Monday, May 11, 2020
Best Reputed World Universities Announced
The Times Higher Education has published the annual list of top 100 influential, powerful and best reputed universities in the world. The list is published since 2011, with the research methods growing in complexity and finesse every year. In order to eliminate the possibility of subjectivity, the survey is carried out on invitation-only basis, and includes only the opinions of very experienced scholars with multiple publications and excellent academic reputation, who found their opinions on their understanding of academic excellency, education methods and overall efficiency of universities in question. More than 10,000 responses from 142 countries were processed, with people taking part in the survey spending on average more than 15 years in higher education and research. The main goal of this yearââ¬â¢s survey was to achieve the best possible spread, both in terms of geography and disciplines. Engineering, technology, social, physical and other sciences have all been represented more or less equally, and the responses are more evenly spread among countries. Arts and humanities in particular have been represented much better than previously, with their share growing from 9 per cent last year to 16 per cent. The reputation score is based on the number of times the university is mentioned by respondents as the best in their particular field. That said, the survey pays greater attention to the research capabilities of the university than its educational facilities, because, according to experts, respondents in general give more accurate judgment on it. The results, at least in what pertains to the top-20, are not very surprising. The first place is held (and was held since the survey was first conducted in 2011) by Harvard University, still far ahead of its closest contenders. Harvardââ¬â¢s score was taken as the basis for calculations, with all the others showing the percentages of how often it was cited by the respondents. Cambridge and Oxford have risen to second and third places correspondingly, overtaking the Massachusetts Institute of Technology and Stanford University that occupied this position last year. British universities have shown better results in general ââ¬â there are 12 UK universities in the top 100 compared to the last yearââ¬â¢s results, with the newcomers being the universities of Durham and Warwick. In general, the USA continues to dominate the list, with 26 US universities in top-50 positions and 43 in the list on the whole. Two universities deserving a notable mention are Tokyo University (twelfth) and the Chinese top higher education institution, Tsinghua University, raising 10 places up to the 26th. Some other countries are notable for their absence ââ¬â for example, India, despite its strong academic traditions, didnââ¬â¢t make it. It, however, should be noted that the survey authors indicate that only the first 50 positions should be treated as following one another, as the differences in ratings between them is quite noticeable. The difference between ratings of the lowest half of the list, however, is so negligible that these universities are simply said to have made it into the top-100, with the place they occupy being largely irrelevant.
Wednesday, May 6, 2020
Parenting Techniques Free Essays
Behavior Parent Training on Fathers Parenting The Behavioral parent training programs have been developed to address child behavior problems through improvement in parenting practices. The triple P or Positive Training Program is widely reported as an effective, evidence based program for parents. However this journal demonstrates that there are significant differences in the programââ¬â¢s effectiveness for mothers and fathers. We will write a custom essay sample on Parenting Techniques or any similar topic only for you Order Now The analysis on this journal demonstrates that The Positive Parenting Program shows a large effectiveness on mothers while having a smaller effect on fathers parenting practices. Considering that fathers make a significant contribution to child development. It is now well accepted that ââ¬Å"poorâ⬠parenting practices will have significant impacts on childrenââ¬â¢s emotional and behavioral wellbeing. Parentsââ¬â¢ harsh inconsistent discipline, inadequate supervision, and a lack of positive relationship have been shown to increase childrenââ¬â¢s behavior problems and later on in life lead to substance abuse, antisocial behavior and criminal activities. In order to strengthen parenting competencies and improve parent-child interactions a wide range of Behavioral Parent Training programs have been developed. According to the journalââ¬â¢s analysis the Positive Parenting Program is very effective when involving the mother and the father, and the children are the beneficiaries of better parenting skills. The study does not show which population the program is working on therefore we have to take into consideration how can we make the proper adjustments in order to make it work for other populations. It is a known fact that mothers are more involved with the program and the children than the fathers are, but fathers are getting involved more every time. Prior parental training programs did not focus on fathers or valued any input on it and there was very little literature for the fathers. The fathersââ¬â¢ involvement plays a very important role on the childrenââ¬â¢s life and upbringing and the fathersââ¬â¢ impact on the childââ¬â¢s life is separate from that of the mothersââ¬â¢. On the one hand, fathers positive parenting (sensitive to childrenââ¬â¢sââ¬â¢ interests, supportive of their autonomy) has been identified as protective against externalizing problems in young children; on the other hand negative training by fathers (harsh discipline, unstable presence) has been found to increase the behavior problems on both boys and girls. Fathers participation on the program improves the childââ¬â¢s behavior and helps to support each other as parents. So the fathersââ¬â¢ involvement on the program is crucial not only for the child but the mother also. Providers need to support the involvement of fathers in the parenting trainings. The Positive Parenting Program focuses on the participation of both the mother and father, and fathers actually benefit from the program. The Positive Parenting Program has five levels; the first level focuses on community media, and information on how to deal with basic child problems. Level two offers individual support, providers offer advice and tips on how to deal with child issues, level three does four thirty minutes behavior counseling sessions in order to manage the progress or lack thereof. Level four was developed for children with disabilities, these sessions deal with the childââ¬â¢s misbehavior and offer strategies for encouraging their development, and level five covers a home-based skills training sessions that offer coping with stress and emotions, marital communication support. It is designed for parents at risk of child maltreatment; it also focuses on anger management. The Positive Parent Program has been used by culturally diverse parents, multi languages, face to face, telephone, and electronic modalities with remarkable results. How to cite Parenting Techniques, Essay examples
Friday, May 1, 2020
Benefits of Sustainability Driven Innovation
Question: Examples of the enterprises you might consider include, a day care centre, a carpet manufacturing business, a small zoo, an insurance office, a bank, an auto repair shop, a veterinary surgery, and many other possibilities including a global corporation like BHP Billiton. Answer: Introduction: Monitoring system is effective for an organization to understand whether they are following the proper method or taking the right steps to achieve the goal that have been set by the organization (Werbach, 2013). The indicators in the monitoring system can be compared to the factors that will help in understanding whether the motoring system is helping the organization to understand whether they are fooling the right path. The monitoring system should be able to measure the output that will reflect the strategies that have been set by the organization (Ferguson Souza, 2016). The monitoring system will be able to identify the main problem that will be faced by an organization while they are operating in the market. The monitoring system needs to be iodated regularly so that the employers can keep a track of the changes that are taking place in the organization. The monitoring system should be user-friendly so that the management can easily use it. The employees should not need any extra training to operate it. The company should not have to bear any cost to run the monitoring system. Even if they have to bear any cost, then the system should be cost-effective enough so that they do not have to plan any extra expenditure to implement the monitoring system. Not only the monitoring system but also the indicators should be effective so that the monitoring system will be helpful to identify the strength and weakness of the organization (Sloan, Klingenberg Rider, 2013). The indicators should be relevant. The indicators should be able to show the things that the organization need to know. The indicators should be easy to understand. The employees should be needing any extra training to understand the meaning of the indicators. The organization should not have to hire any expert to understand the indicators. The employees of the organization as well as the employer should be able to trust the indicators. The indicators should be reliable and highlight the correct data needed by the organization. Any wrong information given by the indicators will take the organization in some other direction. The indicators should not be consisting of those data that cannot be accessed by the people of the organization. The data should be accessible that will make up the indicators. The organization should have the time to act if the indicators show something is wrong. Indicators cannot be called effective if that does not give time for the employees and the employer to make things right after they have noticed something wrong. Rio Tinto needs a proper management system mainly because of two reasons. They have to go up the dunphy scale. Secondly, to go up the dunphy scale, they have need funds that could help them to implement more sustainable measures. The indicators of the monitoring system that will measure the actions of Rio Tinto should keep in mind the profit as well as sustainability to help them go up the Dunphys scale. They need to keep a check on the profit to see that whether their steps are enhancing the business. They need to keep a check on the employee engagement and so that there is balance between the urban employees and the aboriginal employees. The certifications by the external organization are necessary as they will help them to spread their goodwill gestures and help them acquire more clients and finances for their business. Literature Review The Dunphys scale is the best way to measure whether the business of an organization is sustainable enough. Rio Tinto has taken many measure towards sustainable development if the business. Some are directed towards the environment while some are socio-cultural in nature (Beckmann, Hielscher Pies, 2014). They have taken steps to make help the aboriginal as a many parts of the land that are possessed by the aboriginals are being used by the organization for mining purpose (Riotinto.com, 2017). Following is the Dunphys scale: Business case for sustainability The sustainable development of Rio Tinto is worth mentioning and they aim at developing a socio-cultural development of the society. They help in development of the aboriginals who are living in the area and working with the organization (Sidiropoulos, 2014). The aboriginal were ill-treated when in the year, 1963 when the Mapoon mission was closed even after the discovery of bauxite reserve in the year, 1955. The contribution of the indigenous people like Old Matthew (Wakmatha) and George Wilson (Piiramu) was not overlooked after the mission was halted. Six years down the lane after the incident took palce, tio tinto is workimnh in close contact with the aboriginals. Some of the agreements that have helped in the partnership of Rio Tinto and the aboriginals are: The Weipa Township Agreement The Western Cape Communities Co-existence Agreement (WCCCA) The Ely Bauxite Mining Project Agreement Current Dunphy Phase Status of Rio Tinto is at the efficiency stage of the Dunphys scale. The human sustainability is stresses upon in the efficiency stage of the Dunphys scale. Rio Tinto aims at development with the help of the aboriginals (Riotinto.com, 2017). The ratio of the aboriginals who are working for the organization is not in balance with the area that is being used for the operations of the company. 60 percent of the land that are under the aboriginals are used to get the minerals but only 6 percent of the population are involved in the workforce. The place is hugely exploited by Rio Tinto to mine the metals and hence, it is necessary that the workforce should have more aboriginals. Even though Rio Tinto is planning to incorporate for aboriginals in their business, yet they are unable to find a way that will help in reducing the exploitation of the environment. The main aim of involving the aboriginals in their program is to take their help to get an idea for land rehabilitation program. The idea of land rehabilitation is in the pipeline and the involvement of the aboriginals will be helpful as they could tell the ways to restore nature even after mining the land to extract the metals and the minerals. Rio Tinto can be said to be in the efficiency phase as they are not able to implement any such idea to restore the land but the discussions are still on to get such an idea. They are employing the aboriginal, which is a good step but they are not able to employ a huge number of people. The aboriginals should be employed in huge numbers as they are exploiting their land and they have the best idea about the land (Buxel, Esenduran Griffin, 2015). Required elevated position of Dunphy Phase The main aim of every organization should be to reach phase six of the scale but the phase six, which is the sustaining corporation phase. However, the phase has been considered to be too abstract and is not possible in reality (Kiron et al., 2013). The employer would then be left with minimum profit to support the employees who are working in the organization (Sharma Hart, 2014). Hence, Rio Tinto should aim at reaching phase 5, which is the strategic sustainability phase. The organization should have diversity at workplace by balancing the workforce (Wagner Svensson, 2014). There should be equal number of aboriginals and urban employees. The aboriginals do not receive proper training and specific skills to get employment. Hence, it will be the duty of Rio Tinto to educate the people and help them get a job in the organization. They do receive preliminary education but the skills that are needed for mining jobs. It is the duty of the organization to teach the aboriginals about the mining techniques and help them get a job. In this way, they will be able to attain the strategic sustainability phase. The organization has been able to witness a reduction of 30% in the indigenous turnover. Environmental concerns, which is another area that should be taken into consideration (Sloan, Klingenberg Rider, 2013). If more number of aboriginal populations is employed in the organization, they will be able to know the ways that will help them save the land of the aboriginals even after mining is done (Werbach, 2013). The Enterprise Rio Tinto is a British-Australian multinational mining company with its headquarters in London, United Kingdom (Riotinto.com, 2017). The company consisted of Rio Tinto Plc, which is a London and New York stock exchange company and Rio Tinto Limited, which is an Australian Securities Exchange. The business of Rio Tinto is based on four factors: Finding Mining Processing Marketing They aim at finding the mineral resources and deliver them to the customers and the clients. They value the shareholders of the company and work to deliver the best returns with the help of the assets of the company and projects that they take up for the clients. As far as the workforce is concerned, Rio Tinto possesses 55,000 employees. The operations of the organization are spread in 40 countries and the employees work in strong teams. The organization always follows the motto of safety first when it comes to the employees. They believe in innovation and the employees work hard to make those innovations a reality and never steps back from learning something. The major products for Rio Tinto are industrial minerals like salt, titanium dioxide and borates. Other major products are gold, aluminum, diamonds and copper (Riotinto.com, 2017). The metals that are mined by Rio Tinto are converted into end-products and those products are used for development of the living standards and other economic developments of the society. The innovations that are applied to work are not limited to work. Innovations are applied for sustainable development. The organization faces with various challenges like climate change, regional community development, resource scarcity and community employment. The best part of Rio Tinto is that the organization does not see the challenges as challenges but opportunities. They aim at getting over the challenges and help in developing a sustainable business. Conclusion After going through the case of Rio Tinto and placing it on the Dunphys Scale it can be concluded that the organization is performing well as it is on the efficiency phase of the scale. The company involves the aboriginals in their business as most of their land has been used for the mining purposes. However, there is a huge gap between the number of urban employees as and the aboriginal employees. In addition to this, the land exploitation is affecting the environment. It can be said once they employee more aboriginal employees, they will help in giving ides to save the land. The monitoring system suggests that they need to keep a check on the profit, the employee engagement and the result of the external organization. The development plan includes the business model canvas, which will help Rio Tinto to go up from the efficiency phase to strategic sustainability phase. References Beckmann, M., Hielscher, S., Pies, I. (2014). Commitment Strategies for Sustainability: How Business Firms Can Transform Trade?Offs Into WinWin Outcomes.Business Strategy and the Environment,23(1), 18-37. Buxel, H., Esenduran, G., Griffin, S. (2015). Strategic sustainability: Creating business value with life cycle analysis.Business Horizons,58(1), 109-122. Ferguson, M. E., Souza, G. C. (Eds.). (2016).Closed-loop supply chains: new developments to improve the sustainability of business practices. CRC Press. Globalreporting.org,. (2017).About GRI.Globalreporting.org. Retrieved 10 January 2017, from https://www.globalreporting.org/information/about-gri/Pages/default.aspx Integratedreporting.org,. (2017).Integrated Reporting.Integratedreporting.org. Retrieved 10 January 2017, from https://integratedreporting.org/ ISO,. (2017).ISO - International Organization for Standardization.ISO. Retrieved 10 January 2017, from https://www.iso.org/iso/home.html Kiron, D., Kruschwitz, N., Reeves, M., Goh, E. (2013). The benefits of sustainability-driven innovation.MIT Sloan Management Review,54(2), 69. Riotinto.com,. (2017).About Rio Tinto.Riotinto.com. Retrieved 9 January 2017, from https://www.riotinto.com/aboutus/about-rio-tinto-5004.aspx Riotinto.com,. (2017).Working together for a better future.Riotinto.com. Retrieved 10 January 2017, from https://www.riotinto.com/ourcommitment/spotlight-18130_18749.aspx Sharma, S., Hart, S. L. (2014). Beyond saddle bag sustainability for business education.Organization Environment, 1086026614520713. Sidiropoulos, E. (2014). Education for sustainability in business education programs: a question of value.Journal of cleaner production,85, 472-487. Sloan, K., Klingenberg, B., Rider, C. (2013). Towards sustainability: Examining the drivers and change process within SMEs.Journal of Management and Sustainability,3(2), 19. Wagner, B., Svensson, G. (2014). A framework to navigate sustainability in business networks: The transformative business sustainability (TBS) model.European Business Review,26(4), 340-367. Werbach, A. (2013).Strategy for sustainability: A business manifesto. Harvard Business Press.
Saturday, March 21, 2020
Leadership Essay Example
Leadership Essay Example Leadership Essay Leadership Essay Name: Course: Instructor: Date: Consider It less manifests, and more can be applied If enough energy and determination Is given to the task. A leader can pour his heart and soul Into any activity he wants, and get his hands dirty on any task with his subordinates. I do not mean to Imply an NCO, or other leaders, Job Is not supervision, but there is fellowship to be had in any undertaking: one must simply Know winner ten Ellen Is. Being ten TLS awake Ana areas Is a small Acton Tanat snows much, likewise being the last to quit a OPT session, or volunteering for the distasteful. This last, I have been taught by the Corps itself, must be tempered with understanding of your Marines capabilities and readiness. Again, the most emboldened leader must have the technical assets in order to be a solid leader. On that, not all of this is physical; it can Just as easily mean studying more and harder than those you push to the books, and even acknowledging when you do not have an answer but being the one to energetically seek it out. This drive to succeed for your men, to set the example, is really ordered upon the NCO. The final line of a Noncommissioned Officers creed, their performance will reflect an image of me indicates our obligation to not Just tell, but show our Marines how to live and serve. This standard must be set, and set high to continue in the hallowed footsteps all those who came before us. A leader must demonstrate how to be a Marine and inspire others to emulate his example. Ultimately, the philosophy on leadership that I try to be worthy of, gleaned from classes, role models, and experiences, can be summed up by two words: Follow me.
Thursday, March 5, 2020
Using the Spanish Verb Tocar
Using the Spanish Verb Tocar The core meaning of the Spanish verb tocar is to touch. In fact, both words come from the Latin verb toccare. Common Meaning of Tocar Probably the most common meaning of both tocar and touch is to refer to physical contact between things or persons. Some examples of the word used this way in Spanish: Tocà ³ los dedos de su esposa, flojos y calientes. (He touched his wifes weak and warm fingers.)Cuando el avià ³n tocà ³ tierra los pasajeros aplaudieron. (When the plane touched ground, the passengers applauded.)No tocaron el està ©reo. (They didnt touch the stereo.) This meaning is sometimes figurative: Los ciudadanos son ms pobres y aà ºn no han tocado fondo. (The citizens are poorer, and they still havent hit bottom.)Espera con paciencia su momento para tocar el cielo. (She is waiting patiently for her time to touch to the sky.) As with the English touch, tocar can be used as a euphemism to refer to sexual contact: Ãâ°l me decà a que lo nuestro era platà ³nico, y no me tocaba. (He would tell me that our relationship was platonic, and he didnt touch me.)Desde nià ±a me tocaba, y el repulsivo me ofrecà a dinero para que me acostara con à ©l. (Since I was a girl he touched me, and the creep would offer me money to sleep with him.) Using Tocar With Indirect Objects When tocar is used with an indirect object, it can refer to the turn or responsibility of the person who is the indirect object. The exact translation depends on the context: à ¿A quià ©n le toca? (Whose turn is it? Whose job is it?)El mià ©rcoles de esa semana me toca trabajar. (On Wednesday of that week its my responsibility to work.)Nos toca pagar. (Its our turn to pay. Its up to us to pay.) The same can be done when tocar means to affect a person emotionally. In this way, tocar can behave much like the verb gustar. El blues es la mà ºsica que ms me toca el corazà ³n. (Blues is the music that most touches my heart. In this sentence, the direct object is el corazà ³n, while me is functioning as an indirect object.)La actriz digo que la realizacià ³n de este film le tocà ³ emocionalmente. (The actress said that the making of this film touched her emotionally.)Le tocaba el alma la cancià ³n de Navidad. (The Christmas song touched his soul.) Other Meanings of Tocar The other meaning of tocar that is extremely common in Spanish is to play a musical instrument or similar item. For example: La guitarra es uno de los instrumentos ms fciles de aprender a tocar. (The guitar is one of the easiest instruments to learn to play.)Voy a darme un baà ±o y luego tocarà © el piano. (Im going to take a bath and later Ill play the piano.)A la muerte de Susana, se tocaron las campanas de todas las iglesias. (When Susana died, they rang the bells of all the churches.) When referring to someones speaking or writing, tocar can mean to touch on. El presidente no tocà ³ el tema de Irak. (The president didnt touch on the subject of Iraq.)Los Monty Python tocaron todos los gà ©neros del humor. (Monty Python touches on all types of humor.) Tocar can be used so that its subject represents something that is given to someone: Le tocà ³ la loterà a. (He won the lottery.)Le ha tocado un tiempo muy difà cil. (He had been given a very rough time.) Tocar also is used in some set phrases or idioms: Por lo que a mà me toca (as far as Im concerned)à ¡Toca madera! (Touch wood!)Tocar de cerca (to have a close relationship with someone, or to be very familiar with a subject)Tocarle a alguien bailar con la ms fea (to be expected to do something very difficult or disagreeable) Conjugation of Tocar Tocar is conjugated irregularly in spelling but not pronunciation. The c is changed to qu when followed by the e. For example, the first-person preterite form is toquà © (meaning I touched), and the present subjunctive forms follow the pattern of toque, toques, toquemos, etc. Key Takeaways The Spanish verb tocar comes from the same source as the English verb touch and often has that meaning. Among many other meanings, it is also used for to play a musical instrument.When it means to be emotionally touching or to refer to taking turns, tocar is used with an indirect-object pronoun.Tocar is conjugated regularly in terms of pronunciation, but the c of the stem changes to qu when it comes before an e in conjugated forms.
Monday, February 17, 2020
DEPRESSION Research Paper Example | Topics and Well Written Essays - 1500 words
DEPRESSION - Research Paper Example Sleeplessness, feelings of helplessness and hopelessness, Loss of interest in daily activities, Appetite or weight changes etc are some of the major symptoms of depression. Depression can be treated effectively with the help of a psychologist and a psychiatrist. This paper analyses various dimensions of depression. Depression Depression is one of the major psychological diseases which prevent people from leading a normal life. Most of the psychological disorders originated from depression. It is difficult to assess how severely a person is affected by depression. Unlike physical diseases, psychological diseases cannot be assessed with the help of any laboratory testing. The major symptoms of depression can be witnessed in the behaviors of the patient and the severity of the disease can be assessed only through the evaluation of the behavioral pattern of the patient. Chronic depressive patients may cause physical injuries to themselves and others. ââ¬Å"It has been estimated that per haps somewhere between 10 and 30 percent depressives and manic depressives kill themselvesâ⬠(Klein, & Wender, 2005, p.1). Even though the actual causes of depression is still unknown, psychologists believe that heredity and environment plays an important role in making a person depressive. ... Many of them may not sleep well and mood changes occur to them constantly and continuously. It is difficult for depressive patients to concentrate longer on a particular topic. They often complain about unrealistic problems they are facing. For example, it is quite possible that a depressive patient may complain about body pain, head ache etc even though they have no such real problems. Fatigue or tiredness can be witnessed in every activities of a depressive patient. Depressive patients often avoid the company of others and they will try to lead a lonely life. Anxiety is another major symptom of depression. Causes of depression Heredity and environment are the major reasons which contribute heavily to the psychological disorders like depression. A person with family history of psychological disorders is more vulnerable to depression. Same way, a person living in a tough environment can also develop depression. According to Chan et al (2010), ââ¬Å"as many as 38% of cancer patients suffer from major depression, with a mean of 24% and median of 22%â⬠(Chan et al, 2010, p.46). In other words, many of the chronic physical diseases can contribute to the development of depression among people. Man is a social animal who likes to interact with others. These interactions often create stresses in the minds of a person. Personal, family, social and professional commitments of the current generation are more than that of the older generation. The failure in fulfilling these commitments may often make the person depressive. Klein &Wender (2005) have mentioned that depressive illness is often triggered by a real event like the death of a loved one (Klein, & Wender, 2005, p.13). It is possible that people develop close relationships with some others.
Monday, February 3, 2020
Company Law - English law Case Study Example | Topics and Well Written Essays - 2500 words
Company Law - English law - Case Study Example Commentators have attempted to categorise those decisions under various headings, such as agency, fraud, group enterprise, tort and so forth6. What is clear on a close reading of the cases which have distinguished Salomon is that the courts will only interfere - by lifting the veil of incorporation - where there is clear evidence of wrongdoing or where they are required to interfere by Statute. There is therefore a presumption that members of a limited company are only liable to the extent of any unpaid amount on nominal value of their shares unless 'wrongdoing' can be established. LJM Limited seems to have been incorporated for the sole intention of providing a vehicle for the directors Jean, Lynette and Lauren to unlawfully deprive W&H Limited, its shareholders and its members of its corporate assets and any retained profits from the international contract. There is authority to suggest that the courts will lift the veil to prevent evasion of an existing obligation7 and the court will grant an injunction/specific performance in that instance. For a short while it also seemed to be the case that the court would lift the veil where there was clear evidence of asset stripping. In Creasey v. Breachwood Motors Ltd [1992]8 proprietors of Breachwood Welwyn Ltd transferred that company's assets to the defendant company. The evidence indicated that the defendant company had been formed for the sole purpose of avoiding the payment of a substantial wrongful dismissal claim. Breachwood Welwyn Ltd was then struck off the company register following the procedure laid down in Section 652 of the Companies Act 1985; hence depriving the plaintiff of any redress. Robert Southwell QC, sitting as deputy High Court Judge, held that the plaintiff could present his claim for damages directly against the new company, Breachwood Motors Limited, as its sole purpose was to strip Breachwood Welwyn's assets and deprive Creasey of redress. The decision in Creasey was unequivocally overruled in Ord & Another v Belhaven Pubs Ltd [1998] by the Court of Appeal. Hobhouse L.J said: " Creasey v. Breachwood . represents a wrong adoption of the principle of piercing the corporate veil. Therefore, in my judgement the case of Creasey v. Breachwood should no longer be treated as authoritative". The Court of Appeal cited its previous decision in Adams v. Cape Industries plc [1990]9 where plaintiffs were not able to seek redress from a holding company when its subsidiary (the defendant) went into liquidation. The House of Lords have endorsed this stricter interpretation of Salomon more recently in Williams v. Natural Life Health Foods Ltd [1998]10. In that case a franchise company had already gone into liquidation by the time a misrepresentation was discovered. The plaintiff sought redress directly from the sole director of the former franchise company. Their Lordships held not only that the corporate veil was sacrosanct and should only be lifted in the most
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