Right to speedy trial from the point of view of the accused are: (a) the period of remand and pre-conviction detention should be as short as possible. In other words, the accused should not be subjected to unnecessary or unduly long incarceration prior to his conviction; (b) the worry, anxiety, expense and disturbance to his vocation and peace, resulting from an unduly prolonged investigation, inquiry or trial should be minimal; and (c) undue delay may well result in impairment of the ability of the accused to defend himself, whether on account of death, disappearance or non-availability of witnesses or otherwise. In Sunil Batra (II) v. Delhi Administration18, it was held that the practice of keeping undertrials with convicts in jails offended the test of reasonableness in Art. 19 and fairness in Art. 21. Prison Administration In Sunil Batra (I) v. Delhi Administration19, the important question before the court was whether solitary confinement imposed upon prisoners who were under sentence of death, was violative of Articles 14, 19, 20 and 21. It was held that under Sections 73 and 74 of the IPC, solitary confinement is a substantive punishment, which can be imposed by a court of law, and it cannot be left within the caprice of prison authorities. It further observed that if by imposing solitary confinement there is total deprivation of camaraderie amongst co-prisoners, comingling and talking and being talked to, it would offend Article 21 of the Constitution. The liberty to move, mix mingle, talk, share company with co-prisoners if substantially curtailed, would be violative of Article 21 unless curtailment has the backing of law. Here we see the high regard that the Supreme Court gives to human life and personal liberty, notwithstanding a person’s jail sentence. In Prem Shankar v. Delhi Administration20, the Supreme Court has held that handcuffing should be resorted to only when there is clear and present danger of escape. Even when in extreme cases, handcuffing is to be put on the prisoner, the escorting authority must record simultaneously the reasons for doing so, otherwise the procedure would be unfair and bad in law. This is implicit in Article 21 which insists upon fairness, reasonableness and justice in the procedure for deprivation of life and liberty. Legal Aid In Hussainara21, the Supreme Court has observed that it is an essential ingredient of reasonable, fair and just procedure to a prisoner who is to seek his liberation through the court’s process that he should have legal services available to him. Providing free legal service to the poor and the needy is an essential element of any reasonable, fair and just procedure. In Suk Das22, the Court quashed the conviction of the appellant because the accused remained unrepresented by a lawyer and so the trial became vitiated on account of a fatal constitutional infirmity. The court held that free legal assistance at the cost of the State is a Fundamental Right of a person accused of an offence and this requirement is implicit in the requirement of a fair, just and reasonable procedure prescribed by Article 21. Public Interest Litigation One of the most effective instruments evolved by the Supreme Court for attaining social justice is Public Interest Litigation (PIL). Any person with a sufficient interest and acting bona fide can file a PIL in the Supreme Court under Art. 32 or Art. 226. If there is a violation of any fundamental right or legal duties and there is legal injury to a person or a class of persons who are unable to approach the court by ignorance, poverty or by any disability, social or economic, any member of the public can make an application for an appropriate direction or order or writ before the High Court under Article 226 and before the Supreme Court under Article 32 for redressal. This was the gist of the principle laid down in SP Gupta v. Union of India23, in which the Court has given considerable relaxation to the doctrine of locus standi. PILs have played an important role in the fields of prison reforms, gender justice, environment protection, child rights, education, wherein the court has constantly made an attempt to uphold the value of a dignified human life, which is not merely confined to access to food, shelter and clothing, but goes much beyond. For instance, in Vishakha v. State of Rajasthan24, an incident of rape was held to be violative of not only the right to gender equality under Art. 14, but also of the right to life under Article 21. The Supreme Court has laid down specific guidelines as to what constitutes sexual harassment at workplace, placing the responsibility on the employer to ensure the safety of their employees, also making it mandatory for all public offices to have a Women’s Cell, where the women employees could take their grievances. These guidelines can also be found in the Criminal Law Amendment Act 2013. In MC Mehta v. Union of India25, the Supreme Court has developed the concept of absolute liability regarding the payment of compensation by an enterprise engaged in dangerous and hazardous activities. The Supreme Court has also exercised epistolary jurisdiction, wherein a letter has been treated as a petition before the court. In Labourers Working on Salal Hydroelectric Project v. State of Jammu and Kashmir26, litigation was started on the basis of a letter addressed by the People’s Union for Democratic Rights to Mr. Justice D.A. Desai enclosing a copy of the news item which appeared in the issue of Indian Express pointing out that a large number of workmen working on the Salal Hydro Electric Project were denied the benefit of various labour laws and were subjected to exploitation by the contractors to whom different portions of the work were entrusted by the Central Government. In all of these cases, and a number of others, a reflection of Maneka’s decision can be found, wherein the Court has tried to uphold the sanctity of a dignified human life. CRITICAL APPRAISAL OF MANEKA’S DECISION The kind of wide interpretation that has been given to Article 21 post Maneka, has not been given to any other provision. Article 21 read with Articles 32 and 226, has become the most important weapon of judicial activism. By relating Directive Principles of State Policy with Fundamental Rights, court is granting remedies on an ever increasing scale. But it must be remembered that Directive Principles are non-justiciable in nature and cannot be enforced. Yet, the Supreme Court has gone to great lengths to enforce these by relating them to right to life. But balancing of conflicting interests is an important function of law. Function of law is social engineering. This has to be performed by both, the Legislator as well as the Judiciary. Justice Cardozo also says that the court can evolve a process for dealing with the social ills. Thus, where legislators fail to balance the interests, it is the Court which must do it. The court will be criticized for judicial over-reach, that is, for undertaking the power of the legislator and laying down a law, as it happened in Vishakha v. State of Rajasthan. But it must be realized that where the Legislators fail, the court has to step in. The gaps need to be filled. Thus, from the perspective of Roscoe Pound’s social engineering theory, which is very relevant in the present scenario, court’s actions cannot be termed as judicial overreach. CONCLUSION Thus, the decision of the Supreme Court in Maneka Gandhi’s case became the basis of the court’s decisions in subsequent cases pertaining to not only Article 21 expressly, but wherever the court found a relation between life and another aspect of it. The Court developed a theory of ‘inter-relationship of rights’ to hold that governmental action which curtailed either of these rights should meet the designated threshold for restraints on all of them. In this manner, the Courts incorporated the guarantee of ‘substantive due process’ into the language of Article 21. This was followed by a series of decisions, where the conceptions of ‘life’ and ‘personal liberty’ were interpreted liberally to include rights which had not been expressly enumerated in Part III.27 The width of Article 21 will keep expanding as long as our Supreme Court upholds its title of the activist court, and intervenes dutifully to preserve the fundamental rights of the people. The Court has, thus, played the role of a social engineer, constantly making an effort to balance the conflicting interests of the state with those of the society and the individuals. REFERENCES 1. Indian Constitutional Law, M.P. Jain, Sixth Edition (2013). 2. Constitutional Law of India, J.N. Pandey, Forty Third Edition (2006).

Legality of Organ Donation

Progress in medical science and technology has contributed to the growth of kidney and other organ transplantations around the world. Nevertheless, the gap between the supply and demand for transplantable organs continues to widen. Chronic shortage of human organs for transplantation is one of the most pressing health policy issues in many developed countries. In recent years, the persistent scarcity of organs for transplantation has invigorated the controversy about the determinants of organ donation rates and the magnitude of their effects. In spite of the media campaigns and other attempts to promote donation, the organs supply cannot keep up with the demand, and the number of patients on waiting lists has been growing steadily during the last decade. The Philippines is no exception to the dilemma on the shortage of transplantable human organs and there is no clear cut policy yet on how the shortage could be swiftly addressed. The Department of Health (DoH) is currently pushing for â€Å"cadaveric organ donation† and this perhaps, might lessen the gap between the supply and demand for transplantable human organs. But how can one tinker freely with the body of a deceased person? Are there laws in the country which give blanket authority to hospital institutions or to a medical practitioner in harvesting transplantable human organs from a deceased person even without a document or a health card indicating that the deceased is a willing donor? The answer is a resounding ‘None’. The Philippines has yet to come up with a law regarding ‘presumed consent’ unlike in many European countries, particularly Spain, which for so long a time has been implementing their own and unique versions of ‘presumed consent laws’. Under presumed consent legislation, a deceased individual is classified as a potential donor in absence of explicit opposition to donation before death. With the positive effect of presumed consent laws vis-a-vis organ donation rates on countries which enforced such, it is high time that the Philippines should follow suit and come up with its own version of presumed consent laws. Senator Richard Gordon took the initiative in making the battlecry for the passage of a presumed consent law as he was astounded by the staggering figures of the National Kidney Transplant Institute (NKTI). The Institute reported that the usual Filipino kidney transplants performed thereat have gone down by 20% while the demand for kidney donation is going up by ten (10) percent annually. Global Reality. Waiting for a suitable donor organ to become available may take one week to many months. Unfortunately, the latter is more often the case. This waiting time has been described by many transplant recipients and their families as the most difficult part of the transplant process. Fear and anxiety are normal reactions during this period of uncertainty. In Europe, the average waiting time is three years and is expected to last for ten years or until 2010. With 120,000 patients on chronic dialysis and 40,000 patients waiting in line for a kidney in Western Europe alone, about 15 to 30 % of these patients will die annually because of organ shortages. Every day in the United States, 17 people die waiting for an organ transplant. The number of people in the waiting list for an organ has more than tripled over the last ten years; at the same time, the number of donors has remained relatively stagnant. In the United Kingdom, the active transplant waiting list is increasing by about 8% a year, and the ageing population and increasing incidence of Type 2 diabetes are likely to exacerbate the shortage of available organs. In 2006, the UK Organ Donation Task Force was established with the task of identifying barriers to donation and making recommendations for increasing organ donation and procurement within the current legal framework. In the U. S. , Great Britain and in many other countries, the gap between the demand and the supply of human organs for transplantation is on the rise, despite the efforts of governments and health agencies to promote donor registration. In 2002, 6679 patients died on the U. S. organ waiting lists before an organ became available, roughly 18 per day . In 2001, 6,439 people died while waiting for a transplant, nearly double the 3,916 candidates who died while waiting just five years earlier in 1996. In spite of media campaigns and other attempts to promote donation, the supply of organs cannot keep up with the demand, and the number of patients on waiting lists has been growing steadily during the last decade. One of the most frequently quoted explanations of the gap between the supply and demand of organs is that the number of families that refuse to grant a consent to donation is still large. Approximately 50% of the families that were approached for an organ donation in the U. S. and Great Britain refused it, compared to around 20% in Spain and around 30% in France. Notably, Spain and France are presumed consent countries. In many countries, including the U. S. , Great Britain, Germany and Australia, cadaveric organ procurement is carried out under the informed consent principle. Under an informed consent law, cadaveric organ extraction requires the explicit consent of the donor before death, which is usually re? ected on a donor registration card. In contrast, in most of continental Europe, cadaveric organ procurement is based on the principle of presumed consent. Under presumed consent legislation, a deceased individual is classi? ed as a potential donor in the absence of explicit opposition to donation before death. The severe shortage of human organs for transplantation in the U. S. has prompted numerous proposals to alleviate this problem. In addition to presumed consent legislation, proposals include ? nancial incentives for donors , xenotransplantation, educational campaigns, organ exchange mechanisms for living donors with incompatible recipients and preferential assignment of organs to registered donors. However, increasing donation consent rates from families is still viewed as the most promising route to increase organ donation. Many analysts and health professionals believe that presumed consent legislation may play an important role in shaping the decision of the families. In an international survey of transplant professionals, 75% of the respondents supported presumed consent legislation, and 39% identi? ed this type of legislation as the most effective measure to increase donation rates, the highest percentage among all measures considered in the survey, followed by improved education with 18%. Several countries, including Spain, Austria, and Belgium, have opted for a change in legislation and introduced presumed consent, whereby organs can be used for transplantation after death unless individuals have objected during their lifetime (an opt out system). Countries vary in how organ donation legislation functions in practice, and the terms â€Å"hard† and â€Å"soft† have been used to characterize how much emphasis is placed on relatives’ views in these countries. In Austria, for example, a fairly strong version of presumed consent principle is applied, although family views may be taken into account. In Spain, as in most presumed consent countries, even when organ removal can be carried-out by law without the consent of the family, organ coordinators in charge of the donation process do not authorize the extraction of organs without an explicit family approval. Another notable example is Sweden, which goes from an informed consent system to a presumed consent system in 1996. Ten years before, in 1986, Sweden had switched from presumed consent to informed consent. In the data, cadaveric donation rates decreased steadily in Sweden during the informed consent period. This downwards trend seemed to disappear after presumed consent legislation was reinstituted in 1996. National Reality. The National Kidney and Transplant Institute Renal Disease Control estimated 11, 250 Filipinos nationwide developing End Stage Renal Disease (ESRD) annually. It is estimated that half of these ESRD patients are suitable kidney transplant candidates but only five percent (5%) are actually transplanted to date because of insufficient organ supply and the affordability of the operative procedure to most patient. The past years have also witnessed the development of â€Å"medical tourism† as exemplified by countries like India, Thailand and Singapore (but now world-wide) as improved hospital facilities in the less developed countries have attracted patients from developed countries where health care costs were expensive and unaffordable especially to those with no health insurance. In 1999, a TV documentary exposed more than a hundred kidney transplants done in a private hospital from living non-related donors coming from the very poor section of the metropolis, called BASECO in Tondo, Manila. The Philippines is among the world's leading providers of trafficked organs. Reuters named China, Pakistan, Egypt, Columbia and the Philippines as the five organ trafficking hotspots. Trafficked organs are either sold domestically, or exported to the US, Europe, the United Arab Emirates, Saudi Arabia, and especially Israel for their transplant patients. In his privilege speech, Senator Miguel Zubiri tackled about the CNN’s feature regarding the thriving trade of human organs, amidst the poverty in the country. Although he commented in CNN’s report where Mr. Hugh Reminton made an erroneous slant on the human organ trade in the country, Zubiri admitted that there are some truth to the report. The truth is – human organ trade, particularly kidneys, is thriving in the country, specifically in the urban poor communities; that after paying-off the donor, the trader abandons them to face post-surgery risks also without medical attention. In addition to this, the organ transplant sector is rife with stories of traders earning millions of pesos after paying-off donors. This statement could be supported by an incident of kidney sale in Lumban, Laguna where Jose Rivero, 31, a tricycle driver, told the National Bureau of Investigation (NBI) that he had been promised by the broker that he would be paid Php 300,000. 00 for his kidney. However, he received only Php 66,000. 00 which led him to report to the NBI. Special Investigator 3, Joey Narciso, the case officer, said that the country has no law prohibiting the direct sale of organs to a donor. Nothing has been heard of being caught and punished, of conniving surgeons or clinics who knowingly transplant organs that have been sold. Zubiri even suspected that there are big syndicates that prey on the poor and helpless citizens and exploit their ignorance and vulnerability; syndicates which have a growing clientele that includes foreigners and rich Filipinos. During the same session, Senator Gordon disclosed that the NBI is investigating the alleged involvement of doctors and other medical personnel of prominent hospitals in the illegal organ trade after members of a syndicate were arrested for duping several people from Batangas, Quezon and neighboring provinces into selling their organs. Gordon recommended the adaptation of a presumed consent. Zubiri stated that the suggestion could be included in the Senate Bill No. 460 , authored by Senator Jose Jinggoy Estrada.

Beautiful Happiness In A Meaningless Life Short Story English Literature Essay

Beautiful Happiness In A Meaningless Life Short Story English Literature Essay I intend to write a short story featuring a few of the more potent themes present within the novelette â€Å"The Outsider†. This short story has simply been written to entertain, and explore the central themes and issues that I have chosen. The content of the story is gruesome and described with vivid details in some cases, so the target audience would be fairly mature, and have an orientation towards fanciful fantasy worlds. The story is set in a land where the local entertainment consists of arena type pit fights. These pit fights are similar to a council of the city’s rich and wealthiest, with the lower classes also in attendance. These pit fights are also the place where status is gained and lost among these affluent members of society, with the slaves that compete being used as a means to this end. I have also interpreted the ending of â€Å"The Outsider† differently in my story, with my main character realising that he can make a difference with his life, and that he can live for other people rather than himself only. The content of the story is gruesome and described with vivid details in some cases, so the target audience would be fairly mature, and have an orientation towards fanciful fantasy worlds. The story is set in a land where the local entertainment consists of arena type pit fights. These pit fights are similar to a council of the city’s rich and wealthiest, with the lower classes also in attendance. These pit fights are also the place where status is gained and lost among these affluent members of society, with the slaves that compete being used as a means to this end. I have also interpreted the ending of â€Å"The Outsider† differently in my story, with my main character realising that he can make a difference with his life, and that he can live for other people rather than himself only. The ring of steel on steel resounded around the arena, to join the din of gaudy music and jeering shouts ensuing from th e on looking patrons of this violent event. The ‘Slave Games’ took place every day, from the blaze of the new fire in the sky at its start, to its dying embers at dusk. The games consisted of slaves and a monster entered by the ‘Games Keeper’. Of course to make it more complicated, there were two different types of slaves, the ones entered by their master, and the ones donated. By a slave being entered it was similar to a bet being placed, with a small fee for entry paid to the games master, the fee also gave slaves the privilege of a weapon of choice. At the conclusion of the battle if the monster was the last one standing, the games master would keep the majority of the winnings, otherwise if a slave was the victor; their master was granted higher standing in society and a large sum of gold as their winnings. There was also an unspoken tradition, that the victorious slave was granted freedom for their heroic deeds performed within the arena. The ‘do nated’ slaves on the other hand, were the unwanted outcasts of rich society that the Games Keeper bought for a small fee, to â€Å"liven up the games† as he would call it.

Reply to professor comments regarding # 1110606 Assignment

Reply to professor comments regarding # 1110606 - Assignment Example Intrinsically, the support pattern is upheld for a long period of time, maybe, till another person takes over the presidency. The power to declare war makes the presidency too powerful. Despite the constitution giving the Congress the exclusive power to declare war, in the contemporary presidency, the presidency can declare war without any formal Congress declaration. The U.S. is rich in missiles that have nuclear warheads. It’s only the president who is bestowed with the power to launch them by giving a signal, something that can lead to instant destruction of the cities in their entirety (Lowi 2012, p. 195). Surprisingly, the people who wrote and promulgated the presidency had the right intention of striking a balance of power between the presidency and the Congress; however, the modern presidency has evolved to claim too much power as compared to the Congress. The writers of the constitution would not predict that the U.S. world transform to be the worlds richest nation in terms of weapons. This has prompted amendments to the constitution from time to time, giving the presidents superfluous power s. The strength of the U.S.’s economy heightens the presidency’s powers. Presumably, the U.S. is among the top economies in the world. As such, the presidency of America is respected all over the world (Lowi 2012, p. 177). The president uses jets to tour the world and the advice he gives to other nations is taken with much seriousness than any other executive. Also, many dignitaries visit the White House from time to time to come and consult with the presidency on various issues. Contrary to the Congress, the presidency has evolved to be such a respected position, both locally and in the international

WRITTEN PROPOSAL Annotated Bibliography Example | Topics and Well Written Essays - 500 words

WRITTEN PROPOSAL - Annotated Bibliography Example Studies that have reports about exercise’s healing qualities is slowly gaining popularity as well as a way to delay aging and increase longevity. With regard to benefits of exercise to mental health, one of the most compelling discussion is made by Deslandes and Schuch who proposed that the benefits of exercise particularly aerobic and strength training â€Å"contribute to improve cognitive function, especially the executive function†. In the same study, it also reported that exercise reduces depressive symptoms through the â€Å"occurrence of redundant neurobiological pathways with the increase of neurotrophins due to exercise†. Interestingly, Dunn and Jewel, even contend that physical exercise could even be a cure to mental disorder. Their study also reported that exercise can change an indivdiual’s outlook in life to become optimistic that can contribute to one’s health and well-being (Dunn and Jewel 204). Other studies supported this report that physical exercise could reduce and resist anxiety. It prescribed long term exercise however to promote mental wellness that is resistant to anxiety (Strickland and Smith). Interestingly, it seems that exercise could also make one intelligent because according to Brow et al’s study, physical exercise can help â€Å"maintain superior cognitive functioning as well as modify the risk of cognitive decline, AD and dementia† (Brown et al 872). Other benefits of exercise was stated by Raj et al, where he reported that physical exercise make people avoid unwholesome lifestyle such as smoking and drinking. In the same study, Raj et al contended that exercise does not only make people healthy but also increases their philanthropic tendency (Raj 1191). Of course we can deduce that given the benefits of exercise of having a healthy body that is resistant to diseases, that we would live long and slow aging (CBN News). Quoting Brian Kinney assertion that â€Å"the harder you exercise, the longer you live†

Conclusion for my project Essay Example | Topics and Well Written Essays - 500 words

Conclusion for my project - Essay Example Dark tourism therefore has a history which attracts both history makers and curious people to these sites of history. Looking at Prague, The Church of SS Cyril and Methodius are good historical sites and these two have been voted as the best tourist destinations in the Czech Republic leave alone the aspect of being in Prague (Hannam & Knox, 2010, p. 28). This is because they acted as a refuge centre for assassins of ReichsprotektorHeydrich. In these places, the Germans outnumbered their enemies forcing them (enemies) to take their own lives by shooting themselves. That was in 1942 during the Second World War (Martina, 2011, p. 79). The two names centres are not the only ones in Prague that contribute to its tourism. Apparently the increased demand dark tourism has been boosted by the number of dark tourism centres in Prague. This is because the more the number of dark tourist centres, the richer the history of the town. Some other centres in the town that must have an applied history that is need knowledge for so many people are: Due to this, the statement of the research question would be that; the many dark tourism centres in Prague contain a rich history of past happenings and therefore have increased the demand for dark tourism in the town. The aim of this research is to relate the history contained in each of the dark tourism centres to the increased demand in dark tourism in Prague. This is because each centre has got its own history and there are also different types of tourists that visit the place for their knowledge. It is therefore important that the ability of the sites to attract tourists must be indicated as a cause for the increased demand of the tourists in Prague. The reason for choosing this research topic is that dark tourism is a fast-growing niche of the global tourism market. There is a lot of potential in this niche market because people will be always fascinated and

Business project Coursework Example | Topics and Well Written Essays - 500 words

Business project - Coursework Example As competitors move to produce more efficient vehicles, by producing electric cars Toyota will be tapping into the profitable unexploited market. By diversifying the range of products it offers by introducing electric cars, will further increase its market base since it will be appealing to the different tastes and preferences of various consumers. Over the years, Toyota has penetrated the automobile market in various parts of the world. Its presence in different regions and countries provides it with an added advantage in the event it launches a new product. By manufacturing quality, dependable and reliable products, it has created faith among the users of these products. The reputation it has created of production of quality products is likely to spur the sales of the electric cars since it has an already established global presence. Toyota is an established brand and by producing electric cars, it shall be remaining relevant, flexible and dynamic so that it’s able to cope with the changing business demands and environment. There are two types of business environmental factors that are likely to affect the business. They may either be micro; internal factors or macro, those outside the business. One of the internal factors has been product quality features and safety. Between November 2009 and April 2010, the company recalled over 8 million different car and truck models that had been manufactured by Toyota company in U.S.A. the models were discovered as to having a defective brake and acceleration system. For this, it received a USD $16.37 million fine by the U.S government (Toyota Website). A major strength of the company is the ability to offer quality innovative products that suit the tastes of various consumers. This is reflected in the winning of the award of being the number one car manufacturer in the year 2007, a title it also retained in 2008 (Toyota

Error Handling Assignment Example | Topics and Well Written Essays - 750 words

Error Handling - Assignment Example During the execution of a program, an abnormal condition may occur; this is what we call an exception. Examples of exception errors could be dividing a number by a zero, attempting to gain access to an invalid array or even attempting to convert a letter into a number. Therefore, we could term input/output exception as an error that occurs upon the development or existence of a problem with the I/O operation. With Java programming language, we can be able to anticipate the occurrence of an exception and write a code that can be able to handle it (Eriksson et al 2003). Furthermore, one of the most appropriate methods to handle the I/O exception error is by throwing it into a log file. It is important correcting this error so that performance problem ceases to occur. Furthermore, it is much better to use the existent infrastructure so as to avoid the purchase of new infrastructure.Connection Error Connection errors mainly occur due to network problems. A connection error may occur due to the failure of the establishment of the connection to the system's database. Other causative factors could be server errors. Such errors do not have response code simply because the involved server in the system could not return the response code due to no established connection. Consequently, connection error hampers information flow in the activity system. Can, therefore, say that should an application fail to find the location with sufficient stock then this error occurs (Taniar 2010).

Global Warming - Causes, Impacts, the Way Ahead Essay

Global Warming - Causes, Impacts, the Way Ahead - Essay Example The effects of global warming are already obvious as many of the impacts are adversely experienced by the common man these days. For instance, there have been notable variations in the climatic patterns all around the globe. In last couples of decades, the incidence of climatic disasters like floods, hurricanes, landslides and droughts became more and more frequent at different parts of the world. There is widespread consensus in the scientific community that driving force behind climatic changes can be attributed to 20th-century humans’ activities that disturbed the natural atmospheric and the ecological balance and eventually leads to climate change and global warming. The objective of this easy is to analyses the causes and impacts of global warming. The last century industrial revolution greatly influenced global surface temperatures by raising the concentration of greenhouse gases in the atmosphere and hence changing the concentrations of aerosols and ozone layer. These changes modified the land cover of earth’s surface and it changed the radiative balance governing the earth on various timescales and at varying spatial scales. Various studies show that in last 100 years the average temperature of the air near earth’s surface has risen by 1.3 Fahrenheit (Venkataramanan & Smitha, 2011). The increase in temperature results various changes in the physical system of earth. For instance, it accelerates the melting of glaciers and poles ice that raises the sea level. The rise in sea level would have devastating effects as it would submerge a large number of islands like the Maldives laying at very low sea level and hence hundreds of thousands of human lives would be at risk. Also, the rise in global temperature changes the wind pattern across the globe. It would result in colder winters in Europe and more rain in West Africa. On the other hand, there would be an acute scarcity of rain in central Africa (Venkataramanan & Smitha, 2011).  

Pericles Funeral Oration Essay Example for Free

Pericles Funeral Oration Essay I do not think that everything Pericles said in his funeral Oration was true. Pericles goes on and on about how great the Athens city-state had become a strong democratic government. â€Å"He also talks about how they accept everyone into their city-state and give them the same rights as the Athens people regardless if they are foreigners†. â€Å"Pericles even compares his city-state to that of the Spartans; while using slanderous and defaming words to describe their culture†. Pericles believes from reading his Oration that the Athens are better people because of their equally of all in their city state and the freedom they have given their people. Pericles fails to see the contradiction in the culture and in the oration of the Speech he gives about the Athens way of life and this is because he is biased towards the men. Obviously everyone being equal is not true because woman is not equal to men and is certainly not treated as equals. â€Å"Pericles states himself that it is better for woman to never be spoken of whether it is glory or criticism†. He states that a woman’s place is in her home, the only jobs that are available to women are to bare children and to maintain the household, other than that everything else only a man should and could do. The fact that women are treated differently proves that the Athens were not a democratic state their laws to provide fairness to all the people were only catered to the males not the females. The Athens had a negative attitude towards woman and how they should be treated, Pericles seemed almost disgusted to even have to address woman in his speech and when he did he had nothing positive to say about them. Pericles exaggerates in his oration. He depicts a perfect picture of what the Athens society is thought to be, as if the people and the law have no imperfections that need to be spoken of. He illustrates a great city-state with no flaws but then continues to describe and speak of women as if they were not human and discrimination against them was normal. Pericles was in mourning and wanted to give the dead soldiers and their families and all the people of the city-state the honor and confidence they needed to continue on with the war so he exaggerated, he did not want to dishonor the soldier with his words so he chose to speak of their culture and everything they stood for. Coming from a leader’s perspective I think the ideology may be slightly off but much of it was true from the Athens culture and society.

Homeostasis Of Skeletal And Muscular Systems

Homeostasis Of Skeletal And Muscular Systems Living cells of plants and animals are only able to survive under a narrow range of certain conditions that include nutrient availability, pH concentration, temperature, ion concentration among other factors. The human body, usually called inner environment has to time and again adapt to the outside environment which is ever experiencing weather changes and great climate diversification that occurs from one hour to another, one day to another day and from one season to another. It is in this respect that human beings have to device physiological mechanisms in order to survive because any inability by the human body to adjust to these changes leads to either diseases or to death. Human beings for example can only survive under a narrow range of pH values of 7.35 and 7.45.Any value below these results to a situation called acidosis whereas any excess of this causes a situation called alkalosis. It is of paramount importance to note that either condition is as life threatening as the ot her. Likewise, the normal body temperature of 37.2 to 37.7 degrees Celsius has to be equally maintained to ensure survival of a living organism. Any deviation from these results to a condition called hypothermia (if the core body temperature goes below 33 degrees Celsius or 91 degrees Fahrenheit) or hyperthermia (if the core body temperature goes above 42 degrees Celsius or 108 degrees Fahrenheit) This is done through the process called Homeostasis. Homeostasis is the tendency of a system of a living organism, either closed or open, to regulate an internal environment while maintaining a constant and stable condition. Homeostasis is made possible through multiple dynamic equilibrium adjustment and regulation mechanism and not a stable equilibrium as such. This is because internal body conditions are never absolutely stable but varies within a narrow range of average commonly referred to as set point. Several body systems are involved in the process of homeostatic regulation. The Nervous system is in charge of controlling other body parts by sending an electrochemical signal to the brain whenever there is any change from optimum levels. The brain then corresponds by sending the required stimulus to the respective body organ. The Circulatory system, made up of arteries and veins, maintains this balance through the circulation of blood to all other body parts. Through capillaries , an exchange of nutrients in each cell is initiated. This system also enhances the transportation of toxic excretory wastes and other liquid material to the excretory organs. Through lymphatic vessels, the Lymphatic system is involved in homeostasis by collecting excess tissue fluids and taking them back to the veins. The Endocrine system, the main regulator of this process of homeostasis, on the other hand contains hormones (chemical messengers) that keeps circulating throughout the blood stream and acts on the respective target organs. As much as the Endocrine system cannot work without coordinating with the Nervous system, its effects as long lasting even thou they are slow. The process of Homeostatic regulation takes place under a mechanism called feedback. This feedback can either be negative-to ensure stability or positive-to enhance a rapid change. A negative mechanism loop is where a body senses a change in the internal environment and activates methods to negate, reverse or counter that change. A very relevant example of negative mechanism is the process of temperature regulation. A rise in blood temperatures is sensed by specialized neurons located in the hypothalamus found in the brain. This is then signaled to other nerve centers which in turn relay them to the blood vessels of the skin. The dilation of the blood vessels pushes the blood to flow closer to the body surface and excess heat is radiated from the body. If this does not cool the body back to the set point, sweating is activated by the brain. A strong cooling effect is thus felt on the skin due to evaporation of sweat. In the event that the body temperatures fall too low, the same hypo thalamus senses this and signals this to the cutaneous arteries (that supply the skin with blood) to perform an action called constriction. Deeper retention of warm blood in the body is initiated thus less heat is lost from the body surface. If this effect is inadequate, the brain likewise activities the act of shivering and in the course of shivering, each muscle tremor releases heat energy to return the body back to the set point of 37 degrees Celsius. The second mechanism of homeostasis, a counterpart to the negative feedback loop is that of positive feedback and rapid change. In this positive feedback loop mechanism, once the body is able to sense a change, it activates a mechanism to either accelerate or increase that change. As much as this mechanism aids in homeostasis, it mostly produces opposite results and can be life threatening or fatal. A good example of a beneficial positive feedback is exhibited in the process of blood clotting where an enzyme that is used to form the matrix of blood clot thrombin in the complex biochemical pathway is catalyzed thus the process is speeded up. Another beneficial positive feedback is seen in the process of childbirth where the secretion of hormone oxytocin is triggered by the stretching of uterus and this enhances uterine contraction that speeds up labor. Similarly, a beneficial positive feedback is experienced in the process of protein digestion where secretion of hydrochloric acid and enzyme pepsin is initiated by the presence of partially digested protein particles that once digestion begins, it becomes a process that is self-accelerating. However, this mechanism has more harmful and more potential fatal consequences that often results to rapid loss of internal stability. The death of a small area of a heart tissue for example triggers myocardial infarction, a kind of heart attack, because the heart is not able to pump an adequate amount of blood hence the heart itself is deprived of blood and more tissues begins to die. In many cases, this leads to rapid cardiac mal-functioning leading to death. It is therefore important to bear in mind that many deaths that occur are as a result of positive feedback loop. However both the skeletal and the muscular systems work hand in hand in the process of homeostatic regulation in a combined system otherwise known as the muscular skeletal system or rather musculoskeletal system. This system consists of the bones and joints- skeletal system and voluntary or striated muscles-skeletal muscle system. Skeletal muscle fibers contain numerous nucleuses on each cell and the cell nuclei are found beneath the plasma membrane of the skin. Both the skeletal and the muscular systems work together in the process of performing basic and essential functions necessary for life that includes protection (of the brain and other internal organs), supportive services of maintaining an upright posture, blood cell formation in a process called hematopoesis, storage of minerals and fats among other minor duties like leverage that involves magnifying movement or force speed. Musculoskeletal system comprises of five major tissues that include bones, tendons, ligaments cartila ge and skeletal muscles. The ligaments are the tissues on which one bone is attached to another bone. Cartilages are protective and gel-like substances that line interveterbral discs and joints while tendons usually attach muscles to bones. Each of these tissues has four connective blocks that build tissues. They include fibroblasts, collagen, elastic fibers and proteoglycans. Fibroblasts are the mother of all these other connective tissues as it is the one that produces them. Collagens are the principal proteins that are long and thin and are organized into various intertwining fibers to form strong ones that do not stretch. Elastic fibers are found in the walls of arteries whereas proteoglycans are ground substances normally called matrix in which the other connective tissues reside. This combination of functions by both the muscular and skeletal happens mostly when there is a change in both the body pH and the central venous pressure. Active body muscles usually respire and in the process carbon dioxide is produced. The carbon dioxide that is produced dissociates in the blood to produce both hydrogen and carbon ions which have an impact of lowering this pH. Once there is such a decrease in the pH, the chemoreceptors that are centrally located in the brain detect this and induce respiration that accelerates expulsion of the carbon dioxide gas thus maintaining the internal body temperature. The second way in which muscular skeletal homeostasis in the body is evident happens during exercise. Here, more blood is diverted into body muscles as a result of relaxation of arterioles hence a considerable decrease in the volume of blood flowing to the heart. This brings about an impact in the central venous pressure. In order to correct this defect and bring about homeosta sis, the aortic and carotid barroreceptors via the cranial nerves detects this and relays this information in the cardiovascular (medulla) part of the brain. This then lowers the action potential rate in the brain thereby increasing and decreasing the sympathetic and the parasympathetic outputs respectively. The overall result is an increase in not only the inotropy (heart rate) and chronotropy (contractility) but also in vasoconstriction and total peripheral resistance (blood pressure).

Olaudah Equiano :: essays research papers

Olaudah Equiano   Ã‚  Ã‚  Ã‚  Ã‚  Olaudah Equiano was an African American that fell into slavery. He was forced like many other African Americans during the 17th and 18th century. In the short story about Olaudah Equiano, it tells about his life and what he went through being a slave. The Narrative has some similar things that we went over in class. I am going to discuss a few topics about Equiano and other slaves.   Ã‚  Ã‚  Ã‚  Ã‚  First, there was a lot of trading or bartering going on with the white slave owners. They would use their slaves as a material item and not think of them as a person. They thought of them like a product or money. The trade involved the Americans, the Africans, and finally the West Indies. America mostly traded rum for slaves, Africa traded there own people (which would become slaves to whomever owned them) for sugar and molasses with the West Indies. The West Indies would trade rum, molasses, or sugar to America for slaves. This created a “Triangular Trade.'; It was the most popular and resourceful method to get slaves, rum, or any other thing that a certain country wanted. It worked out for everybody trading except for the slaves. Equiano was traded for such items in the Narrative. The first person to “own'; Equiano was a Quaker named Robert King. He did most of his business in the West Indies. Equiano was eventually traded for sugar cane and was forc ed to go on a slave ship. The conditions were horrible.   Ã‚  Ã‚  Ã‚  Ã‚  Equiano was transported on a slave ship called the “Zong.'; The British Republic owned the Zong. Equiano, as well as the other slaves were stuffed under the cargo area. There was so many slaves that they could hardly breathe. They were always hungry because of the little amount of food and the large amount of slaves. Disease spread throughout the ship causing many slaves to die. They would also die of hunger and getting beaten so much by the white crew onboard. Equiano had to survive in these conditions for long periods of time.   Ã‚  Ã‚  Ã‚  Ã‚  Equiano was from Nigeria and lived in a powerful village called Essako. The British kidnapped him in 1756. He was kidnapped with his sister and dragged away from there home. A lot of the whites would just go into villages and start taking African Americans to be their slaves or to trade them for goods.

Peter Paul Rubens :: essays research papers

Peter Paul Rubens was the painter of the first part of the 17th Century in Catholic Europe. How he became so is an interesting story.   Ã‚  Ã‚  Ã‚  Ã‚   Rubens was educated to be a humanist but like all great artists choose his profession for himself. The combination of first-rate classical education with an innate visual genius made for an unprecedented combination in an artist.   Ã‚  Ã‚  Ã‚  Ã‚   It has been said that no artist has ever been as well educated as Rubens. After training with three minor artists in Antwerp. Rubens set off for Italy to complete his education; a position at the court of the Duke of Mantua was quickly accepted and he stayed in Italy for eight years. His job was to travel to all the major artistic collections, especially Rome and Venice painting copies of famous works of art, especially paintings of beautiful women, for the Duke's collection. He was also sent to Spain where he had an opportunity to study the enormous collection of Titian masterworks in the Royal Collection in Madrid. Copying the masterpieces of the Italian Renaissance especially and the recently unearthed sculptures of classical antiquity, Rubens sketched and painted and encompassed all that was best in Italian and Classical art. Rubens combined the lessons of Antique Sculpture with the vaunting ambition of the High Renaissance giants in an unprecedented way. He used the plastic less ons of sculpture as a composition model but insisted that flesh should look like flesh in a painting thus developing his breakthrough approach to the naked body. In this he never forgot the earthy luminous realism of the old Netherlandish tradition of the 15th and 16th century (Van Eyck, Van Weyden, Breughel). You won't appreciate Rubens the master of the female nude until you consider that he was the greatest influence on French painting from the 18th to the 20th century: Watteau, Fragonard, Delacroix, and Renoir were his among his loyal followers.   Ã‚  Ã‚  Ã‚  Ã‚   Rubens was to develop a phenomenal ability to analyze the different styles of painting and sculpture and then synthesis them into whatever his clients wanted. His clients included just about every Catholic monarch, as well as Catholic leaning Protestants like King Charles I of England, and every major religious order in Western Europe. Not to mention every wealthy connoisseur of painting. To satisfy an ever growing demand Rubens opened the largest art workshop Europe has ever seen: he would paint an small initial oil sketch which when approved and contracted for would be given over to one or more of his students to paint the full length canvas, finally Rubens would add the finishing touches and sign it.

Free Essays on Homers Odyssey: Telemachus :: Homer Odyssey Essays

Telemakhos of The Odyssey Telemakhos, Odysseus's son, finally realizes that in order to preserve his estate he must fill in his father's shoes and grow up. Telemakhos not only needs to do this for himself, but for his father who is still alive. Telemakhos became a man his father would be proud of. Twenty years ago Odysseus left for Troy, leaving Telemakhos without a father figure since he was an infant. He grew up a mommy's boy not knowing his role in the kingdom because Odysseus was far away. Telemakhos recognizes that all the men trying to court his mother, Penelope, only want control of his kingdom. Zeus, King of the God's, gives his daughter, Athena permission to encourage Telemakhos to fall into his fathers shoes and become the man he was meant to be. "For my part, I shall visit Ithaka to put more courage in the son, and rouse him."(211 &212) In a way Zeus and Athena are doing what Odysseus could not be there to do. The reader is left to question if Telemakhos needed to be encouraged or would he have grown up on his own? The first sign that Telemakhos is becoming a man is when instead of comforting his mother in her grieving for Odysseus, he scolds her and tells her "Mother, why do you grudge our own dear minstrel joy of song, wherever his thought may lead?" (218) "Odysseus was not the only one at Troy never to know the day of his homecoming. Others, how many others, lost their lives!" (218) Telemakhos then went to his mother's suitors and told them "At daybreak we shall sit down in assembly and I shall tell you---take it as you will---you are to leave this hall." (218) This was very stunning to all the suitors because Telemakhos had no male guidance and they wondered who had invoked him to take back his home and inheritance. The suitors questioned Telemakhos if the God's were "teaching you this high and mighty manner." (218) Telemakhos justified himself by saying "all I insist on is that I rule our house and rule the slaves my father won for me.

Analysis of Hypocrisy in Adventures Essay

The Adventures of Huckleberry Finn, takes place in a time in age where the deficits of society are so intricately interwoven and ignored upon the individuals that make up that society. This results in hypocrisy that constantly plays a crucial part in how Mark Twain depicts the society that participates in such irrational activity. Characters, that Huck and Jim meet as they head for their freedom, which for Jim is slavery, and for Huck is the enslavement through civilization which is â€Å"practiced† by such a hypocrite society. Both are searching for freedom that is well defined in their own parameters; but are kept under constant hypocrisy in the pursuit to achieve their freedom. However, hypocrisy by a â€Å"civilized† society is as dominant in today’s society as it was in the time that Huck and Jim encountered it. Even though today’s, hypocrisies take a new shape and form and are interwoven with daily activities. They are given as much attention as any â€Å"civilized† society would. Although the hypocrisies that are evident in Huckleberry Finn might be in the form of the judge allowing Huck’s father, to keep him in custody, well knowing that he a drunkard would kill Huck to get his money. To the ignorance, of towns people and the nieces who were scammed by the duke and king. Everyone had taken so much self-esteem into the fact that the nieces had accepted the duke and king as their uncles that no one gave a second thought, even when it was publicly announced by Dr.  Robinson; as every â€Å"civilized† person who knew right from wrong sprang upon the doctor, trying to subdue him. As the greatest hypocrisy that took place in the book, was due to the time period itself; a time of white supremacy and racial prejudice, that took place everywhere, a time of slavery. These individuals who Huck ran away from to avoid being civilized, were themselves uncivilized due to the way they treated slaves who are non-other than human beings as well. Implying the fact that it is impossible for a society who owns and treats slaves as uncivilized people themselves can never be just. While, we see this constantly throughout our society today, as people call others fat, anorexic, sub-standard, not cool, not cute, irrational, and stupid; while they themselves have a bottomless pit of ignorance, leading to their own oblivion. Today’s society is actually worse than before in the sense that we are not only fed these things as a child; but we have to incorporate it into daily life through the influence of others, such as parents, media, and peers. Making our very existence, self-evident of such a paradox that can only derive from hypocrisy of a so called â€Å"civilized† society. As the time Mark Twain had written this novel, many social flaws existed within the fabrics of the community as a whole. The book played a major role within the cultural context of the era due to the fact that Jim, who was a slave and Huck a freeman were able to bond and have such an amazing journey together. Within this journey, Twain had interwoven several moments, that on the surface seemed like a norm at the time, but exploited several social flaws that would have otherwise been dismissed by ignorance. Resulting in a successful message from the author, hopefully allowing one to see at that time in age what horrid activities they take place in on a day to day basis, when viewed upon by another person’s spectacle.

Night World : Witchlight Chapter 11

She's what?† Keller said, coming out of the bathroom, toweling her hair. â€Å"She's sick,† Winnie said. â€Å"Runny nose, little temperature. Looks like a cold. Her mom says she has to stay home from school.† Well, it looks like we're having a run of good luck, Keller thought. It would be much easier to protect her inside the house. Winnie and Nissa had spent the night in Diana's room, while Keller, who was supposed to be asleep on the sofa bed in the family room, wandered the house in between catnaps. She'd asked Galen to stay in the guest room, and he had done just that. â€Å"We can have a quiet day,† she said now to Winnie. â€Å"This is great-as long as she gets well for Saturday.† Winnie grimaced. â€Å"What?† â€Å"Um-you'd better go in and talk to her yourself.† â€Å"Why?† â€Å"You'd just better go. She wants to talk to you.† Keller started toward Diana's room. She said over her shoulder, â€Å"Check the wards.† â€Å"I know, Boss.† Iliana was sitting up in bed, wearing a frilly nightgown that actually seemed to have a ribbon woven into the lace at the neck. She looked fragile and beautiful, and there was a delicate flush on her cheeks from the fever. â€Å"How're you feeling?† Keller said, making her voice gentle. â€Å"Okay.† Iliana modified it with a shrug that meant fairly rotten. â€Å"I just wanted to see you, you know, and say good-bye.† Keller blinked, still rubbing her hair with the towel. She wasn't crazy about water, especially not in her ears. â€Å"Say good-bye?† â€Å"Before you go.† â€Å"What, you think I'm going to school for you?† â€Å"No. Before you go.† Keller stopped toweling and focused. â€Å"Iliana, what are you talking about?† Tm talking about you guys leaving. Because I'm not the Wild Power.† Keller sat down on the bed and said flatly, â€Å"What?† Diana's eyes were that hazy iris color again. She looked, in her own way, as annoyed as Keller felt. â€Å"Well, I thought that was obvious. I can't be the Wild Power. I don't have the blue fire-or whatever.† She tacked the last words on. â€Å"Diana, don't play the dumb blond with me right now, or I'll have to kill you.† Diana just stared at her, picking at the coverlet with her fingers. â€Å"You guys made a mistake. I don't have any power, and I'm not the person you're looking for. Don't you think you ought to go out and look for the real Wild Power before the bad guys find her?† â€Å"Diana, just because you couldn't stop that car doesn't mean that you don't have power. It could just be that you don't know how to tap into it yet.† â€Å"It could be. You're admitting that you're not sure.† â€Å"Nobody can be absolutely sure. Not until you demonstrate it.† â€Å"And that's what I can't do. You probably think I didn't really try, Keller. But I did. I tried so hard.† Diana's eyes went distant with agonized memory. â€Å"I was standing there, looking down, and I suddenly thought, I can do it! I actually thought I felt the power, and that I knew how to use it. But then when I reached for it, there was nothing there. I tried so hard, and I wanted it to work so much†¦Ã¢â‚¬  Diana's eyes filled, and there was a look on her face that struck Keller to the heart. Then she shook her head and looked back at Keller. â€Å"It wasn't there. I know that. I'm certain.† ‘It has to be there,† Keller said. â€Å"Circle Daybreak has been investigating this ever since they found that prophecy. ‘One from the hearth that still holds the spark.' They've tracked down all the other Harmans and checked them. It has to be you.† â€Å"Then maybe it's somebody you haven't found yet. Some other lost witch. But it's not me.† She was completely adamant and genuinely convinced. Keller could see it in her eyes. She had managed to vault back into denial in a whole new way. â€Å"So I know you'll be leaving,† Iliana went on. â€Å"And, actually, I'll really miss you.† She blinked away tears again. â€Å"I suppose you don't believe that.† â€Å"Oh, I believe it,† Keller said tiredly, staring at an exquisite gold-and-white dresser across the room. â€Å"I really like you guys. But I know what you're doing is important.† â€Å"Well, is it okay with you if we just hang around for a little while longer?† Keller asked heavily. â€Å"Just until we see the light and realize you're not the Wild Power?† Iliana frowned. â€Å"Don't you think it's a waste of time?† â€Å"Maybe. But I don't make those decisions. I'm just a grunt.† â€Å"Don't you treat me like a dumb blond.† Keller opened her mouth, lifted her hands, then dropped them. What she wanted to say was, How can I help it when you're determined to be such a nincompoop? But that wasn't going to get them anywhere. â€Å"Look, Iliana. I really do have to stay until I get orders to go, all right?† Keller said, looking at her. â€Å"So you're just going to have to bear with us for a little while longer.† She stood up, feeling as if a weight had fallen on her. They were back to square one. Or maybe not quite. â€Å"Besides, what about Galen?† she said, turning back at the door. â€Å"Do you want him to go?† Diana looked confused. Her cheeks got even pinker. â€Å"I don't†¦ I mean†¦Ã¢â‚¬  â€Å"If you're not the Wild Power, you're not the Witch Child,† Keller went on ruthlessly. â€Å"And you know that Galen has to promise himself to the Witch Child.† Iliana was breathing quickly now. She gulped and stared at the window. She bit her lip. She really is in love with him, Keller thought. And she knows it. â€Å"Just something to keep in mind,† she said, and went out the door. â€Å"Did you get any info on the license plate?† Nissa shook her head. â€Å"Not yet. They'll call us when they have anything. And a courier brought this.† She handed Keller a box. It was the size of a shirt box but very sturdy. â€Å"The scrolls?† â€Å"I think so. There are wards on it, so we have to get Winnie to open it.† They had a chance after breakfast. Mrs. Dominick took the baby and went out shopping. Keller didn't worry too much about her. Just as Jaime was now being watched by Circle Daybreak agents, any members of Iliana's family who left the safety of the wards would be followed for their own protection. They sat around the kitchen table-except for Iliana, who refused to join them and sat in the family room in front of the TV. She had a box of tissues, and every few minutes she would apply one to her nose. â€Å"Before you open that,† Keller said to Winnie, â€Å"how are the wards around the house?† â€Å"They're fine. Intact and strong. I don't think anybody's even tried to mess with them.† Galen said, â€Å"I wonder why.† Keller looked at him quickly. It was just what she had been wondering herself. â€Å"Maybe it has something to do with what happened yesterday. And that's the other thing I want to talk about. I want to hear everybody's opinions. Who was in that car-Night Person or human? Why did they try to run over Jaime? And what are we going to do about it?† â€Å"You go first,† Winnie said. â€Å"I think you had the best view of it.† â€Å"Well, I wasn't the only one,† Keller said. â€Å"There was someone else beside me.† She looked toward the living room. Iliana made a show of ignoring her completely. Keller turned back. â€Å"But anyway, simplest first Let's say the car was from the Night World. They cruised down the street in front of the school once before coming back. It's perfectly possible that they saw Iliana standing at the window. Maybe they were trying to determine for sure that she was the Wild Power. If she'd stopped the car, they'd have had solid proof.† â€Å"On the other hand,† Nissa said, â€Å"they must be pretty sure she's the Wild Power. After all, it's really beyond question.† She was looking earnestly at Keller, but she spoke loudly enough for Iliana to hear everything distinctly. Keller smiled with her eyes. â€Å"True. Okay, more ideas. Winnie.† â€Å"Uh-night.† Winnie sat up straighter. â€Å"The car was from the Night World, and they weren't actually trying to run over Jaime. They were going to snatch her because they somehow knew she'd been with us, and they figured she might have some information they could use.† â€Å"Nice try,† Keller said. â€Å"But you were over by the door. You didn't see the way that car was driving. No way they were planning to grab her.† â€Å"I agree,† Galen said. â€Å"They were going too fast, and they were heading right for her. They meant to kill.† Winnie dropped her chin into her hands. â€Å"Oh, well, fine. It was just an idea.† ‘It brings up something interesting, though,† Nissa said thoughtfully. â€Å"What if the car was from the Night World, and they knew Iliana was watching, but they weren't trying to get her to demonstrate her power? What if they were just trying to intimidate her? Show what they were capable of, by lolling her friend right in front of her eyes? If they knew how close she and Jaime were-â€Å" â€Å"How?† Keller interrupted. â€Å"Lots of ways,† Nissa said promptly. â€Å"If they haven't snooped around that high school and talked to other kids, their intelligence system is worse than I think. Ill go farther. If they don't know that Jaime was in that music room with us yesterday at lunch, they ought to turn in their spy badges.† ‘If that's true, then maybe it's even simpler than we think,† Galen said. â€Å"The law says that any human who finds out about us has to die. Maybe the car was from the Night World, and they didn't know that Iliana was watching-or they didn't care. They thought Jaime knew the secret, and they just wanted to carry out a good, old-fashioned Night World execution.† â€Å"And maybe the car wasn't from the Night World!† Iliana yelled suddenly, jumping off the family room couch. She wasn't even pretending not to listen anymore, Keller noted. â€Å"Did any of you ever think of that? Maybe the car just belonged to some crazed juvenile delinquents and it's all a massive coincidence! Well? Did you think of that?† She stood with her hands on her hips, glaring at all of them. The effect was somewhat diluted because she was wearing a frilly nightgown with a flannel robe over it and slippers with teddy bear heads on them. Keller stood up, too. She wanted to be patient and make the most of this opportunity. But she never seemed to have much control where Iliana was concerned. â€Å"We've thought of it. Circle Daybreak is trying to check on it-whether the car's registered to a human or a Night Person. But you're asking for a lot of coincidence, aren't you? How often do people deliberately run each other over in this town? What are the chances that you just happened to be watching when one of them did it?† She felt Galen nudge her ankle with his foot. With an effort, she shut up. â€Å"Why don't you come over here and talk with us about it?† he said to Iliana in his gentle way. â€Å"Even if you're not the Wild Power, you're still involved. You know a lot about what's been going on, and you've got a good mind. We need all the help we can get.† Keller saw Winnie glance at him sharply when he said the bit about Iliana having a good mind. But she didn't say anything. Iliana looked a little startled herself. But then she picked up the box of tissues and slowly came to the kitchen table. â€Å"I don't think well when I'm sick,† she said. Keller sat down. She didn't want to undo what Galen had accomplished. â€Å"So where does that leave us?† she asked, and then answered her own question. â€Å"Nowhere, really. It could be any of those scenarios or none of them. We may need to wait for whatever Circle Daybreak comes up with.† Keller looked around the table grimly. â€Å"And that's dangerous,† she said. â€Å"Assuming it was the Night World that sent that car, they're up to something that we don't understand. They could attack us at any moment, from any direction, and we can't anticipate them. I need for all of you to be on your guard. If anything suspicious happens, even the fittest thing, I want you to tell me.† â€Å"It still bothers me that they haven't even tried to get in here,† Galen said. â€Å"No matter how strong the wards are, they should at least be trying.† Keller nodded. She had an uneasy feeling in the pit of her stomach about that. â€Å"They may be laying some kind of a trap somewhere else, and they may be so confident that well fall into it that they can afford to wait.† â€Å"Or it could be that they know I'm not the one,† Hiana chimed in sweetly. â€Å"And they're off kidnapping the real Wild Power while you guys are wasting your time here.† She blew her nose. Keller gritted her teeth and felt a pain in her jaw that was getting familiar. â€Å"Or it could be that we just don't understand dragons,† she said, possibly with more force than was necessary. She and Diana locked stares. â€Å"You guys, you guys,† Winnie said nervously. â€Å"Um, maybe it's time we opened this.† She touched the box Circle Daybreak had sent. Diana's eyes shifted to it with something like involuntary interest. Keller could see why. The box had the mysterious allure of a Christmas present. â€Å"Go ahead,† she told Winnie. It took a while. Winnie did witchy things with a bag of herbs and some talismans, while everyone watched intently and Diana mopped her nose and sniffled. At last, very carefully, Winnie lifted the top of the box off. Everyone leaned forward. Piled inside were dozens and dozens of pieces of parchment. Not entire scrolls but scraps of them, each encased in its own plastic sleeve. Keller recognized the writing†-it was the old language of the shapeshifters. She'd learned it as a child, because Circle Daybreak wanted her to keep in touch with her heritage. But it had been a long time since she'd had to translate it. Diana sneezed and said almost reluctantly, â€Å"Cool pictures.† There were cool pictures. Most of the scraps had three or four tiny illustrations, and some of them had only pictures and no writing. The inks were red and purple and deep royal blue, with details in gold leaf. Keller spread some of the plastic sleeves across the table. â€Å"Okay, people. The idea is to find something that will show us how to fight the dragon, or at least something to tell us how he might attack. The truth is that we don't even know what he can do, except for the black energy he used on me.† â€Å"Um, I can't read this, you know,† Diana pointed out with excessive politeness. â€Å"So look at the pictures,† Keller said sweetly. â€Å"Try to find something where a dragon is fighting a person-or, even better, getting killed by one.† â€Å"How do I know which one's the dragon?† It was an amazingly good question. Keller blinked and looked at Galen. â€Å"Well, actually, I don't know. I don't know if anybody knows how to tell a dragon from another Night Person.† â€Å"The one in the mall-Azhdeha-had opaque black eyes,† Keller said. â€Å"You could tell when you looked into them. But I don't suppose that's going to show up on a parchment like this. Why don't you just look for something with dark energy around it?† Iliana made a tiny noise that in someone less delicate would have been called a snort. But she took a pile of the scraps and began poring over them. â€Å"Okay,† Keller said. â€Å"Now, the rest of us-â€Å" But she never got to finish. The phone on the kitchen wall shrilled. Everyone glanced up toward it, and Iliana started to stand, but there was no second ring. After a long moment of silence, it rang again-once. â€Å"Circle Daybreak,† Keller said. â€Å"Nissa, call them back.† Keller tried not to fidget as Nissa obeyed. It wasn't just that she was hoping against hope that there was useful information about the car. For some reason she couldn't define, that very first ring of the phone had made her feel unsettled. The early warning system of the shapeshifters. It had saved her life before, by giving her a hint of danger. But for what was about to happen now, it was entirely useless. â€Å"Nissa Johnson here. Code word: Angel Rescue,† Nissa said, and Keller saw Diana's eyebrows go up. â€Å"Yes, I'm listening. What?† Suddenly, her face changed. â€Å"What do you mean, am I sitting down?† Pause. â€Å"Look, Paulie, just tell me whatever-â€Å" And then her face changed again, and she did something Keller had never seen Nissa do. She gasped and brought a quick hand up to her mouth. â€Å"Oh, Goddess, no!† Keller's heart was pounding, and there was a boulder of ice in her stomach. She found herself on her feet without any memory of standing. Nissa's light brown eyes were distant, almost blank. Her other hand clutched the receiver. â€Å"How?† Then she shut her eyes. â€Å"Oh, no.† And finally, very softly, â€Å"Goddess help us.†