Public Trust Doctrine: Indian Contours

Who owns the Earth and its resources? To what extent may the general public claim the pure water, clean air, rich soil, and the myriad services Earth provides to sustain human life? Across continents and spanning centuries, a dynamic tension continues between those who would circumscribe the Earth’s bounty for private use and those who would carefully allot Earth’s riches to satisfy human needs. Private property—sequestering Earth’s resources for personal, exclusive use—has its zealous advocates, and in many locales its legal status is unimpeachable, and its ideology is unquestioned.But a competing ideology, dating from antiquity[1], holds that some of Earth’s riches should never be sequestered for private use, must be left for the public’s enjoyment, and must be stewarded by those in power. Codified 1,500 years ago during the Roman Empire, legal scholars labeled this the â€Å"Public Trust Doctrine. † The Public Trust Doctrine perseveres as a value system and an ethic as its expression in law mutates and evolves. More recently, scholars, activists, and lawyers have begun discussing the rights of people to access and enjoy various essential resources and services the Earth so generously yields.The Public Trust Doctrine primarily rests on the principle that certain resources like air, sea, waters and the forests have such a great importance to the people as a whole that it would be wholly unjustified to make them a subject of private ownership. The said resources being a gift of nature should be made freely available to everyone irrespective of the status in life. The doctrine enjoins upon the Government to protect the resources for the enjoyment of the general public rather than to permit their use for private ownership or commercial purposes.Three types of restrictions on governmental authority are often thought to be imposed by the public trust: first, the property subject to the trust must not only be u sed for a public purpose, but it must be held available for use by the general public; second, the property may not be sold, even for a fair cash equivalent; and third, the property must be maintained for particular types of uses. I begin this article by tracing the historical origins of the Public Trust Doctrine, charting its (r)evolutionary leaps across centuries, legal regimes, and environmental entities.I then shift legal gears and analyze certain current environmental problems vis-à  -vis this Doctrine. I explore how the judicial creativity complements and expands the Public Trust Doctrine’s legal connotations, which, for 1,500 years, have constrained how Earth’s resources can be used and have guided who must bear responsibility for stewarding resources for the public good. Evolution of the doctrine Roman Law: 1,500 years ago, the Roman Emperor Justinian simplified the jumble of laws governing his Empire.He commissioned dozens of the era’s leading jurists, whose wisdom became codified in the Corpus Juris Civilis. [2] In 529, Justinian’s code contained a Section as: â€Å"By the law of nature these things are common to all mankind, the air, running water, the sea and consequently the shores of the sea. †[3] The Public Trust Doctrine, as this notion came to be known, suggests that certain resources—usually water, but now much more—are common, shared property of all citizens, stewarded in perpetuity by the State. 4] Several hundred years after the fall of the Roman Empire, a copy of the Corpus Juris Civilis was rediscovered in Pisa, and scholars spent centuries analyzing the tome. [5]In the peripatetic manner that has come to characterize it, the Public Trust Doctrine migrated with the Corpus Juris Civilis throughout Europe, to both civil law and common law regimes. [6] English Law: The Magna Carta codified Justinian’s words in England, and in 1225 King John was forced to revoke his cronies’ exc lusive fishing and hunting rights, because this violated the public’s right to access these common resources. 7] Thus in England, while the King had vested ownership of public lands, he stewarded them in trust for the public. This notion of government ownership of resources held in trust as a commons is a shared precept in all places where the Public Trust Doctrine persists. [8] Evolution in India: India has the roots of this doctrine in ancient Vedas when every king was to protect the trees and natural resources. But somehow it bore mere moral and religious obligations and lacked legal recognition. The PTD has been recognized as a part of law of the land in 1997 in the case of M.C. Mehta v. Kamal Nath. The evolution of the same has been discussed in the next Chapter. [9] An insight into Indian legal arena Article 21 of India’s constitution declares: â€Å"No person shall be deprived of his life or personal liberty except according to procedure established by law. â⠂¬ [10] Laws that conflict with or abridge fundamental rights named in the constitution are voided. [11] Citizens are allowed to challenge violations of these rights directly, and in fact citizen suits are the most rapid means to challenge actions that threaten fundamental rights. 12] In India, Judges have taken these substantive and procedural rights seriously and have buttressed them by establishing the Public Trust Doctrine to secure powerful protections for citizens’ Environmental Human Rights[13].While the constitution does not explicitly provide for Environmental Human Rights, Indian courts have gone further than almost any in naming environmental rights that serve the fundamental right to life. [14] The claims that impinge on Article 21’s fundamental right to life include various challenges where ecosystems have been impaired. 15] India’s Supreme Court stopped unauthorized mining causing environmental damage, holding that this â€Å"is a price that has to be paid for protecting and safeguarding the right of the people to live in a healthy environment with minimal disturbance of ecological balance. †[16] When a government agency action threatened a local fresh water source, the High Court of Kerala held that government â€Å"cannot be permitted to function in such a manner as to make inroads into the fundamental right under Art. 1. . . . The right to sweet water and the right to free air are attributes of the right to life, for these are the basic elements which sustain life itself. †[17] In a case upholding a statute that allows India to pursue justice following the Bhopal gas leak disaster, the Supreme Court further consolidated the link between Article 21’s right to life and the right to a clean environment. [18] In 1997, the landmark case of M.C. Mehta v. Kamal Nath[19] conjured up the Public Trust Doctrine in India. In that case, the Minister of the Environment (respondent) impermissibly allowed a motel to be built at the mouth of a river, and impermissibly allowed the motel to change the course of the river (which created subsequent flooding in nearby villages) in violation of the Public Trust Doctrine—which hadn’t explicitly existed before this case. 20]Before invoking the Public Trust Doctrine, the court alludes to: the classic struggle between those members of the public who would preserve our rivers, forests, parks and open lands in their pristine purity and those charged with administrative responsibilities who, under the pressures of the changing needs of an increasingly complex society, find it necessary to encroach to some extent upon open lands heretofore considered inviolate to change. 21] In this case, the court summons up the Public Trust Doctrine by first saying â€Å"The notion that the public has a right to expect certain lands and natural areas to retain their natural characteristic is finding its way into the law of the land. †[22] To justify thi s notion, the court cites excerpts from a Harvard Environmental Law Review article: â€Å"Human activity finds in the natural world its external limits.In short, the environment imposes constraints on our freedom; these constraints are not the product of value choices but of the scientific imperative of the environment’s limitations†[23] , promoting a new kind of natural law exigency for protecting environmental resources in the name of protecting fundamental human rights. [24] The court then revisited Justinian’s notion of the Public Trust Doctrine, including the exegesis of more than a half dozen seminal cases[25] of United States law that invoked and reinvigorated the Public Trust Doctrine. 26] The court concluded: â€Å"Our legal system—based on English common law —includes the public trust doctrine as part of its jurisprudence. The State is the trustee of all natural resources which are by nature meant for public use and enjoyment.Public at l arge is the beneficiary of the sea-shore, running waters, airs, forests and ecologically fragile lands. The State as a trustee is under a legal duty to protect the natural resources. These resources meant for public use cannot be converted into private ownership. 27] And thus the â€Å"aesthetic use and the pristine glory of the natural resources, the environment and the eco-systems of our country cannot be permitted to be eroded for private, commercial or any other use unless the courts find it necessary, in good faith, for the public goods and in public interest to encroach upon the said resources. †[28] The Supreme court for the first time recognized and declared, â€Å"the Public Trust Doctrine as discussed in this judgment is a part of the law of the land. †[29] In M. I. Builders Pvt. Ltd. v.Radhey Shyam Sahu[30], the Indian Supreme Court subsequently hitched the Public Trust Doctrine to the constitutionally guaranteed right to life. [31] The court held that a pub lic park and market are public trust resources that may not be replaced with a shopping complex. [32] Citing the precedent of M. C Mehta, the court reasserted that the Public Trust Doctrine is part of Indian law,[33] and thus ordered the appellant to restore the park that it had destroyed when it (and the government agency that permitted its actions) improperly violated the public trust. 34] The park in a crowded area is of â€Å"historical importance and environmental necessity. †[35] To allow the construction would mean that citizens â€Å"would be deprived of the quality of life to which they are entitled under the law. †[36]Because the government’s Development Authority was the trustee of the park, it had violated â€Å"the doctrine of public trust, which [is] applicable in India. †[37] The government authority was obliged to manage this park for the public good, and it â€Å"has deprived itself of its obligatory duties which cannot be permitted. [38 ] The court noted that â€Å"this public trust doctrine in our country, it would appear, has grown from Article 21 of the Constitution. †[39] The Public Trust Doctrine was invoked anew specifically to protect the fundamental human rights enshrined in the Constitution. Here, then, the Indian Supreme Court avers that the actions of the government and the private party appellant violated the right to life guaranteed in Article 21 of the Indian Constitution, and the government agency has committed these violations by violating PTD.Drawing on the Illinois Central[40] decision to explain Sax’s central tenet of the PTD[41], the court recited that â€Å"when a state holds a resource which is available for the free use of the general public, a court will look with considerable skepticism upon any governmental conduct which is calculated either to reallocate the resource to more restricted uses or to subject public uses to the self-interest of private parties. †[42] Subse quent litigation has affirmed the PTD’s relevance in Indian law.For example, the High Court of Jammu & Kashmir[43] allowed a manufacturing plant to be constructed, but only if the regional government observed its PTD duties to ensure that all possible pollution safeguards were implemented. A plant for filling cylinders with LPG was started after complying with the statutory requirements and clearance from PCB. When the residents objected the plant to continue and filed a writ of mandamus, the court after referring to Article 21, 47[44], 48-A[45], 51(A)(g)[46] and the post independence legislations invoked the doctrine of public trust and held that natural resources belong to people.The decision once again said that Article 21 of the constitution required that the government observe its public trust duties, for the â€Å"public has a right to expect certain lands and natural areas to retain their natural characteristics. †[47] The judgment also extended the scope of the Public Trust Doctrine, as â€Å"there can be no dispute that the State is under an obligation to see that forests, lakes and wildlife and environment are duly protected. [48] The Fomento Resorts Case (2009)[49]: Here, Fomento Resorts and Hotels Ltd had extended the construction of its hotel resort encroaching upon a public road and parking place which was a natural access to people visiting the Vainguinim beach. On a writ petition filed by a local residents, the Bombay High Court ordered demolition of the unauthorized structures following which the resort company preferred an appeal in the apex court.The apex court concurred with the view of the local residents that the unauthorized construction had put hindrances in their access to the beach. ‘Natural resources like beaches, forests, rivers and other water bodies are for uninterrupted and unhindered use of the general public and even the State cannot deprive them of their natural rights’, the Supreme Court held. Such rights are governed by the â€Å"public trust doctrine† and people can move the courts for enforcing the rights and directed Fomento resorts Goa to emolish its unauthorised construction on Vainguinim Beach, which had been overlooked by the state government. â€Å"The State cannot transfer public trust properties to a private party, if such a transfer interferes with the right of the public the court can invoke the public trust doctrine and take affirmative action for protecting the rights of the people to have access to light, air and water and also for protecting rivers, sea, tanks, trees forest and associated natural eco-system.The doctrine puts an implicit embargo on the right of the State to transfer public properties to private party if such transfer affects public interest, mandates affirmative State action for effective management of natural resources and empowers the citizen to question ineffective management thereof,† the apex court ruled. AN ANALYSIS OF THE JUDICIAL TRENDS The aforementioned decisions, however a major breakthrough, do not reveal whether the judges are saying this Doctrine has always been a part of Indian law, or whether it is a new provision.Mostly they seem to reiterate that United States law has always found the Doctrine to be part of its common law heritage as a British colony, and so should be done here as well. What is distinctively clear, however, is that the court felt the Public Trust Doctrine was necessary to bolster its demands on the government to advance constitutionally protected rights. It also appears that putting the Public Trust Doctrine in service of constitutionally guaranteed environmental rights puts not only new strictures on government, but also places new constraints on private property rights in India.Those constraints could be cast as a sextuple threat to Indian private property rights. First, the Indian Constitution mandates a fundamental right to life. Second, two decades and dozens of court cases interpret this constitutionally provided right to mean that environmental harms themselves are proscribed in order to serve the fundamental right to life. Third, to prohibit private acts that threaten environmental resources essential to safeguard the right to life, the Indian Supreme Court has repeatedly cited the â€Å"polluter pays principle and the precautionary principle† as emerging norms of international environmental law. 50] Fourth, the Public Trust Doctrine is asserted to buttress the government’s ineluctable responsibility to protect the right to life and the ancillary rights that serve the fundamental right.Fifth, private rights of action against private or government parties are permitted to vindicate the fundamental and corollary rights. Finally, the Indian Constitution requires an affirmative â€Å"fundamental duty† of every citizen of India â€Å"to protect and improve the natural environment including forests, lakes, rivers, wild life, a nd to have compassion for living creatures. [51] While a thorough examination of Indian private property rights is beyond the scope of this project, the combination of court-enshrined corollary environmental rights in service of fundamental right to life when accompanied with a decade-old reinvention of the Public Trust Doctrine means that whatever rights private property owners had before in India are now cast in a new, circumscribed way[52]. Contemporary Twists in the tale:Multi faceted Application of the doctrine National parks and national monuments harbor some of the most scenic areas in India. Each summer, motorists and tourist lineup to see the majesty of places like Kanha National Park , the holy shrines of Haridwar, Mankadevi, Rishikesh, Gangotri and Yamnotri and numerous Beaches and backwaters, gawking at wildlife and snapping photos to share. These public lands are also rich in natural resources like coal, oil, gas and timber.It is generally expected that Nation’s leadership would put these â€Å"public lands† wisely to use. Today, the conflict between protection of natural resources upholding the doctrine of public trust and the responsibility of state to manage national interests of industrialization and preservation of natural resources. Sometimes these conflicts are subtle, and sometimes the interests they represent are in direct opposition. This section discusses two case studies as a way to raise the issues.The first case the conflict is between traditional Native religious practitioners and commercial mountain climbing interests. The conflicts may seem more subtle as the policy makers see the mountain climbing â€Å"recreational† use that ought to be consistent with traditional native use since both depend, to some extent, upon the preservation of the mountain and its aesthetic qualities. However it is far too simplistic to assume that recreational use of public lands is consistent with â€Å"preservation† uses.Whi le environmentalists frequently deplore the idea that natural resources exploitation can achieve a friendly coexistence with â€Å"preservation† of these spectacular places, the current political and economic climate reflects the emphatic commitment to commercial exploitation of public lands. Native peoples’ longstanding interests in these public lands are frequently reduced to a religious attachment or, in policy terms, an interest in â€Å"sacred sites protection. All the policymakers overlook in the process that the native people have a unique relationship with their ancestral homelands, which are time and again encroached upon. Natives have legal, moral, political and cultural interests in their ancestral homelands, and these multiple and complex interests should not be described as purely religious in nature.The following case study addresses a compelling issue for contemporary policymakers: how do we protect the inherent rights of the people to the natural resou rces which are time and again endangered by industrial and commercial exploiters? 53] The story revolves around the tribes people of Kalahandi who oppose Vedanta[54]’s takeover of a region they hold in reverence. For the last one year, the Niyamgiri hills in Kalahandi district of southwestern Orissa have been reverberating with protests and demonstrations. The tribals of the area[55], who worship the hills as living gods—are taking on Vedanta, a UK-based mining major that has acquired a license from the government to exploit the abundant bauxite reserves in the pristine region.Conflicts between tribals and the state are nothing new—especially when they are portrayed as a struggle between the modern (read: progressive governments and corporates) and the primitive (read: tribals). Vedanta, in partnership with the state-owned Orissa Mining Corporation, promises to put India on the global map as undisputed leader in production of iron ore, aluminium and zinc. But th e tribals are asking if this should be at the cost of destroying their habitat, with which, in their animist traditions, they engage in a sacred covenant.And environment activists ask if there can ever be another Niyamgiri once the mining starts. A visit there is a trip to paradise—lush greenery, scores of streams crisscrossing the mountains, rich soil, an abundance of wildlife. In fact much of the region is protected under Section 18 of the Indian Wildlife Act, and the Orissa government had declared it an elephant reserve as recently as 2004. But once the mining begins, the ecosystem will be lost. The pollution and degradagion and degeneration has begun. The earlier warnings were all ignored.The first had come from the central empowered committee in 2002, constituted under the EPA[56]. The committee observed: â€Å"Had a proper study been conducted before embarking on a project of this nature and magnitude involving massive investment, the objections to the project from the environmental/ecological/forest angle would have become known in the beginning itself and in all probability the project would have been abandoned. † The second came from WII in 2006. Its status report said, â€Å"Mining could trigger irreversible changes in the ecological characteristics of the area.The cost-benefit value should not only take into account the material benefits of bauxite mining†¦ (but also) the perpetuity of the resources and ecosystem services that would be provided by these forests in the future. Compromising long-term economic returns, therefore, cannot be an alternative for short-term gains. † The apex court, however, ruled in 2008 that the company was free to mine after it complies with the due process of law. Today the public trust doctrine serves an important role in adjudicating tribal rights and state responsibilities. 57] Modern case laws have defined contours of State responsibility and highlighted it’s application towards prote ction of the interests of â€Å"We, the People. †Skeptics may say the process could allow Vedanta scope for intervention, but the tribal activists are steadfast in their resolve. â€Å"We’re not against development,† they say, â€Å"But the state must recognize the rights of tribal communities that have lived here for ages. † Critical analysis Is the public trust doctrine a threat to private property? Is it a vital, evolving common law doctrine? Or a metastasizing source of governmental uthority over private land? These are certain inevitable questions to be raised by the critics of the said Doctrine. Analysing the Doctrine, it can be said that it serves two purposes: it mandates affirmative state action for effective management of resources and empowers citizens to question ineffective management of natural resources. The Public Trust Doctrine can be used as leverage during policy deliberations and public scoping sessions and hearings. This forces agenci es to prove that their actions are not environmentally harmful to the extent that they will destroy a public resource.If the agencies fail to provide a more environmentally benign alternative, then you can bring up a Public Trust lawsuit. Although the court process may be long and arduous, many important precedents have been established. It is interesting to note that in the Kamal Nath case[58] the Supreme Court held that even if there is a separate and a specific law to deal with the issue before the Court, it may still apply public trust doctrine. If there is no suitable legislation to preserve the natural resources, the public authorities should take advantage of this doctrine in addition to the fact that there was a branch of municipal law.Secondly the Supreme Court in M. I. builders[59], however, stated that public trust doctrine has grown from Article 21 of the constitution. By attaching this doctrine to the fundamental right to life, the Supreme Court appears to be willing to diversify the application of this doctrine. It seems likely that the court would give precedence to right to life when the public trust doctrine, as a part of right to a safe and healthy environment, is challenged by any other fundamental rights.Thirdly by ordering the Mahapalika to restore the park to its original beauty, the Supreme Court redefined the duties of a trustee to its beneficiaries the users of the park. In effect, it aligned the local authorities duty as a trustee with the concept of intra-generational and inter-generational equity. Fourthly, the case came before the court as a judicial review and not as challenge against the decision of the government from a beneficiary. As this doctrine acts as a check upon administrative action by providing a mechanism for judicial or resource allocation decisions.Therefore, public trust doctrine could serve as an additional tool for environmental protection particularly where administrative discretion has been abused. IMPORTANCE O F PUBLIC PARTICIPATION FOR PROPER IMPLEMENTATION OF PTD Public participation is a necessary component of vibrant, dynamic, functioning and participatory democracy. It has potential to make all governmental decision making transparent, rational just, fair and responsive as a good governance practice which entails effective participation in public policy making provisions of the rule of law.Public participation also serves as a useful device to make government and its agencies accountable and at the conceptual level public participation is inextricably linked with democracy, decentralization, self-administration, self-management and respect for human rights and fundamental freedoms. The idea of public participation has also entered the arena of environmental protection and its recognition as an important part of environmental decision making is discernible at all levels of government. 60]The contribution of public participation in environmental decision-making to the substantive quali ty of decisions was given a significant boost with the entry into force of the Aarhus Convention[61] adopted through the United Nations Economic Commission for Europe. The Convention stresses that public participation in environmental decision-making contributes to â€Å"the protection of the right of every person of present and future generations to live in an environment adequate to his or her health and well-being. † NEED FOR PROPER FRAMEWORKOF LAWS IMPLEMENTING THE DOCTINEThe public trust doctrine could provide a practical legal framework for restructuring the way the oceans are regulated and managed. It would support ocean-based commerce while protecting marine species and habitats. The public trust doctrine is â€Å"a simple but powerful legal concept,† that obliges governments to manage certain natural resources in the best interests of their citizens, without sacrificing the needs of future generations. Extending the public trust doctrine to ocean waters would help State agencies better manage conflicting demands such as conservation, offshore energy development, fisheries and shipping in the 3. million nautical square miles of water included in the nation's territorial sea and EEZ.Currently dozens of laws, regulate species and activities in these waters, without any mandated, systematic effort to coordinate their actions for the public good. Though the public trust doctrine is well suited to serve as a critical legal foundation for a coordinated, ecosystem-based ocean policy, it has not yet been formally articulated by the executive branch, nor has it been recognized by courts or expressly established in statutory law.As we contemplate managing our ocean resources, not only for today but for future generations, we need to ask ourselves two critical questions: For whom should the country's oceans be managed? And for what purpose? The public trust doctrine answers both of these questions. International Scenario It is a common law concept, defined and addressed by academics in the United States and the United Kingdom. Various common properties; including rivers, the seashore, and the air, are held by the government in trusteeship for the uninterrupted use of the public.The sovereign could not, therefore, transfer public trust properties to a private party if the grant would interfere with the public interest. The public trust has been widely used and scrutinized in the United States (The Mono Lake case being the breakthrough)[62], but its scope is still uncertain. Various have been made to apply this doctrine to protect navigable and non-navigable waters, public land sand parks, and to apply it to both public and private lands and ecological resources.The Supreme Court of California has broadened the definition of public trust by including ecological and aesthetic considerations. Although the public trusts doctrine is not without its fair share of criticism it is being increasingly related to sustainable development, the precautionary principle and bio-diversity protection. The doctrine combines the guarantee of public access to public trust resources with a requirement of public accountability in respect of decision-making regarding such resources.Moreover, not only can it be used to protect the public from poor application of planning law or environmental impact assessment, it also has an intergenerational dimension. The Stockholm Declaration of United Nations on Human Environment evidences this seminal proposition: â€Å"The natural resources of the earth, including the air, water, land, flora and fauna and especially representative samples of natural system, must be safeguarded for the benefit of present and future generations through careful planning or management, as appropriate†¦ Conclusion Om vanaspataye Shanti Bhavantu[63] The Rishis of Aryavrata, the great thinkers of the ancient period pronounced above in the Vedas in no uncertain terms. However, we have sadly forgotten this pre cept except uttering the words occasionally while conducting havan to propitiate Gods and Nature without understanding the implication of this Mantra.In recent years these life supporting systems are gradually declining through the capricious exploitation of earth’s resources by the ever expanding human population in order to meet its growing material needs in the name of modernization and development and so does our relationship with natural resources continues to deteriorate till nature’s resources are exploited and utilized in a more rational & economical way to maintain a sustainable development. Environment is common heritage for all.Obviously, conservation and development can and must go hand in hand unrevealing and understanding the complexities of various eco-systems with a changing attitude of â€Å"touch-me-not† to â€Å"use me wisely†. It is evident that the state is not the owner of the natural resources in the country but a trustee who holds fiduciary relationship with the people. By accepting this task the government is expected to be loyal to the interests of its citizens and to discharge its duty with the interest of the citizens at heart and involve them in decision-making process concerning the management of natural resources in the country.The Public Trust Doctrine may provide the means for increasing the effectiveness of environmental impact assessment laws. The Public Trust Doctrine stands for the proposition that some of nature’s gifts inherently belong to all people, and the government must steward these to prevent both private arrogation of public resources and the â€Å"tragedy of the commons† from unfettered public access to these shared resources. [64] Environmental Human Rights represent a growing movement to codify this belief, to make positive law that firms up the philosophy promulgated for 1,500 or so years in the name of the Public Trust Doctrine.In addition, the Public Trust Doctrine h as expanded its reach to cover more of the Earth as the interrelatedness of ecosystem processes becomes more defined, and the success of the strategy in protecting those processes becomes more apparent. The Public Trust Doctrine encourages government officials to fulfill their stewardship duties. Judicial vigilance creates obligations erga omnes, i. e. , duties that must be performed. The Public Trust Doctrine urges judges to take a hard, skeptical look when government action appears to allow private interest to impede public trust environmental resources.The Public Trust Doctrine naturally shrinks what constitutes private property rights (and moves us to reconsider them as â€Å"private† â€Å"property† â€Å"rights†), either because certain resources never actually were subject to private usurpation, or never should have been. The Public Trust Doctrine has always reflected a value preference for public over private access to environmental assets. Invoking envi ronmental rights as human rights amplifies the public’s right, now and in the future, to share in ecological gifts fundamental to human health and wellbeing.

King’s attitude towards slavery Essay

Reconciliation struck King as divinely just, and he recommended the same practice for the United States. He suggested that this was the only moral and practical way to bring the Negro’s stand-ups to a realistic level. Reconciliation in the form of compensation was such a good idea in King’s mind because the practice would support the freedom of the human personality and lead to a just society. He also believed that it would make freedom real and substantial for the black people. He never believed that the mere absence of desegregated public accommodations would fully free the human personality and establish a just society. Although many whites were against him, he began to emphasize his belief that real and substantial freedom as well as the mandates of the just society, require not desegregated public facilities but also the economic goods that would allow blacks to use such facilities. King equated freeing the blacks and leaving them just like that to giving a pair of shoes to a man who has not learned to walk. His point was that freedom from desegregation requires the material goods to enjoy freedom from integration. King’s own response to the Johnson administration was to post for state atonement for the Disadvantaged. In King’s view, just as the state properly compensated World War II veterans for the time they spent away from their home, jobs, so too should it compensate blacks for their years of enslavement. He argued that only a few people considered the fact that in addition to being enslaved for two centuries, the Negro was during all those years, robbed of wages of his toil. He believed that no amount of gold could provide adequate compensation for the psychological turmoil caused by slavery, but that a price could be placed upon unpaid wages. King’s extra marital affairs It is clear that King did a lot of good deeds, most of which were based on pure ethical standards. However, there are some ethical challenges that were hard for him, and the most common is the sexual relationships with many women. Two years after King married his wife Coretta, he began his work in the civil rights movement. He left his young wife and baby to pursue endeavors that would take him far from home, putting aside his wife, and while he was home, he spent a lot of time on the phone. His friends who were worried of what these extramarital affairs would do to his reputation cautioned him about the importance of avoiding the appearance of wrongdoing. They also cautioned him that due to his prominence, he would become the target of those seeking to discredit him. He was also warmed that women could become his downfall if he failed to resist this temptation. King failed to take these warnings. By the time he won the Nobel Peace Price of 1964, his relations with women outside his marriage were far from secret. Wiley Branton, a close associate of King approached him about the subject when he was unable to ignore the rumors. He told king that colleagues had expressed concern over his behavior and were worried that he was going to get hurt, but King was unresponsive. The topic again came up with another friend, and this time King responded that because he was away from home the majority of each month, sex served as a way to reduce his anxiety. King’s attitude towards money While king had a hard time resisting sexual temptation, the temptation to profit from his fame was by no means a temptation for him. He had never bee influenced by the prospect of making money. In fact, while in college he had developed an opposition to his father’s concern with money. His lack of desire for material possessions increased after he visited India. Even his wife sensed a change in him. She said that this growing selflessness had led to his increasingly dismissive attitude toward his clothing and appearance, which up until then he had taken pride in. Since his college years at the Morehouse, King had enjoyed nice clothing. His selflessness also affected the financial status of SCLC. When he won the Nobel Peace Prize, he donated the price money to the group, despite the objection of his wife. She wanted to put some of the money aside for college for their children, but King insisted that the money go in full to the SCLC. Later, when two board members suggested that he accept a salary from the organization, King declined the offer. He explained that his income from Ebenezer Baptist church and the sum that he kept from speaking and writing was enough to support his family. Conclusion Due to King’s legacy as a man of good man, his shadow persisted even after his assassination. The poor people’s campaign initially was identified with the martyred prophet, not with his successor. The goals King established, especially for the campaign of equality among the whites and the blacks were probably unreachable, but King-the-symbol remained untarnished by failure. In addition to the charisma of his leadership, King had clear strategies for achieving goals. He believed that besides the use of legal tactics, the federal government was a necessary ally. King believed that because of man’s sinfulness, a restraining force was needed. According to him, it was the government that could counteract collective evil. His ultimate goal in many of his campaigns was to force the federal government to act. Time after time, his strategy worked. From the term paper, it is clear that his leadership was two fold. He was able to mobilize blacks, while at the same time appealing to the consciousness of the whites. King’s influence was as a result of several factors. To African Americans, his background was rooted in the black community, he was a Baptist preacher, and his academic training combined with religious faith provided the leadership skills he needed. To white Americans, he was an African American with the extraordinary ability to convince them of the evil of segregation. His words carried a powerful punch that, while what he was saying about segregation was not new, he stirred a moral awakening. Cementing his position was his leadership through nonviolent resistance, which appealed to decency and the commonality of humanity that, until then, had been ignored. Reference 1) Long M. G. (2002). Against us, but for us: Martin Luther King, Jr. and the state. California; Mercer University Press

Roman Catholic Communion Essay Example | Topics and Well Written Essays - 1250 words

Roman Catholic Communion - Essay Example Hence, when it comes to rituals, Communion tends to be an important ritual in the Roman Catholic religion. Communion in the Roman Catholic religion not only extends a sense of belonging to the Roman Catholics around the world, but also helps them stay connected with the essential beliefs and values associated with their religion. In the Roman Catholic Church, communion tends to be the source and centre of the Roman Catholic religion. Communion tends to be the high point of any Roman Catholic mass. In the Roman Catholic Church, communion happens to be an important sacrament. It is a way and means to reach Jesus. The Ritual of Communion The communion in the Roman Catholic Church begins with an opening prayer. The clergy conducting the mass makes a sign of cross and says the opening prayer. The clergy formally welcomes the believers attending the mass and offers prayers for the well being of the parish and the community. After the opening prayer, the clergy starts the reading of the scr ipture. It does need to be mentioned that the reading of the scripture in a Catholic communion is not random or haphazard, but rather it follows a liturgical calendar. The Catholic Church has prescribed the readings for each and every day of the year. This practice of affiliating to the same reading on a particular day at the Catholic Churches placed all across the world, lends a sense of community and camaraderie to the people following the Catholic religion. The reading of the scripture is followed by the Lord’s Prayer. Once the Lord’s Prayer is said then begins the sacrament of communion. The priest offers to the believers gathered in the Church for the mass, the bead dipped in wine, which at a symbolic level is taken to be the blood and body of Jesus, offered to the believers so that it could atone for the sins committed by them (O’Collins & Farrugia 250). It does need to be mentioned that communion tends to be the most important aspect of a Catholic mass. T he Roman Catholic religion preaches that receiving communion is a must for the attainment of salvation. The other important belief associated with the Roman Catholic communion is that only a priest, who has been ordained in the apostolic succession, could manifest through Jesus Christ the imminent miracle of Transubstantiation, thereby changing the ordinary bread and wine into the blood and body of the Christ. Meaning and Significance of Communion It does need to be noticed that Communion or Eucharist commands a central place in the Roman Catholic form of worship. Baptism and Communion are the two sacraments that have been clearly mentioned in the Bible. It is held that the practice of Communion was actually started by Jesus Christ, and this ritual is clearly recorded in the Gospels. It was Jesus Christ who initiated the practice of the Last Supper where he offered bread to His disciples, telling them that it is His body, and then made them drink a little wine, saying it to be His b lood. Jesus told his followers to repeat this ceremony and the Catholic Christians have been practising this ritual right from the days of early Christians. The ritual of Communion owes its spiritual moorings to the sacraments relation to the actual sacrifice of Jesus on the cross. In the New Testament one many a times come across Jesus addressing himself as a sacrifice, thereby pointing towards his imminent sacrifice on

Divorce from Different Perspectives Essay Example | Topics and Well Written Essays - 3000 words

Divorce from Different Perspectives - Essay Example This paper will provide a platform for the analysis of the topic of divorce by first understanding their rationale on the subject. Some of the major contributors to the increased divorce cases will be identified and will finally conclude by establishing some of the ways the different parties propose for tackling this problem. According to Browning, the major causes of the change in family patterns such as increased divorce rates are modernization and globalization. This further raises a vital question such as should the changes be embraced and seen as the norm? The other important question that arises is what are the changes indicative of dynamism in family life or are they part of a wider problem or crisis? Browning notes that since the 1980’s there has been a significant change in the worldwide perception of family changes such as divorce. Studies conducted by sociologists, psychologists and economists point to these changes as to having detrimental effects on most people. D ivorce has been found to bring about immense emotional, social and financial consequences. Changes in the family patterns caused by practices such as divorce have been linked to declining well-being of children who are involved in the process. Studies into the effects of divorce have pointed out that children from families where divorce has happened have a high rate of delinquency. They were also found to exhibit low self-confidence and faced a higher risk of leading unhappy marriages in the future. It is critical to understand that each branch of Christianity views divorce in its different way. Since its commencement over two thousand years ago, the Catholic Church has maintained its stand on the indissolubility of marriage. The church holds a conservative view on the dissolution of a marriage. According to the Catholic Church teachings, marriage is a covenant not only between two consenting adults but also between the parties and God.  

Career plan Essay Example | Topics and Well Written Essays - 1750 words

Career plan - Essay Example The selection of which career path to pursue should be informed by a number of things. Firstly, I should select a profession that I am passionate about. The statement explains why I am not keen on pursuing an accountancy route. Although they command a lot of respect in the society, accountants do routine work that does not appeal to my desire for constant improvement. However, I appreciate that the advice follow your passion is overrated. Human beings have the capacity to develop interest in the activities that they are engaged in. Second, the level of compensation. The high cost of living makes it a necessity to find a profession that will enable me to pay off my student loans. In addition, it should provide an opportunity for realizing economic and social mobility. My interest in finance can be attributed to my belief that money can be a force for good if it is managed properly. The finite resource plays a significant role in determining the ability of people to have access to opportunities for economic and social mobility. There is a popular saying that money causes all the evils in the world. In contrast, I believe that the inability to manage the money appropriately causes a lot of misery in personal lives. On a larger scale, the mismanagement of corporate and public funds can lead to the collapse of businesses and the loss of jobs. As a result, the critical profession is important in ensuring that the society achieves economic and social progress. The first career option that I shall focus on is banking. The banking industry plays a significant role in the international economy. The 2008 global recession was caused by the collapse of a few banks. As a result, it is evident that banks support the global economy. The industry involves a lot of pressure to deliver good performance. The pressure is rewarded with a generous compensation package that is determined by the performance of the individuals. The payment structure is appealing

Toyota Production System Article Example | Topics and Well Written Essays - 750 words

Toyota Production System - Article Example In a company that produces iron sheets, just in time can be applied by placing orders for raw material such that the materials ordered for arrive at the company in the right quantity just when it is needed and without any delays. Muda refers to waste or anything that adds no value to the system. Muda exists in the form of motion, correction, processing, waiting time, conveyance, overproduction, and inventory. In a company that manufactures iron sheet, one example of muda is raw material that has been established to be substandard in quality and therefore needs to be reworked. Yokoten implies horizontal deployment; good practices and results in one area or organization are copied or applied to other areas or organizations. One franchise of Coca Cola company can decide to send a team of its employees to a more efficient franchise in a different country so that the team observes and learns how things are done to ensure high efficiency and productivity. The team will learn and implement what they have learnt doing what they can to improve on the ideas in their organization. Pokayoke involves the use of fool proof devices during production. Through the use of fool proof devices, the production of defective parts that result from human error is minimized or altogether eliminated. In a manufacturing plant, the buttons in the control panel of a machine can be color coded and associated with drawings that show what the buttons make the machines do. This way, even an untrained operator has less chances of pressing the wrong button that may lead to the production of faulty parts. Hoshin involves capturing and cementing strategic goals as developed by executive managers so that they are realized eventually. The organization’s level of performances is set to improve with the passage of time as the strategic goals are realized. In a soda manufacturing company, top management may develop strategic goals relating to the production of a given quantity of soda crates.

ILLEGAL LOGGING & DISASTERS IN THE PHILIPPINES Essay

ILLEGAL LOGGING & DISASTERS IN THE PHILIPPINES - Essay Example Humility and poverty are focused by Franciscan spirituality due to several reasons. They provide the means for understanding the real purpose of existence. Excessive material wealth leads to avarice, greed, and hatred which can cause the destruction of humanity. Thus the notion of believing in Christ helps an individual to contemplate about the Crucifixion and Resurrection. It helps the individual to recognize the unique creation of humanity that is entrusted with the task of creating a just and humane society. The Philippines is a great nation with a talented and productive workforce. It has natural resources that are being threatened by unscrupulous individuals who desire greed and profit. Illegal logging poses a serious threat to indigenous people and local habitats. It has the potential of creating natural disasters that increase misery and oppression. The goal of this paper is to apply Franciscan spiritual principles in the context of illegal logging and natural disasters in the country. It seeks to develop a collective response by focusing on the major principles of spirituality. Background Franciscan spirituality is based upon the notion of living a life that is filled with humility and poverty. It encourages the development of spirituality as the means to attaining eternal grace and union with God3. It embraces the notion of living as Christ because he is the symbol of divinity and humanity. His crucifixion enables the believer to contemplate about the changing environment. It creates an environment where success can be attained by recognizing the value of human life4. Spirituality means the application of moral principles that enable a human to live in harmony and balance with the external environment. Every action of humans must be Christian centric because ultimately it will be the criteria for success. The Philippines is a beautiful country with a hardworking and talented people5. It has numerous resources like natural habitats and environmental won ders. All of these resources are under threat from unscrupulous individuals who seek to destroy them for their own purposes. Illegal logging and natural disasters pose a threat to the integrity of the country. It is contrary to the natural values that embrace the notion of solidarity, peace, and harmony with the external environment. Franciscan spirituality advocates love for all human beings irrespective of their differences6. It embraces the notion of poverty as a means of fulfilling the covenant of Christ. It believes in the absolute supremacy of poverty because richness is really found in the spiritual domain. Application of Franciscan Spirituality Franciscan spirituality is derived from the Christian notion of perfection and sanctity because the believer is encouraged to achieve the ultimate dream of eternal union with the divine entity7. Hence it advocates the development of a spiritual framework that seeks to exert the believer to perform righteous actions to the utmost in or der to achieve sainthood. The Filipino people value the importance of sustainable living with the surrounding environment. This is because the natural environment provides food, shelter, growth, and sustenance. Hence it must be respected according to their natural values and norms. A recurrent theme of Franciscan spirituality is the emphasis towards modesty and destitution8. This is because materialistic possessions tend to create greed and avarice among

Central Financial Management Activities Essay Example | Topics and Well Written Essays - 1250 words

Central Financial Management Activities - Essay Example It is not uncommon for an organization to employ its directors and/or its chairperson when it comes to judgment in the financial management process. Judgment must be borne on issues of strategy, performance, and resources, including key appointments and standards of conduct. Organizations may also employ non-executive directors for the judicial process, as an independent judgment that is free from bias is superior (Mcmenamin 1999). It is the task of the judgment personnel to evaluate what has taken place in relation to how the financial picture of an organization can be improved. The judges in the financial management process have the capacity to do away with certain decisions and thereby begin a new financial year with better prospects. Most Fortune 500-size firms use sophisticated mathematical and statistically-based methods in the financial management of inventory. A firm’s financial managers concentrate on the allocation and efficient management of financial resources in various inventory categories, for example, raw materials, work-in-progress, and finished goods. A firm’s production and inventory managers, on the other hand, are more interested in the efficient production of different finished goods items, and therefore pay close attention to employee production schedules, long production runs, and the storage of finished goods. It is not infrequent for a conflict of interest to arise between these two branches of management. The top management must intervene in this case to determine the proper investment of financial resources in the production function. Now a great deal of analysis enters the picture. For this, all firms must have data necessary to make precise calculations of cost-convenience -profit trade-offs (Grablowsky 1984).

E-books in relation to technology, science, and their impact on Research Paper

E-books in relation to technology, science, and their impact on society. Where will they be in 2060 - Research Paper Example According to a research study by Lyman and Hal in 2002, more than 93 percent of completely new information is being produced in digital format (as cited in Lee, Guttenberg, McCrary, 2002, p.227). In recent times, digital publishing has reached critical mass. Media coverage and future books fair reporting has made the consumer well-aware of eBooks and ereaders. Apple’s iPad cum ereader has changes the way ereaedrs are perceived. Ebooks market is in transition, it is evolving and restructuring itself for better (PwC,n.d.,pp.2-4).While suggesting the future of eBooks in 2060 based on research evidence, the paper briefly studies the EBooks’ impact on our society, technology, and science. 1. EBooks and Technology With the accelerated production of digital content, user interest is increasing in devices that are specifically designed to read electronic content (eBooks) such as, e-readers, PPCs, Smartphone, and tablets. From many aspects, eBooks are far more efficient than tra ditional paper books (pbooks), such as: storage, transfer, accessibility, and delivery. Due to compressing ability, storage devices for eBooks are much smaller in size as compared to pbooks. Unlike pbooks, eBooks allow readers to introduce multimedia and hypertext links into books. For instance, eBooks facilitates the readers experience by video clips, audio or sound narrations. Reader can easily jump to a location on Web through a simple click (Lee, Guttenberg, McCrary, 2002, p.227). With the arrival of Amazon Kindle and Apple’s iPad, e-reader technology has taken off. EBook readers are increasingly becoming part of our everyday life, readers are going to experience much more of e-readers and their competitors, such as, tablet computers in future libraries(Rotman Epps & McQuivey as cited in Aaltonen, Mannonen, Nieminen, & Nieminen,2011,p.16). 2. E-books and Society Accessibility is another major feature that can easily overcome pbooks in future. Online libraries provide valu able information in their public domains eBooks, for instance, netLibrary, Internet Public Library, and Project Gutenberg. EBooks provide people with a chance to access wealth of information just by having an internet connection. Despite all the convenience, eBooks may not completely take over pbooks. However, there is considerable number of predictions for the success of eBooks. Considering the limitation of eBooks, such as, slow acceptance of the innovation, user unwillingness to read from screen(Lee, Nicholas, & Victor, 2002, p.228) lacking display quality, cost, durability, and ease(Sottong as cited in Lee, Â  Guttenberg, McCrary, 2002, p.228) it can be inferred that eBooks are going to co-exist with pbooks in recent future. EBooks have great potential for providing enhanced learning opportunities for better engagement and control over content and activities. Quick access and portability is the feature that facilitate remote learning and save travel time and energy (Hernon et a l., as cited in Lam, Lam,& McNaught,2010,p.8).EBooks have potential to enhance the learning experience by improved relationship between student and educator while dealing with learning materials(Shiratuddin, Landoni, Gibb,& Hassan,2003).According to Robert, Slattery and Kardos, text-to-speech or Braille output programs are likely to increase information

Essay (see instruction) Example | Topics and Well Written Essays - 250 words

(see instruction) - Essay Example Therefore, there has been a constant reduction of tourists who opt for regions with low tariffs. Consequently, there is a need to set low tariffs (Hall, Smith, & Marciszewska, 2006). Second, insecurity is a major challenge affecting tourism. Unfortunately, many countries have done less about solving the problem. Consequently, this has led different nations to imposing sanctions as a way of protecting their citizens. Therefore, this has led many tourism countries to face economic losses. As a solution, governments need to invest more on security, and set up policies that would protect tourists (Okoth & Ndaloh, 2010). Third, political instability has continuously been a challenge to the tourism sector. Thus, it has subjected tourists to difficult political situations. For instance, despite claims by government that they support tourism, visa allocation has been limited. These among many others hinder tourism. Therefore, through proper leadership political stability is attainable (Some of the Major Current Issues Confronting Tourism, 2006). Hall, R. D., Smith, K. M., & Marciszewska, B. (2006). The Challenges and Opportunities of EU Enlargement. In R. D. Hall, K. M. Smith, & B. Marciszewska, Tourism in the New Europe (pp. 247-250). New York:

Steve Jobs Leadership at Apple Essay Example for Free

Steve Jobs Leadership at Apple Essay The organization Apple Inc. has a flat hierarchy with six levels. This makes it possible for the CEO and the Board of Directors to have a larger overview of the company. The departments at Apple Inc. are functionally grouped. Some (e.g. Global Communication) are then grouped geographically. The organization is divided into specialized departments or teams, who all report to a team leader. All team leaders then meet with the CEO to discuss matters. Within theses teams are people who the CEO trusts to do their part. This means the CEO has a quite narrow span of control, as he does not have the responsibility for all departments, but he has selective influence on them. On a daily basis, Jobs had direct contact with about 50 people, out of the about 10.000 working at Apple Inc. For the organization to run as smoothly as possible, Jobs let those of a higher status (â€Å"A-players†) have a lower formalization, as he feared that if he did not let these very qualified people do their job, they would leave the company. Those of a lower status have higher formalization, as Steve has little trust in them. At the same time, it can be said that the organization has a centralized structure, as for instance, no product is ever released without it being approved by the CEO. In many situations though, decisions have to be made without his approval. A reason for this can be found in the wise words â€Å"No brain can effectively control more than 6-7 other brains† (General Sir Iain Hamilton) Who is Steve Jobs as a Leader? It is interesting to discuss whether Steve Jobs can be defined as a leader, or if he is in fact â€Å"just† a manager. Leaders can be said to be visionaries who drive new initiatives, which makes them likely to take risks. They seek to create positive or dramatic change. Managers on the other hand seek to achieve stability and predictability. It cannot be denied that Jobs has never hesitated to take a risk with his ideas and products, which would therefore make him a leader. â€Å"Managers do things right, leaders do the right thing† is another perception of the two terms. With undeniable success, Jobs has definitely done things right, which would make him a manager. Of course, there has been failure on his road to success, but if we take the firing from Apple (1998) as an example, his comeback only made him seem even more important in his role as CEO of the company. It is difficult to define him as one or the other. According to Mintzberg, management and leadership overlap. However, although most CEO’s must be a manager, not all posses the traits of a leader. The leadership ability to inspire is not easily acquired, and it was perhaps this trait, which made him not only a manager, but also an exceptional leader. Besides his inspirational qualities, there are other personality traits that define him as a leader. Through his commencement speech at the Stanford University graduation, he made use of his great rhetorical skills and charisma. According to Cannel (2008) typical traits of good leaders include ability to inspire and listening, sharing and delegating skills, and these boxes can therefore be checked off. In addition to this, an appealing trait is technical or professional knowledge and competence in a particular field. Jobs had an ability to connect art and technology, which led to e.g. the iPod. Taking the traits above into consideration, Jobs can be defined as what we call a Transformational leader, which is a term in new leadership. A such leader is typically charismatic, inspiring and motivates others to perform â€Å"beyond their contract†. According to Tichy and Devanna (1986) Transformational leaders have three main roles: Recognizing the need for revitalization Creating a new vision Institutionalizing change Jobs fulfils all three roles, as he had the ability to figure out what customers wanted, before they knew they wanted it. The creation of the iPod was on of the first examples of this. The iPhone and iPad kept Apple competitive on the market. Jobs has always been very involved in these inventions and has always aimed for the highest possible standards in his products. His way of incorporating art into technology, is what made the products of Apple unique and competitive. Examples of new ideas are the white iPods, Macs etc. and touch-screens. Even though other brands have attempted to use the same, it has now become a part of the Apple brand. The concept of New Transformational Superleader combines the ultimate traits of a leader in the 20th century. Such leaders must be in possession of specific traits, style-counselling and a context-fitting leadership. In the first category is appearance. In relation to this, it is interesting to notice that Steve Jobs always dresses in a black turtleneck, round glasses, jeans and sneakers. This characteristic outfit has become a symbol of his personality as it reflects his characteristic style. (Steve Jobs, p. 411 Walter Isaacson 2011) In the style-counselling category we again find that inspirational and visionary qualities together with risk-taking is valued. In an interview with ABC news, his former partner Steve Wozniak explained how Jobs was never afraid to take a chance on what he believed in, and he deliberates on the meaning of Jobs’ quote in the Stanford university commencement speech â€Å"Stay hungry, stay foolish†: â€Å"Like his other words (†¦) â€Å"follow your dreams, follow your internal passion, what’s in your heart, believe in yourself even when a lot of people are saying â€Å"No, this is not right, it’s not going to be worth anything, it’s not going to go anywhere, you’re off the right track,† and that’s very important.† Last we find the context-fitting category. Jobs is a very situational leader. As the world changes the products need to change too. An example of his context-fitting style was the personalization of the computer or the invention of the iPod. He did not invent these, but his creations so fundamentally changed the market, he might as well have. Today, many people do not have mp3 players, they have iPods, and so he created a whole new concept for a whole new time. Again, Jobs’ way of seeing what people wanted before they knew they wanted it, paved the way for great success on a new market. Later on, as the iPod almost became a necessity, and smartphones became popular, Jobs again fitted his products with the situation and found a way to combine the iPod, the computer (Mac/iOS) and the smartphone into one – the iPhone. The future of Apple Inc. The death of Steve Jobs had great impact on the organization of Apple. Having identified what made him so successful as a leader, it has become obvious that the new CEO has much to live up to. The stocks of Apple fell the day Jobs died, which provokes the idea that people connect Jobs’ death with Apple Inc.’s failure. (See attachment 1) It has come to show that people have dreaded what will now happen to Apple. There is a fear that Cook lacks the creativity and innovativeness that Jobs possessed. When the iPhone 4s came out instead of an iPhone 5, it cannot be denied that many were disappointed. Even though Jobs was in on the development of the 4s, it was Cook who presented it to the world, and so many have linked this ‘lack of renewal’ with Cook. Cook has yet to prove to Apple customers that he too has the required skills to be as successful as Jobs. Even though people may have doubts about Jobs’ successor, he has in fact done a lot to make Cook as capable as himself: Weve got really capable people at Apple. I made Tim [Cook] COO and gave him the Mac division and hes done brilliantly. I mean, some people say, Oh, God, if [Jobs] got run over by a bus, Apple would be in trouble. And, you know, I think it wouldnt be a party, but there are really capable people at Apple. And the board would have some good choices about who to pick as CEO. My job is to make the whole executive team good enough to be successors, so thats what I try to do. Tim Cook may be a capable CEO, but he has yet to prove his creative skills. He was a perfectionist and may have had more passion for his products than Cook has. A great leader should always leave behind a company, which is independent of them, and will flourish without them. When Jobs was fired in 1985 the company proved to be dependent on him, and it most likely would have gone bankrupt, had he not been rehired. The last time Jobs ‘left Apple’ it all went downhill†¦ will it happen again? Conclusion In conclusion, the organization of Apple has a flat structure, which gives the CEO a possibility for a high level of involvement, while delegating responsibilities to teams he trusts to do their part. Steve Jobs has personally contributed a great deal to the success of Apple with his creativity and innovative mind. As a leader he has made the organisation very functional by attempting to create an independent company, but still staying as involved as possible. He can be defined as a New Transformational Superleader, who is an inspirational person with the anility to motivate followers to higher levels of achievement and at the same time lead others to lead themselves. His ability to know what customers want before they know it themselves has transformed Apple from a minor computer company to a worldwide brand. His role in the creation of unique products was big, and as a front figure of the company the success of Apple has been linked to him, and made him a memorable leader, who will very likely go down in history. The future of Apple is yet to be defined, but if his successor possesses some of the same qualities as himself, it is likely that the success of Apple will continue for many years to come. Stay hungry, stay foolish – Steve Jobs References Litterature: Andrzej A. Huczynski and David A. Buchanan, Organizational Behaviour (7th Ed.) Walter Isaacson, Steve Jobs – En biografi om manden bag Apple, Gyldendal 2011 Webpages: Steve Wozniak on Steve Jobs’ risk taking: http://abcnews.go.com/GMA/video/steve-wozniak-death-steve-jobs-146801955 Independent leadership: http://www.gordontraining.com/leadership-training/no-steve-jobs-at-apple-how-dependent-should-an-organization-be-on-a- single-charismatic-leader/ Steve Jobs at the D8 Conference 2010: http://www.youtube.com/watch?v=LrS7JQv-zgY Jobs on whether Apple could live without him: http://money.cnn.com/galleries/2008/fortune/0803/gallery.jobsqna.fortune/5.html The biography of Steve Jobs: http://allaboutstevejobs.com/bio/short/short.html : Steve Jobs as a leader: http://abcnews.go.com/GMA/video/steve-jobs-proudest-achievement-14801246 Attachment 1: Organizational Chart: http://www.theofficialboard.com/org-chart/apple Attachment 2: Apple Stocks http://finance.yahoo.com/echarts?s=AAPL+Interactive#chart6:symbol=aapl;range=20110701,20111209;indicator=volume;charttype=line;crosshair=on;ohlcvalues=0;logscale=on Attachment 1 Attachment 2

Decision Making Essay Example for Free

Decision Making Essay 1.What issues would you take into account? The stakeholders welfare, responsibility towards the society (in this case it can be identified as United States or as broad as the global inhabitants) which includes environmental issues, and also the ethics. For sure one more important issue is profitability or survivability of the firm. All of the issues mentioned earlier may be thought of as means for ensuring the long-run success of the company. 2.What major sources of uncertainty do you face? The major sources of uncertainty include research and development, and market analysis. â€Å"Will the substitute product work and would it be working the same?† â€Å"Is the ozone problem really directly related to Chlorofluorocarbons, or a normal cycle has actually caused these observed recent changes?† Finally, â€Å"could Du Pont’s efforts really have an effect, and how much?† â€Å"Is this effect going to bring any profit for the company?† and as a market analysis viewpoint, â€Å"will the market and society accept them?† 3.What corporate objectives would be important for you to consider? Do you think that DuPont’s objectives and the way the company views the problem might have evolved since the mid-70s when CFCs were just beginning to become an issue? DuPont’s views of the situation Of course have changed over time. Early on, the chlorofluorocarbon issue was basically ignored. DuPont was the largest CFC producer in the world with a 25% market share in the 1980s.This product was a less hazardous alternative to the sulfur dioxide and ammonia and was widely used as refrigerants in refrigeration, ACs, and medical inhalers for asthma patients. In March 15, 1988 NASA announced that CFCs were not only creating a hole in the ozone layer above Antarctica, but also thinning the layer elsewhere in the world. After NASA announcement, DuPont announced that it would begin to phase out the CFCs. It invested more than $500 million in this case and commercialized a family of refrigerants with zero or lower ozone depletion effects in January 1991 for the first time.

Impact of Video Games on Society

Impact of Video Games on Society Video games are a pastime for masses of adolescents worldwide. The unprecedented technological advancements to this entertaining culture have caused many gamers, especially adolescents, to acknowledge it as the ultimate fantasy. According to many studies, video games can increase aggressive behavior, cause emotional outbursts and decrease inhibitions in many people (Kardaras 2008). As a result of the increased exposure to this modern phenomenon, a mounting body of research is linking video games to violent, aggressive and anti-social behavior. For this reason the study focuses on investigating the impact of video gaming on society to determine whether it leads to aggressive, violent, anti-social behavior. The first aim of this investigation is to document the different types of video games and how they operate through electronic devices, and therefore examining the associations between video game exposure and the different attitudes and behaviors displayed by gamers. The second objective is to explain the key factors which lead to violent, aggressive and anti-social behavior and the extreme lengths to which the gaming industry will go to in order to reap the advantages of video games. The investigation also presents an outline of the current rating and censorship systems in Australia, which has resulted in some violent video games being banned for their violent and inappropriate content. To end the research a feasible solution is proposed to maximize the potential advantages of rating systems. In conclusion, the paper summarizes the impact of video games on society. It concludes that gamers who expose themselves to greater amounts of video game violence are more likely to be prone to violent, aggressive and antisocial behavior over time. Word Count: 272 Section One: Introduction The gaming industry has grown immensely through the evolution of modern consoles, games and accessories. Therefore the ever growing hype that surrounds these technological gadgets is unprecedented even in the world of gamers, causing many adolescents to perceive video games consoles as a necessity in their lives, rather than an accessory. The impact of video gaming has been a debated issue for many years, and consequently the problem appears to be influencing many of my peers therefore I took this opportunity to explore the effect of video games on society. This paper presents an investigation into the impact of video gaming on society to determine whether it leads to aggressive, violent and anti-social behavior. For the purpose of this examination the information has been divided into four sections. The first section examines what video games are and the genre of games which have resulted gamers displaying different behaviors. The next section assess how video games have an impact on society through real life examples, and then the possible factors which could lead to aggressive, violent and anti-social behavior. The final section in addition to a proposed solution to this issue, aims to discuss how effectively game ratings restrict inappropriate content from adolescent users. There is no question that video games have an impact on society. One thing that is certain is that the gaming industry is growing rapidly which consequently increases the impact of video games on society. Section Two: What are video games and the different type of video games played? A video game is an electronic game that involves interaction with a user interface to generate visual feedback on a device specially made for game play called a video console; these interactions are entered via input devices such as controllers, joysticks and hand-held peripherals. The electronic systems used to play video games are known as platforms which range from: personal computers, video game consoles and small handheld devices and through these platforms video and sound are produced to interact with the user (Video Game 2009). The advancements in gaming consoles have become a major factor in promoting video game addiction, and therefore amplifying the video game influence among users. As gaming technology continues to expand, consoles such as Microsofts Xbox 360 and Sonys Playstation are becoming more sophisticated due to the customer demand for an enhanced gaming experience. Recent developments allow gamers to have access to video games at any time; for example with the PSP (Play Station Portable) a gamer is able to carry their console around with him/her anywhere, thereby adding to the amount of hours spent playing games. Similarly consoles like the Wii set a new precedent for the gaming world, trying to create a physical and more realistic gaming experience through innovative accessories such as the Wii MotionPlus which provided true motion and position information to the console (The Wiire 2008), and therefore encouraging users to become more engrossed in the game. Furthermore, the development of graphical interfaces and televisions appear to be significant factors in endorsing excessive gaming time. In particular the transition to LCD (Liquid-Crystal Display) and plasma televisions, which introduced a gratifying experience for gamers through the addition of surround sound speaker systems and improved graphic resolution. Subsequently the enlargement of graphic interface screens also added to the attractiveness of video games, as the screen sizes increased from 14 inch up to the unprecedented size of 65 inch (LCD television 2010). As the mind-blowing graphic resolution becomes more available, users are promised real entertainment in these virtual worlds, by creating a more realistic gaming experience. The most commonly played games are action games; these games encourage the development of aggressive characteristics to emerge in gamers, as they have a large amount of violence due to their fast-paced nature. The games usually allow the user to play person against person or person against animal/aliens; a classic example is the game Halo which incorporates violent confrontations which are practised through violent combat between the user interface and the console (Caruana, Caruana Bruner 2009). Currently the most recent video games present players with expansive spaces and allow users to interact in multiple ways; resulting in each player having a unique experience (Garrelts 2006). One of the most problematic games of recent times is Grand Theft Auto: San Andreas. The controversy behind this game stemmed from many politicians condemning its frequent violent and sexual scenes. As illustrated above (refer figure 3), the game encourages inappropriate actions such as violence to be practised through gang warfare, raising concerns as these types of games have been turned into fodder for entertainment (Loftus 2002). Another genre of video games is adventure/role playing games; these games are usually less graphic than action games but contain mild violence and typically have an element of surrealism and fantasy. Games like Starfox Adventures are usually combined with a role playing element and allow the character to initiate dialogue. These games tend to be among the most addictive due to their narrative fantasy themes together with their mild violent content (Caruana, Caruana Bruner 2009). In a study conducted on video game usage and content this genre of games was found to encourage an increasing amount of antisocial values of a violent nature (Tompkins 2003). Section Three: How do video games have an impact on society? Adolescents and children are the group of people which are mostly engrossed to video games in society. The vulnerability of these groups especially children is prominent, as they are at such crucial stages in their development that they are highly influenced by their environment. For this reason some concerns have arisen as to why video games have become very influential story-tellers for this generation of children and youth (McCain J 2000).This may be a result of the technological advances which have exposed new generations to more graphic games which emphasize violence. With regards to this argument there are two very opposite sides, the first being put by the gaming industry who argue that gaming is secure entertainment with no link to violence and the others being the psychologists and researchers who argue that violent media promotes aggression (Tompkins 2003). Research dedicated to this issue is enormous, with many scientific studies concluding that significant exposure to violent video games increases the risk of aggressive behavior in certain children. From this exposure children become desensitized to violence making them believe that the world is a meaner and scarier place than it is (Tompkins 2003). Unfortunately, these thoughts are often said to be difficult to change later on in life. Therefore children begin to think that violence is normal behavior as depicted in the games. The idea of violence in video games can be similar to that of domestic violence, where children who are exposed to violence either become offenders or victims as they believe that what they observe is the norm (Tompkins 2003). The development of these thoughts in gamers could potentially lead to gamers becoming more violent and aggressive over time. Much of the research found on video games, like Dr Andersons, a leading researcher in the field of gaming reveals unequivocal evidence that game violence increases the likelihood of aggressive and violent behavior in both immediate and long-term contexts (Anderson et al. 2003). The studies conducted found that the short-term exposure increases the likelihood of physically and verbally aggressive behavior, thoughts and emotions immediately after playing the game. While large-scale longitudinal studies provided converging evidence linking frequent exposure to violent video games during childhood leads to aggression later in life, including physical assaults and spouse abuse (Anderson et al 2003). Other researchers illustrate a comprehensive correlation between playing of M-rated games and bullying in schools. The gamers who played M-rated games, commonly adolescents, were found to be more likely to be reported for bullying other members in the school community (Thomas 2008). Sadly thes e negative outcomes are real as they are affecting our childrens behavior in schools, therefore creating more violent and troublesome youth within the wider community. The aspect of video games that is of most interest for this investigation is the content due to the fact that the violent content exposed to users can potentially be a factor which leads to aggressive outcomes (Gentile, Lynch, Linder Walsh 2004). Although current researchers conclude violent affects, Dr Anderson himself describes the relationship between games and aggressive behavior as similar to that between smoking and cancer. This comparison illustrates the idea that exposure to violence in video games may not always necessarily lead to aggressive outcomes; likewise smokers do not always develop cancer. Nevertheless, the chances of video games causing violent behavior in adolescents are increased dramatically (Hian Hou 2009). The negative effects of violent video games are evident in a recent study which involved adolescents playing two different games for 30 minutes. The researchers divided a group of 44 adolescents into two groups and randomly assigned the children to play one of the two games; the first being the high-octane Need for Speed: Underground, and the other the ultra-violent first-person shooter Medal of Honor: Frontline. Following the gaming session the children were given MRIs (Magnetic resonance imaging) of their brains. The scans revealed that the adolescents who played Medal of Honor, as a result of the exposure to violent and destructive scenes, showed an increase in emotional arousal and a corresponding decrease of activity in brain areas involved in self-control, inhibition and attention(Kalning 2006). Unsurprisingly that same effect was not present in the children who played Need for Speed. For many gamers the exposure to violent video games increases their violent behavior; the cumulative effect of the exposure to these realistic and disturbing graphics is that it is creating a more violent society. Many modern time games now have been designed to demonstrate stereotypical characters. For example regarding gender, the portrayal of men has caused many adolescents to learn from these violent games, but unfortunately they are getting the wrong messages across. The men which are often portrayed as large and aggressive characters have resulted in gamers using violence as a means to solve conflict and problems with negotiation and non-violent solutions being totally disregarded. The concept of the gamers solving issues themselves in a similar manner through the practice of violence and aggression in order to be a man becomes apparent in gamers, ultimately resulting in some gamers imitating scenes from games in real-life situations (Haymes 2009). The impact of violence in video games has ignited debate in recent times, due to the rise of video games as a modern phenomenon. Psychology lecturer Caleb Owens, an obsessive gamer himself who spends lots time at a console, was so disturbed by scenes from the game Modern Warfare 2 where a player could at an airport assume the role of a terrorist in a Mumbai-style massacre (Dikeos 2010), that he complained to the Classification Review Board. The response from the games publishers was that this is to help gamers understand terrorism from the other side(Dikeos 2010). Supporting this response is Laura Parker, who is a devoted gamer and an online journalist for a gaming website, saying that a lot of people take these violent scenes out of context and say that the whole game is made up of these elements and thats often not the case at all (Dikeos 2010). Even so, frequent scenes which depict blood and murder have caused greater concern, as it could potentially encourage gamers to imitate vi olence in real-life situations. Despite the negative associations, some experts have come to other conclusions, strongly arguing that video games have no link to violence. In recent times Modern Warfare 2 has been criticized for its violent content but it is not going to cause a change in adult behavior (Barnett 2009) says Professor Mark Griffiths. The professor explained that there is no definitive proof or research to show that violent video games make adults behave any more violently (Barnett, 2009), adding that younger gamers, typically under the age of eight tend to be more influenced by games and what they see on screen. They usually try and mimic what they have watched on the big screen. However adults, which this game is certified for, have already formed their cognitive sensibilities and will not usually start acting differently because of a video game (Barnett 2009). Although these justifications sound reasonable they overlook the ease with which children can access violent and adult rated games. Currentl y video games cannot be certified to a specific group of people because the chances of a child obtaining a MA18+ rated game have increased due to the feeble enforcement of censorship regulations enforced in many countries. Section Four: Factors which lead to aggression, violence and anti-social behavior. The most worrying issue is that most violent games are landing in the hands of millions of children, despite ratings attempting to restrict prohibited access. For this reason inappropriate games have become implicated in a string of recent school shootings and murders which has raised concerns to new heights (McCain J 2000). Modern games are designed to be entertaining and challenging. The reality is that manufacturers are shamelessly exploiting children for revenue. Currently 89% of video games released contain some violent content. For this reason when consumers specifically children, who are highly influenced by what they see on the big screen, expose themselves to violence they begin to incorporate aggressive concepts and behaviors into their typical behavioral repertoire (Anderson, Gentile Buckle 2007). Despite these unethical practices by manufacturers being scrutinized, many retailers still insist on advertising games where it is better to kill people, attack police and drive dangerously. Although video games exposure is correlated to many negative outcomes, some research suggests that video game exposure independent of content is related to improvements in certain types of cognition and learning. These benefits are real but are limited, as the majority of games played tend to incorporate an increasing amount of violence and inappropriate content (Barlett, Anderson and Swing 2008). Despite some research in support of positive outcomes, the negative outcomes of video games are more evident. As research, in this case a meta-analysis by Anderson and Bushman (2001) found that across 54 independent tests of the relation between video games and violence, involving 4262 participants, there appeared to be five consistent results from playing games with violent content. Playing violent games tend to increase aggressive behaviors, awareness, emotions, and physiological arousal and decrease pro-social behaviors. These effects are noticeable and have been found in children and ad olescents, in males and females and in experimental and non-experimental studies. Therefore it can be considered as concrete evidence supporting the negative effects of video games on gamers. Further research by Anderson suggests that exposure to violent video games may increase angry and hostile feelings while interacting with peers, teachers and adults which leads users to demonstrating fierce behavior (Anderson et al. 2004). Perhaps the best example of violent video game influence over adolescents is the case of Dylan Klebold and Eric Harris. The two video game fanatics opened fire in their Colorado High School in 1999, killing 13 people. Experts made a convincing link between the murder and the continuous playing of video games with reports revealing that Harris and Klebold spent long hours playing video games like Wolfenstein 3D, Doom and Mortal Kombat. The two murderers enjoyed playing various violent games, which effectively played a focal role in their violent acts. Eric Harris had actually modified a version of the game Doom and placed it on his website.   In his version there were two shooters, extra weapons and other characters in the game that couldnt shoot back. Harris and Klebold essentially acted-out their version of Doom on innocent classmates demonstrating how violent content in games played could have a pronounced influence on the users behavior and actions (Holmes 2005). The dramat ic rise in violent shootings by adolescents many of which have been linked to playing violent video games supports the argument that video game violence transforms into real-world situations (Layton 2007). Another murder which was linked to video games was that of a 14-year-old British boy by an older friend. The court heard that Warren Leblanc, the convicted murderer had struck Stefan Pakeerah over the head with a claw hammer from behind. The spark behind the prolonged assault was found to be the horrific images observed on the computer while playing a violent video game, as Stefans parents proclaimed that Leblanc had mimicked a game called Manhunt, in which the players score points for violent killings. The parents of Warren themselves claimed that their son was obsessed with the game, as a result guiding him to rehearse violent scenes of this game in real life in an exceptionally disturbing manner (Video game sparked hammer murder 2004). The ethical question arising from these cases is that if these violent video games are having such a pronounced influence on gamers causing them to commit crimes in such a cruel manner, should they really be developed and sold in the first place. Moral concerns also arise with recent studies suggesting that adolescents playing such games have difficulty distinguishing between fantasy and reality, therefore guiding them to perform acts played on consoles in real life. (Video game sparked hammer murder 2004). For many the line between reality and fantasy is lost through their addiction. In some fantasy games like Second Life players are able to live their fantasy life in a virtual world, to the point where the virtual world overrules their daily life. Even though these types of role playing games do not necessarily encourage aggressive or violent behavior, nevertheless they still contribute to the possibility of a gamer engaging in anti-social behavior as they create an alias where people can live technologically, contrary to their usual social life. The addictive nature of video games can lead to gamers developing anti- social behavior. This addiction is so problematic that such games have affected non-adolescents day-to-day activities. An example of an addictive game is the popular online game The World of Warcraft which has over 10 million online users. Due to the extended hours spent playing these game extreme cases have occurred as excessive exposure to this online game has resulted in some mature aged gamers getting divorced, fired from their jobs, and in a rare case, someone dying as a result of the lack of sleep or proper nutrition (Do Video Games Cause Aggression and Death The Truth About Video Game Effects 2010). Often gamers can connect with multi-players around the world through the click of a button, without even meeting them or knowing who they are. The availability and easy access to the internet directly from the console eliminates the need for users to go out and socialize as these technological communications are in effect replacing social interactions for gamers; thus leading to isolation and the development of anti-social behavior over time. On the other hand, a report by Greg Thom suggests that fun games which encourage teamwork and friendship can lay the groundwork for positive interaction between children, leading to better behavior and academic results (Thom 2009). Although these findings exemplify positive outcomes, they are limited as such results only apply to gamers who play non-violent and G-rated games. At present the number of fun games has diminished as the growing culture within the gaming world demands more violent and adventure orientated games. For this reason the negative associations allied to video games are more apparent with an increasing number of gamers spending hours playing violent and role playing games, isolating themselves from the rest of the world. The exposure to long hours over time allows for basic social functions to be forgotten leading to players hesitating when handling social activities. Other impacts are loneliness, aggressiveness and disregard for rules and regulations. An initial addiction to video games which may not be considered severe can easily turn into a psychological anti-social disorder (Anti-Social Behaviour n.d.) 5. Section Five: Overview of ratings and censorship in Australia. The purpose of a rating system is to provide concise and impartial information about the content in video games so consumers, especially parents, can make informed purchase decisions (Game Ratings Descriptor Guide 2009). Nevertheless rating systems implemented in many countries including Australia are open to manipulation quite easily whether it is because of dishonest retailers or careless parents. Unfortunately games that are rated MA15+ or AO are potentially at risk of falling into childrens hands. With pirated media rampant in society a game that is banned in your country could be downloaded to a destination where it has not been released, again limiting the effectiveness of current rating systems. The main reason that games are banned is because they promote anti-social behavior and expose users to high levels of violence, sex and drug use. An example of a game banned in Australia for its explicit adult content is Phantasmagoria, which goes so far as to have a rape scene in it. Without censorship, games like these which are highly inappropriate could easily be found in childrens video games consoles. However while it is possible to control the content of what hits the shelf, it is what happens once they have been bought that remains the issue. Another game is Left 4 Dead 2 a first person shooter game which was refused classification because of its frequent and intense portrayal of violence and graphic depictions of blood and gore. The disturbing scenery resulted in some politicians correlating between the people playing such violent video games and the increase in criminal activity (MacDonald, 2009). Of the thirty three games that have been banned in Australia fourteen of them contained images that were deemed inappropriate for users and considering that the average age of a video gamer in Australia is 30 years old, that is indicative of just how explicit the content is (List of banned video games 2009). There are already issues in todays society with children being exposed to images/cultures which are inappropriate and the addition of unsuitable video games can add to the increasing problem of media influence on children and adolescents. The unfortunate failure of these ratings is that some parents are not aware retailers are selling inappropriate games to their children, who, by law are not permitted to purchase them. Even though this is the case parents should be encouraged to monitor and be more attentive to their children while playing video games by restricting their time in front of the television and computer (Tompkins 2003). Governments should strive to insure that all parents are fully aware of the rating system and the way it works. To promote awareness a campaign should be launched across all media regarding the negative implications of the exposure to inappropriate video games on their children. With the support of a rating system to try and minimize the amount of inappropriate content, parents should make an effort to become more involved in their childrens lives before it is too late (Tompkins 2003). Effectively if the parents take more responsibility by endeavoring to cooperate with their governments i n an attempt to limit the amount of violent and inappropriate content displayed to their children then the potential impact of video games on society could be lessened. Section Six: Conclusion The impact of video games is apparent as it is affecting thousands of people around the world daily. From Street Fighter to FIFA 09 these games are impacting the gamers in society psychologically and physiologically. Many gamers have become attached to the life and person they believe they have become through virtual worlds experienced in games. These worlds have caused gamers who otherwise would not be living their ideal life in reality to get caught up in the fantasy and unrealistic expectations of video games. The objective of this research was to investigate the impact of video gaming on society to determine whether it leads to aggressive, violent, anti-social behavior. The essay demonstrated how video games have a pronounced influence on adolescents in society, with violent behavior becoming more prevalent amongst adolescent, gamers begin to act like the characters they seek to control in games. Video game impact on society is evident, as the exposure to video game violence was found to be a significant risk factor for aggressive and violent behavior (Tompkins 2003). Unfortunately, games which contain violent content are reaching our childrens hands, therefore encouraging them to act aggressively and anti-socially. One question which we should ask is Who should be held responsible for the increase of video game exposure in society? Are the gaming companies to blame for releasing highly graphic and violent games d, the irresponsible parents who allow their children to spend long hours playing inappropriate games or simply the young people who choose to play the games? Consequently, other possible issues attached to this effect can be examined; for example more stringent regulations or laws to implement impose accountability for the retailers. Therefore the focus for further research should be based on these questions that are emerging to possibly come to a conclusion about how to finally address this issue. Currently there is no definitive solution to the issue of gaming and the effect that it has on the users behaviors. Nevertheless, there are some recommendations to a possible solution; these include the need for more governments to impose stricter rating systems, parents becoming more aware and responsible for their childrens game play and also gamers themselves becoming more mindful of separating the gaming world from the real world. 7. Section Seven: References and Bibliography Reference list: Online books: Anderson, C, Gentile, D Buckle, K 2007, Violent video game effects on children and adolescents: theory, research, and public policy, Oxford University Press Inc., New York. Garrelts, N 2006, The meaning and culture of Grand theft auto: critical essaysHYPERLINK http://books.google.com.au/books?id=Woct9TuzNNoCpg=PP1dq=The+meaning+and+culture+of+Grand+theft+auto:+critical+essays++By+Nate+Garreltscd=1à ¢Ã¢â€š ¬Ã… ½, McFarland and Company Inc, North Carolina. Online journals/articles: Anderson, C.A. Bushman, B.J (2001). Effects of violent games on aggressive behavior, aggressive cognition, aggressive affect, physiological arousal, and prosocial behavior: A meta-analytic review of the scientific literature. Psychological Science, 12 , pp. 353-359, retrieved on 2 May 2009. Anderson, C. A., Carnagey, N., Flanagan, M., Benjamin, A.J., Eubanks, J., Valentine, J. C. (2004). Violent Video Games: Specific Effects of Violent Content on Aggressive Thoughts and Behavior. Advances in Experimental Social Psychology, 36, p. 199-249, retrieved on 23 April 2009. Anderson et al., (2003), The influence of media violence on youth. Psychological Science in the Public Interest, 4(3), p.81-110, retrieved on 10 September 2009. Barlett, C. P, Anderson C.A, Swing, E.L (2008). Video Game Effects- Confirmed, Suspected, and Speculative: A Review of the evidence, Simulation Gaming, vol. 40, pp. 337, retrieved on 25 August 2009. Gentile, D.A, Lynch, P.J, Linder, R.H Walsh, D.A (2004). The effects of violent video game habits on adolescent hostility, aggressive behaviors, and school performance, Journal of Adolescence, vol. 27, pp. 5-22, retrieved on 11 November 2009. McCain, J. (2000), The impact of interactive violence on children. Committee on commerce science, and transportation United State Senate, retrieved on 20 July 2010. Tompkins, A. (2003), The Psychological Effects of Violent Media on Children. AllPsych Journal, retrieved on 15 June 2010. Websites: Anti-Social Behaviour (n.d), A social, psychological and economic study of the positive and negative impact the internet has on children and families, viewed 27 June 2009, http://people.hamilton.edu/bhouse/DoWeEncourage/DoWeEncourage5.html Barnett, E 2009, Modern Warfare 2: No link between video games and adult violence, Telegraph, viewed March 20 2010, http://www.telegraph.co.uk/technology/video-games/6536966/Modern-Warfare-2-No-link-between-video-games-and-adult-violence.html Caruana, V, Caruana, C Bruner O 2009, Types of Video Games, Focus on the Family, viewed 28 June 2009, http://www.focusonthefamily.com/entertainment/mediawise/parents_guide_to_video_games/types_of_video_games.aspx Dikeos, T 2010, Emotive debate over R rating for video games, ABC, viewed 20 March 2010, http://www.abc.net.au/7.30/content/2010/s2848891.htm Do Video Games Cause Aggression and Death The Truth About Video Game Effects (2010). Update Reality: Self Improvement, viewed 15 Ju