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establishment by Amelung
American glass produced from 1784 to about 1795 by John Frederick Amelung, a native of Bremen in Germany. Financed by German and American promoters, Amelung founded the
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Donoghue v Stevenson
Donoghue v Stevenson | |
Court | House of Lords |
Full case name | M'Alister (or Donoghue) (Pauper) v Stevenson[Note 1] |
Decided | 26 May 1932 |
Citation(s) |
Transcript(s) | House of Lords transcript |
Case history | |
Prior action(s) | Outer House of the Court of Session ([1930] SN 117)[3] |
Appealed from | Inner House of the Court of Session ([1930] SN 138)[3] |
Case opinions | |
Manufacturers have a legal duty of care to the ultimate consumers of their products if it is not possible for defects to be identified before the goods are received.[1]:9[4]:643 | |
Court membership | |
Judges sitting | |
Keywords | |
Donoghue v Stevenson [1932] UKHL 100 was a foundational decision in Scots delict law and English tort law by the House of Lords. It created the modern concept of negligence, by setting out general principles whereby one person would owe a duty of care to another person.
Also known as the "Paisley snail"[5][6] or "snail in the bottle" case, the facts involved Mrs Donoghue drinking a bottle of ginger beer in a café in Paisley, Renfrewshire. A dead snail was in the bottle. She fell ill, and she sued the ginger beer manufacturer, Mr Stevenson. The House of Lords held that the manufacturer owed a duty of care to her, which was breached, because it was reasonably foreseeable that failure to ensure the product's safety would lead to harm of consumers.
Prior to Donoghue v Stevenson liability for personal injury in tort usually depended upon showing physical damage inflicted directly (trespass to the person) or indirectly (trespass on the case). Being made ill by consuming a noxious substance did not qualify as either, so the orthodox view was that Mrs Donoghue had no sustainable claim in law. However, the decision fundamentally created a new type of liability in law which did not depend upon any previously recognised category of tortious claims. This was an evolutionary step in the common law for tort and delict, moving from strict liability based upon direct physical contact to a fault-based system which only required injury. This evolution was taken further in the later decision of Letang v Cooper [1965] 1 QB 232 when it was held that actions should not be jointly pleaded in trespass and negligence, but in negligence alone.
On the evening of Sunday 26 August 1928, during the Glasgow Trades Holiday, Donoghue took a train to Paisley, Renfrewshire.[3][7]:1 In Paisley, she went to the Wellmeadow Café. A friend,[Note 2] who was with her ordered a pear and ice for herself and a Scotsman ice cream float, a mix of ice cream and ginger beer, for Donoghue.[7]:4 The owner of the café, Francis Minghella,[Note 3] brought over a tumbler of ice cream and poured ginger beer on it from a brown and opaque bottle labelled "D. Stevenson, Glen Lane, Paisley". Furthermore, although the bottle was labelled as Stevenson's, McByde suggests it is possible it did not originally belong to him. Bottles were often reused, and in the process occasionally returned to the incorrect manufacturer. Moreover, Stevenson initially claimed he did not issue bottles matching the description provided by Donoghue.[3][7]:9–10 Donoghue drank some of the ice cream float. However, when Donoghue's friend poured the remaining ginger beer into the tumbler, a decomposed snail also floated out of the bottle. Donoghue claimed that she felt ill from this sight, complaining of abdominal pain.[3][9] According to her later statements of facts (condescendences), she was required to consult a doctor on 29 August and was admitted to Glasgow Royal Infirmary for "emergency treatment" on 16 September.[7]:23[10]:7 She was subsequently diagnosed with severe gastroenteritis and shock.[3][8]:566
The ginger beer had been manufactured by David Stevenson, who ran a company producing both ginger beer and lemonade at 11 and 12 Glen Lane, Paisley, less than a mile away from the Wellmeadow Café.[7]:6–7 The contact details for the ginger beer manufacturer were on the bottle label and recorded by Donoghue's friend.[7]:11
Donoghue subsequently contacted and instructed Walter Leechman, a local solicitor and city councillor whose firm had acted for the claimants in a factually similar case, Mullen v AG Barr & Co Ltd,[11] less than three weeks earlier [3] (see also George v Skivington).
Despite the ruling in Mullen, Leechman issued a writ on Donoghue's behalf against Stevenson on 9 April 1929.[3][12]:31 The writ claimed £500 in damages, the same amount a claimant in Mullen had recovered at first instance, and £50 in costs.[7]:22[10]:4 The total amount Donoghue attempted to recover would be equivalent to at least £27,000 in 2012[update].[7]:22[13]
The full allegations made by Donoghue were presented in five condescendences, which claimed that Stevenson had a duty of care to Donoghue to ensure that snails did not get into his bottles of ginger beer, but that he had breached this duty by failing to provide a system to clean bottles effectively, a system that would usually be used in the business and was necessary given that the ginger beer was intended for human consumption.[7]:22–23 The ineffectiveness of the cleaning system was alleged to result from the bottles being left in places "to which it was obvious that snails had freedom of access ... and in which, indeed, snails and snail trails were frequently found",[10]:6 an allegation described by Matthew Chapman as "somewhat gratuitous".[7]:7 This breach of duty was alleged to have caused Donoghue's subsequent illness.[10]:7
Stevenson responded to the condescendences by denying that any of his bottles of ginger beer had contained snails and "that the alleged injuries are grossly exaggerated ... any illness suffered by the [claimant] was due to the bad condition of her own health at the time".[10]:6–7 In response to the writ, Stevenson pleaded (1) that the claim had no legal basis, (2) that the facts could not be substantiated, (3) that he had not caused Donoghue any injury and (4) that the claimed amount was excessive.[7]:22–23[10]:8
Legal background[edit]
Injuries resulting from defective products were normally claimed on the basis of a contract of sale between the seller and the consumer.[3] However, Donoghue had no contractual relationship with Minghella as she had not purchased the ginger beer; while her friend did have a contract through having placed the order, she had not suffered any injury. Moreover, neither had a contract with Stevenson, the manufacturer.[9] Donoghue was therefore required to claim damages for negligence.[3]
Ansell v Waterhouse[14] had established in 1817 that legal liability could arise for an act or omission "contrary to the duty which the law casts on him in the particular case" (i.e. negligence).[15]:105–106 However, there was no general duty of care and therefore no general liability for negligent behaviour. Only limited exceptions to this rule were made in which duties were found in specific circumstances, most of which had a contractual background.[4]:643[15]:109[16]:86
The most difficult precedent for Donoghue was Mullen v AG Barr & Co Ltd, a recent Court of Session case. In Mullen, two children, John and Francis Mullen, and Jeanie Oribine had separately found dead mice in their bottles of ginger beer, manufactured by AG Barr & Co Ltd, and claimed to have become ill through drinking the tainted liquid. In separate hearings in Glasgow and Greenock Sheriff Court respectively, Orbine was successful in claiming compensation while the Mullens were not. The losing parties of both cases appealed to the Court of Session.[7]:16–17
At the Court of Session, the claimants argued that although there was no direct evidence that the manufacturer had been negligent in preparing the ginger beer, negligence could be presumed (res ipsa loquitur) from the mere presence of dead mice in ginger beer bottles. However, the court ruled against the claimants.[7]:16–17 The majority held that on a factual basis AG Barr & Co Ltd had rebutted a presumption of negligence and that on a legal basis product manufacturers only owed a duty of care to the ultimate consumers if there was a contractual relationship between the parties; if the dangerousness of the product was intentionally withheld from the consumer (in which case there might also be a claim for fraud); or if there was no warning of the intrinsic dangerousness of certain products, such as explosives.[3][7]:17–18 Only Lord Hunter dissented, finding that negligence to be inferred and that the fact that the bottle contents could not be examined (because of the dark glass) gave rise to a specific duty of care that would allow consumers to claim for damages.[7]:18–19
However, neither of the circumstances in which negligence could be found in product liability cases applied to Donoghue: ginger beer is not intrinsically dangerous, nor did Stevenson intentionally misrepresent the threat it posed. Nevertheless, Donoghue's counsel argued that manufacturers also owed a duty of care to their ultimate consumers if it was not possible to examine the goods before they were used, an exception that would apply to Donoghue.[9]
Court of Session, Outer House[edit]
The first interlocutory action was heard on the Court of Session on 21 May 1929 in front of Lord Moncrieff. After an adjournment, Minghella was added as a defender on 5 June; however, the claim against him was abandoned on 19 November, likely due to his lack of contractual relationship with Donoghue (Donoghue's friend had purchased the ginger beer) and his inability to examine the contents of the dark glass bottle. On 12 December, Minghella and Stevenson were awarded a combined costs claim of £108 6s 3d against Donoghue for this abandoned strand of litigation. However, it was recorded on 20 December that Donoghue did not pay the costs awarded to Minghella.[7]:23–25
The case was heard by Lord Moncrieff in the Outer House on 27 June 1930. In his judgment, delivered on the same day, he held that, as a general principle, there should be liability for negligent preparation of food.[7]:25–26
I am unhesitatingly of opinion that those who deal with the production of food or produce fluids for beverage purposes ought not to be heard to plead ignorance of the active danger which will be associated with their products, as a consequence of any imperfect observation of cleanliness at any stage in the course of the process of manufacture ... Tainted food when offered for sale is, in my opinion, amongst the most subtly potent of 'dangerous goods', and to deal in or prepare such food is highly relevant to infer a duty. I fail to see why the fact that the danger has been introduced by an act of negligence and does not advertise itself, should release the negligent manufacturer from a duty, or afford him a supplementary defence.[17]:4,6
English case law that required that liability for injuries resulting from goods that were not intrinsically dangerous to have a contractual basis (breach of warranty) was dismissed by Lord Moncrieff (citing John Salmond) for the narrowness of the approach and because there was no decision that incorporated it into Scots law.[7]:26–27[17]:15–16 Finally, Mullen, despite its factual similarity, was discounted by a "very close reading of the precedent opinions".[7]:27–29[17]:17–19
Court of Session, Inner House[edit]
Stevenson appealed the case to the Inner House, where it was heard by the same four judges who had found against Mullen: Lord Alness (the Lord Justice-Clerk), Lord Ormidale, Lord Hunter and Lord Anderson.[7]:29 In their judgment, given on 13 November 1930,[17]:21 they all referred back to and supported their statements in Mullen, Lord Alness observing that "the only difference — and, so far as I can see, it is not a material difference — between that case [Mullen] and this case [Donoghue] is that there we were dealing with a mouse in a ginger-beer bottle, and here we are dealing with a snail in a ginger-beer bottle".[17]:22 Thus, Lord Alness, Lord Ormidale and Lord Anderson all allowed the appeal while Lord Hunter dissented.[7]:29–30
House of Lords[edit]
Donoghue filed a petition to appeal to the House of Lords on 25 February 1931.[7]:32 She also sought (and subsequently received) permission to pursue the case in forma pauperis (with the status of a pauper) – a status she had not, for unknown reasons, sought at the Court of Session[7]:33–34 – providing an affidavit declaring that "I am very poor, and am not worth in all the world the sum of five pounds, my wearing apparel and the subject matter of the said appeal only excepted...".[3] This claim was supported by the minister and two elders of her church and meant that Donoghue was not required to provide security for costs in case she lost the appeal.[7]:34 (Her legal team had agreed to work pro bono.[3])
The petition was granted and the appeal was heard 10 and 11 December 1931 by Lord Buckmaster, Lord Atkin, Lord Tomlin, Lord Thankerton and Lord Macmillan. A supplementary statement from Donoghue's appeal papers indicates that her counsel, George Morton KC and William Milligan (later the Lord Advocate and a Privy Counsellor), argued that "where anyone performs an operation, such as the manufacture of an article, a relationship of duty independent of contract may in certain circumstance arise, the extent of such duty in every case depending on the particular circumstances of the case".[10]:16 Stevenson, they argued, owed a duty to take reasonable care in the manufacture of his ginger beer because the sealed bottles were opaque, and therefore could not be examined, and because the ginger beer was intended for human consumption.[7]:35–37[10]:16–17
Stevenson's counsel, Wilfrid Normand KC (Solicitor General for Scotland and later a Law Lord) and James Clyde (later the Lord President of the Court of Session and a Privy Counsellor), responded that "it is now firmly established both in English and Scottish law that in the ordinary case (which this is) the supplier or manufacturer of an article is under no duty to anyone with whom he is not in contractual relation".[18]:7 They denied that ginger beer was intrinsically dangerous or that Stevenson knew that the product was dangerous (the two established exceptions for finding a duty of care)[18]:7–8 and argued that the third exception that Donoghue was attempting to introduce had no basis in precedent.[7]:37–38[18]:8–11
The House of Lords gave judgment on 26 May 1932 after an unusually long delay of over five months since the hearing.[Note 4][19]:236–237 The court held by a majority of 3–2 that Donoghue's case disclosed a cause of action.[8]:562 The majority consisted of Lord Atkin, Lord Thankerton and Lord Macmillan.[8]:562
Lord Atkin commented that he did "not think a more important problem has occupied your Lordships in your judicial capacity, important both because of its bearing on public health and because of the practical test which it applies to the system under which it arises".[12]:43 He agreed with counsel, based on his own research, that Scots and English law were identical in requiring a duty of care for negligence to be found and explained his general neighbour principle on when that duty of care arises.[7]:40–41
" | At present I content myself with pointing out that in English law there must be, and is, some general conception of relations giving rise to a duty of care, of which the particular cases found in the books are but instances. The liability for negligence, whether you style it such or treat it as in other systems as a species of "culpa," is no doubt based upon a general public sentiment of moral wrongdoing for which the offender must pay. But acts or omissions which any moral code would censure cannot, in a practical world, be treated so as to give a right to every person injured by them to demand relief. In this way rules of law arise which limit the range of complainants and the extent of their remedy. The rule that you are to love your neighbour becomes in law, you must not injure your neighbour; and the lawyer's question, Who is my neighbour? receives a restricted reply. You must take reasonable care to avoid acts or omissions which you can reasonably foresee would be likely to injure your neighbour. Who, then, in law, is my neighbour? The answer seems to be – persons who are so closely and directly affected by my act that I ought reasonably to have them in contemplation as being so affected when I am directing my mind to the acts or omissions which are called in question."[12]:44 | " |
He supported this broad test by citing Heaven v Pender[20] and rejected the cases in favour of a narrower interpretation of a duty of care with the example of negligently poisoned food, for which there had been no claim against the manufacturer. "If this were the result of the authorities, I should consider the result a grave defect in the law, and so contrary to principle that I should hesitate long before following any decision to that effect which had not the authority of this House".[7]:41[12]:44–46 He went on to suggest that there should be a duty of care owed by all manufacturers of "articles of common household use", listing medicine, soap and cleaning products as examples. "I do not think so ill of our jurisprudence as to suppose that its principles are so remote from the ordinary needs of civilized society and the ordinary claims it makes upon its members as to deny a legal remedy where there is so obviously a social wrong."[7]:42[12]:46
Lord Atkin then rejected cases that did not support his approach and cited Benjamin N. Cardozo in MacPherson v. Buick Motor Co.[21] in favour of his view.[7]:42[12]:46–56
He concluded:
" | If your Lordships accept the view that this pleading discloses a relevant cause of action, you will be affirming the proposition that by Scots and English law alike a manufacturer of products, which he sells in such a form as to show that he intends them to reach the ultimate consumer in the form in which they left him, with no reasonable possibility of intermediate examination, and with the knowledge that the absence of reasonable care in the preparation or putting up of the products will result in an injury to the consumer's life or property, owes a duty to the consumer to take that reasonable care.
It is a proposition which I venture to say no one in Scotland or England who was not a lawyer would for one moment doubt. It will be an advantage to make it clear that the law in this matter, as in most others, is in accordance with sound common sense. I think that this appeal should be allowed.[12]:57 |
" |
Lord Thankerton ruled that Donoghue had no contract with Stevenson, nor that her case was covered by one of the scenarios in which a duty of care had previously been found. However, he held that where goods could not be examined or interfered with, the manufacturer had "of his own accord, brought himself into direct relationship with the consumer, with the result that the consumer [was] entitled to rely upon the exercise of diligence by the manufacturer to secure that the article shall not be harmful to the consumer", an exception to the general nonexistence of a duty of care that applied to Donoghue.[7]:51[12]:59–60
Lord Thankerton further argued that it was impossible "to catalogue finally, amid the ever-varying types of human relationships, those relationships in which a duty to exercise care arises apart from contract" and commented that he "should be sorry to think that the meticulous care of the manufacturer to exclude interference or inspection by the [seller] should relieve the [seller] of any responsibility to the consumer without any corresponding assumption of duty by the manufacturer".[7]:51–52[12]:60
Lord Macmillan examined previous cases[12]:65–70 and held that "the law takes no cognizance of carelessness in the abstract. It concerns itself with carelessness only where there is a duty to take care and where failure in that duty has caused damage".[7]:46–47[12]:70 Whether there was a duty and breach would be examined by the standard of the reasonable person. These circumstances "must adjust and adapt itself to the changing circumstances of life. The categories of negligence are never closed".[7]:47[12]:70 Lord Macmillan held that, according to this standard, Stevenson had demonstrated carelessness by leaving bottles where snails could access them; that he owed Donoghue a duty of care as commercial manufacturer of food and drink; and that Donoghue's injury was reasonably foreseeable. He therefore found that Donoghue had a cause of action and commented that he was "happy to think that in ... relation to the practical problem of everyday life which this appeal presents ... the principles of [English and Scots law] are sufficiently consonant with justice and common sense to admit of the claim which the appellant seeks to establish."[7]:47–48[12]:71–72
The minority consisted of Lord Buckmaster and Lord Tomlin.[8]:562 Lord Buckmaster focused on precedent, and commenced by warning that "although [common law] principles are capable of application to meet new conditions not contemplated when the law was laid down, these principles cannot be changed nor can additions be made to them because any particular meritorious case seems outside their ambit".[12]:35 He held that there were only the two recognised exceptions to the finding of a duty of care and supported Baron Alderson's judgment in Winterbottom v Wright that "the only safe rule is to confine the right to recover to those who enter into the contract; if we go one step beyond that, there is no reason why we should not go fifty".[7]:43–44[12]:36
Lord Buckmaster dismissed George v Skivington,[22] opining that "few cases can have lived so dangerously and lived so long",[12]:37 and rejected Heaven as a tabula in naufragio (Latin: literally "plank in a shipwreck") that was unrelated to Donoghue's case; both "should be buried so securely that their perturbed spirits shall no longer vex the law".[12]:42 He concluded that there was no common law support for Donoghue's claim and supported Lord Anderson's judgment in Mullen.[7]:44–46
"In a case like the present, where the goods of the defenders are widely distributed throughout Scotland, it would seem little short of outrageous to make them responsible to members of the public for the condition of the contents of every bottle which issues from their works. It is obvious that, if such responsibility attached to the defenders, they might be called on to meet claims of damages which they could not possibly investigate or insure."[12]:43
Lord Tomlin concurred with Lord Buckmaster. While he agreed with Lord Atkin that the duty of care a manufacturer owed to its consumers was the same regardless of the product they produced, he held that no general duty of care existed and that the fact the product was in a sealed container made no difference to the finding of a such duty.[7]:50[12]:57–58 He further endorsed concerns that Lord Atkin's broader test of liability would have allowed everyone injured in the Versailles rail accident to be able to claim compensation from the manufacturer of the axle that broke and caused the crash.[3][12]:57
The suggested ratio decidendi (Latin: the reason for the decision) of the case has varied from the narrowest, jokingly suggested by Julius Stone, that there was merely a duty "not to sell opaque bottles of beverage containing dead snails to Scots widows",[24] to the widest, suggested by Lord Normand, who had been one of Stevenson's counsel, that Lord Atkin's neighbour principle was the ratio.[25]:756–757[1]:7
Although the neighbour principle was a critical part of Lord Atkin's reasoning, and was therefore part of the ratio of his judgment, neither of the other judges in the majority expressly endorsed the principle.[1]:7–8 Robert Heuston therefore suggests that case only supports the claims there can be duties in tort even if there is a contract; that manufacturers owe a duty of care to the ultimate consumers of their goods; and possibly that negligence is a separate tort. "No amount of posthumous citation can of itself transfer with retrospective effect a proposition from the status of obiter dictum [passing comments] to that of ratio decidendi."[1]:9
Subsequent events[edit]
The legal basis for the claim now settled, the case was returned to the Court of Session for a hearing scheduled for January 1933. In the hearing, Donoghue would have to prove the factual elements of the case that she had claimed, including that there had been a snail in the ginger beer as a result of Stevenson's negligence and that this snail had caused her illness.[7]:170 However, Stevenson died on 12 November 1932, aged 69.[7]:7 One year later, Stevenson's executors were listed as third-party defenders to the case. However, the claim was settled out of court in December 1934[15]:115 for, according to Leechman's son, £200 of the £500 originally claimed.[Note 5][3][7]:171–173
Donoghue had moved to 101 Maitland Street with her son, Henry, around February 1931; he moved out when he married in 1937, after which she moved to 156 Jamieson Street. She continued to work as a shop assistant. In February 1945, Donoghue divorced her husband, from whom she had separated in 1928 and who now had two sons by another woman, and reverted to using her maiden name.[7]:5–6[26]:7 She died of a heart attack on 19 March 1958, at the age of 59, in Gartloch Mental Hospital, where she had probably been staying for a short period of time as a result of mental illness.[26]:8 Although she is listed on her death certificate as May McAllister, she was by then commonly known as Mabel Hannah, having adopted her mother's maiden name and the first name of her daughter, who had died when she was eleven days old.[2][26]:5,8[27]:2
Stevenson's business was taken over by his widow, Mary, and his son, the third David Stevenson in the family. It became a limited company (David Stevenson (Beers and Minerals) Limited) on 1 July 1950; the family sold their shares in 1956. The Glen Lane manufacturing plant was demolished in the 1960s.[7]:7
The Wellmeadow Café, where the snail had been found, closed around 1931; the building was demolished in 1959. Minghella, its owner, subsequently became a labourer; he died on 20 March 1970.[7]:2–3
Neighbour principle[edit]
Lord Atkin's neighbour principle, that people must take reasonable care not to injure others who could foreseeably be affected by their action or inaction, was a response to a question a lawyer posed to Jesus: it is required that someone wanting to inherit eternal life must love their neighbour as themselves, but who is a person's neighbour? Jesus responded with the Parable of the Good Samaritan.[28]:212–213
"And Jesus answering said, A certain man went down from Jerusalem to Jericho, and fell among thieves, which stripped him of his raiment, and wounded him, and departed, leaving him half dead. And by chance there came down a certain priest that way: and when he saw him, he passed by on the other side. And likewise a Levite, when he was at the place, came and looked on him, and passed by on the other side. But a certain Samaritan, as he journeyed, came where he was: and when he saw him, he had compassion on him, and went to him, and bound up his wounds, pouring in oil and wine, and set him on his own beast, and brought him to an inn, and took care of him. And on the morrow when he departed, he took out two pence, and gave them to the host, and said unto him, Take care of him; and whatsoever thou spendest more, when I come again, I will repay thee."
"Which now of these three, thinkest thou, was neighbour unto him that fell among the thieves? And he [the lawyer] said, He that shewed mercy on him. Then said Jesus unto him, Go, and do thou likewise."[29]
The neighbour principle itself was first mentioned in relation to law by Francis Buller[Note 6] in An Introduction to the Law relative to Trials at Nisi Prius, which was printed in 1768.[28]:212
"Of Injuries arising from Negligence or Folly. Every man ought to take reasonable care that he does not injure his neighbour; therefore, wherever a man receives any hurt through the default of another, though the same were not wilful, yet if it be occasioned by negligence or folly, the law gives him an action to recover damages for the injury so sustained."[30]
In precedent, there was an obiter suggestion by Lord Esher in Heaven v Pender that "whenever one person is by circumstances placed in such a position with regard to another that every one of ordinary sense ... would at once recognise that if he did not use ordinary care and skill in his own conduct ... he would cause danger of injury to the person or property of the other, a duty arises to use ordinary care and skill to avoid such danger".[20]:509 However, this approach had been rejected by the two other judges in the Court of Appeal.[15]:107–108 Lord Esher's attempt to reintroduce the principle in further obiter remarks in Le Lievre v Gould,[31] in which he stated that Heaven only established that there may be a duty even if there is no contract and that this duty arose if there was proximity between the parties, was also unsuccessful.[15]:108–109[31]:497
Two cases from the New York Court of Appeals, Thomas v. Winchester[32] and MacPherson v. Buick Motor Co., were also influential in the formation of the neighbour principle.[7]:102 In Thomas, Thomas had purchased and administered belladonna to his wife after it was mislabelled by Winchester, the dealer, although not the seller, of the treatment as extract of dandelion. Thomas' wife became seriously ill as a consequence and Thomas successfully claimed in negligence; Winchester's behaviour had created an imminent danger which justified a finding of a duty of care.[7]:102–103
This principle was relied on in MacPherson, in which a car wheel collapsed, injuring MacPherson. The manufacturer was sued in negligence and the court held that manufacturers could owe their ultimate consumers a duty of care in limited circumstances.[7]:104–106[33]:414
"If the nature of a thing is such that it is reasonably certain to place life and limb in peril when negligently made, it is then a thing of danger. Its nature gives warning of the consequences to be expected. If to the element of danger there is added knowledge that the thing will be used by persons other than the purchaser, and used without new tests, then, irrespective of contract, the manufacturer of this thing of danger is under a duty to make it carefully ... If he is negligent, where danger is to be foreseen, a liability will follow."[21]:389–390
Lord Atkin used the concept of legal neighbours in an address to the University of Birmingham's Holdsworth Club on 9 May 1930, in which he commented that "the man who swears unto his neighbour and disappointeth him not is a person commended by the law of morality, and the Law enforces that by an action for breach of contract".[7]:111 On 28 October 1931, just over one month before he heard Donoghue, Lord Atkin also used the principle in relation to defamation, perjury, fraud and negligence in a lecture at King's College London.[28]:211
"[A man] is not to injure his neighbour by acts of negligence; and that certainly covers a very large field of the law. I doubt whether the whole law of tort could not be comprised in the golden maxim to do unto your neighbour as you would that he should do unto you."[Note 7][35]:30
Existence of the snail[edit]
In a speech scheduled to be delivered in May 1942 (although delayed by the Second World War), Lord Justice MacKinnon jokingly suggested that it had been proven that Donoghue did not find a snail in the bottle.
"To be quite candid, I detest that snail ... I think that [Lord Normand] did not reveal to you that when the law had been settled by the House of Lords, the case went back to Edinburgh to be tried on the facts. And at that trial it was found that there never was a snail in the bottle at all. That intruding gastropod was as much a legal fiction as the Casual Ejector."[7]:170–171
This allegation, suggests Chapman, established itself as a legal myth;[7]:172 it was repeated by Lord Justice Jenkins in a 1954 Court of Appeal practice note.[36]:1483 However, both MacKinnon and Jenkins were unaware that the trial had not gone ahead because of Stevenson's death – the events following the case were only published in response to the practice note.[37] As Donoghue's factual claims were therefore never tested in court, it is generally held that what happened in the Wellmeadow Café is not proven and will not be known for certain.[1]:2[3][4]:643[7]:172
The case was reviewed by Frederick Pollock in a 1933 edition of Law Quarterly Review, in which he commented that there was no doubt as to the importance of the decision and that "a notable step has been made in enlarging and clarifying our conception of a citizen's duty before the law ... not to turn dangerous or noxious things loose on the world".[38]:22 However, Donoghue otherwise attracted little attention; it was understood only as precedent that manufacturers were liable for injuries their goods cause their ultimate consumers rather than that there was a general principle of liability in negligence.[39]:61 The majority of the Court of Appeal (Lord Justice Cohen and Lord Justice Asquith) therefore held in Candler v Crane, Christmas & Co[40] that Donoghue had not affected tortious liability for negligent misstatement.[39]:61 This narrow understanding of Donoghue changed with the cases of Hedley Byrne v Heller[41] in 1963 and Home Office v Dorset Yacht Co[42] in 1970.[7]:116–117
Hedley Byrne v Heller[edit]
In Hedley Byrne, Hedley Byrne, advertising agents, had been indirectly informed by Heller & Partners Ltd, the bankers of Easipower, a company wishing to place a large order, that Easipower was a "respectably constituted company, considered good for its ordinary business engagements".[39]:62 Hedley Byrne relied on this information and subsequently lost over £17,000 when Easipower went into liquidation. The House of Lords held that Heller owed Hedley Byrne a duty of care as they used a special skill for Hedley Byrne and because this skill was relied upon by the company (although the negligence claim was unsuccessful due to a disclaimer of responsibility included in Heller's letter).[7]:127–128
The application of Donoghue was discussed and, while all the judges agreed that it would be taking Donoghue too far to immediately apply it to Hedley Byrne, Lord Devlin suggested that "what Lord Atkin did was to use his general conception [the neighbour principle] to open up a category of cases giving rise to a special duty" and that the case could incrementally expand the duty of care.[7]:128–129[41]:524–525
Home Office v Dorset Yacht Co[edit]
Home Office was the culmination of a movement from duties of care being found in specific circumstances to using the neighbour principle as a general duty of care.[43]:150 In Home Office, the Home Office had taken a group of boys from a borstal to Brownsea Island in Poole Harbour, where seven had escaped overnight and collided one yacht with another belonging to Dorset Yacht Company.[42]:1025 The company sued the Home Office for negligence and a preliminary issue, whether the Home Office owed a duty of care to Dorset Yacht Company, was found in the company's favour by both the High Court and the Court of Appeal. The case was appealed to the House of Lords, who held by a majority that the Home Office did owe a duty of care.[7]:129–130
Lord Reid, giving the leading judgment, rejected the argument that there was no precedent for the claim, instead acknowledging "a steady trend towards regarding the law of negligence as depending on principle so that, when a new point emerges, one should ask not whether it is covered by authority but whether recognised principles [from Donoghue] apply to it".[42]:1026–1027 Donoghue, he argued, should therefore be applied in almost all circumstances.[7]:132–133
"[Donoghue] may be regarded as a milestone, and the well-known passage in Lord Atkin's speech should I think be regarded as a statement of principle. It is not to be treated as if it were a statutory definition. It will require qualification in new circumstances. But I think that the time has come when we can and should say that it ought to apply unless there is some justification or valid explanation for its exclusion."[42]:1027
In the sole dissenting judgment, Viscount Dilhorne held that the neighbour principle could not have been intended to be applied in all circumstances and that it could only be used to determine to whom a duty of care is owed rather than if one exists.[42]:1043–1042 Judges, he opined, "are concerned not with what the law should be but with what it is. The absence of authority shows that no such duty [to Dorset Yacht Company] now exists. If there should be one, that is, in my view, a matter for the legislature and not for the courts".[42]:1045 Chapman comments "that this conclusion appeared ... distinctly quaint, old-fashioned and even untenable in the light of [Donoghue] shows how far the law had moved in the four decades which separated the two House of Lords decisions".[7]:134
Caparo Industries plc v Dickman[edit]
In 1990, the House of Lords revised Lord Atkin's "neighbour" principle to encompass public policy concerns articulated in Caparo Industries plc v Dickman.[44] The three-stage Caparo test for establishing a duty of care requires (i) foreseeability of damage, (ii) a relationship characterised by the law as one of proximity or neighbourhood and (iii) that the situation should be one in which the court considers it would be fair, just and reasonable that the law should impose a duty of given scope on one party for the benefit of the other. In other jurisdictions, such as New Zealand, there is now a two-part test for novel fact situations, where the establishment of a duty must be balanced against applicable policy matters.
As a metaphor[edit]
Today the far reaching changes of the decision for the law of torts is sufficiently well recognised that the case's name is used as a metaphor. For example, Barclays Bank v W J Simms [1980] 1 QB 677 has been described as "the Donoghue v Stevenson of restitution for mistake."[45] It has also been stated that Slade's Case "could be said to be the Donoghue v. Stevenson of contract."[46] Similarly, Jarvis v Swans Tours Ltd [1972] EWCA 8 has been called "the Donoghue v Stevenson of Tourism Law".[47]
In 1990, a pilgrimage to Paisley was organised by the Canadian Bar Association, the Faculty of Advocates and the Law Society of Scotland. This included a conference in Paisley Town Hall entitled "The Pilgrimage to Paisley: a Salute to Donoghue v Stevenson".[7]:173–174 A memorial commemorating the case was unveiled at the conference on the site of the former Wellmeadow Café[3][48] and a bench was added in 1992; both were replaced in 2012.[49]
In 1996, Justice Martin Taylor produced a documentary on the case: The Paisley Snail.[50]
- ^ Scots law practice was to include both the married and maiden names of female litigants in the form "maiden name (or married name)".[1]:1 The maiden name for Donoghue, however, has been listed as both "McAlister" and "M'Alister" in the law reports, even though she was born May McAllister.[2] "(Pauper)" indicates that Donoghue would have been unable to pay Stevenson's costs had she lost, but was granted an exemption from providing the required security.[3]
- ^ Although the friend was not named and has not been identified, she is referred to as "she" in the House of Lords judgment.[3][8]:605 It has been suggested that this information was provided by counsel during the hearing.[7]:5
- ^ Minghella's surname was incorrectly spelt as "Minchella" in law reports of Donoghue v Stevenson.[7]:2
- ^ Judgment was originally scheduled for 14 April, but was delayed for unknown reasons (although Alan Roger suggests that the delay gave Lord Macmillan time to rewrite his speech).[19]:247
- ^ It has also been reported that the case was settled for £100 (by William McBryde on the basis of information from Lord Macmillan, which he probably heard from Lord Normand, one of Stevenson's counsel) and £500 (by Thomas Donoghue, May Donoghue's grandson; however, this amount is likely to be an exaggeration as it was the amount Donoghue originally claimed).[7]:173[26]:9
- ^ Although authorship of An Introduction to the Law relative to Trials at Nisi Prius has also been attributed to Lord Bathurst.[7]:87
- ^ The original version of the Golden Maxim requires that "thou shalt not avenge, nor bear any grudge against the children of thy people, but thou shalt love thy neighbour as thyself."[28]:212[34]
- ^ a b c d e f Heuston, R. F. V. (1957). "Donoghue v. Stevenson in Retrospect". Modern Law Review. Wiley-Blackwell. 20 (1): 1–24. doi:10.1111/j.1468-2230.1957.tb00421.x. Retrieved 7 September 2012.
- ^ a b Taylor, Martin R. (2008). "The Most Famous Litigant". Donoghue v Stevenson Digital Resources. Scottish Council of Law Reporting. Retrieved 8 September 2012.
- ^ a b c d e f g h i j k l m n o p q r s Taylor, Martin R. (2004). "Mrs Donoghue's Journey". Donoghue v Stevenson Digital Resources. Scottish Council of Law Reporting. Retrieved 7 September 2012.
- ^ a b c Patten, Keith (2012). "Personal injury: Snail trail". New Law Journal. LexisNexis. 162 (7513): 643–645. Retrieved 2 September 2012.
- ^ Wylie, A. F. "The Paisley Snail MiniTrial". Donoghue v Stevenson Digital Resources. Scottish Council of Law Reporting. Retrieved 18 September 2012.
- ^ "The Paisley Snail". Paisley Online. Retrieved 18 September 2012.
- ^ a b c d e f g h i j k l m n o p q r s t u v w x y z aa ab ac ad ae af ag ah ai aj ak al am an ao ap aq ar as at au av aw ax ay az ba bb bc bd be bf bg bh bi bj bk bl bm Chapman, Matthew (2010). The Snail and the Ginger Beer. Great Britain: Wildy, Simmonds & Hill Publishing. ISBN 9780854900497. Retrieved 10 September 2012.
- ^ a b c d e Donoghue v Stevenson, 1932 AC 563 (UKHL 26 May 1932).
- ^ a b c Coleman, Clive (20 November 2009). "The legal case of the snail found in ginger beer". BBC News. Retrieved 10 September 2012.
- ^ a b c d e f g h Morton, Geo.; Milligan, W. R. Donoghue v Stevenson Appeal Papers: The Appellant's Case. Chapman, Watson & Co. Retrieved 11 September 2012.
- ^ Mullen v AG Barr & Co Ltd, 1929 SC 461 (ScotCS 20 March 1929).
- ^ a b c d e f g h i j k l m n o p q r s t Donoghue v Stevenson, 1932 SC (HL) 31 (UKHL 26 May 1932).
- ^ "UK £ relative values". Measuring Worth. Retrieved 11 September 2012.
- ^ Ansell v Waterhouse, 1817 M & S 385.
- ^ a b c d e Lunney, Mark; Oliphant, Ken (2010) [2000]. Tort Law: Text and Materials (4 ed.). Oxford University Press. ISBN 9780199571802.
- ^ Ferrari, Franco (1994). "Donoghue v. Stevenson's 60th Anniversary". Annual Survey of International & Comparative Law. Golden Gate University. 1 (1): 81–90. Retrieved 18 September 2012.
- ^ a b c d e Donoghue v Stevenson Appeal Papers: The Appendix (Opinions). Chapman, Watson & Co. Retrieved 15 September 2012.
- ^ a b c Normand, W. G.; Clyde, J. L. Donoghue v Stevenson Appeal Papers: The Respondent's Case. Hugh Patron & Sons Ltd. Retrieved 16 September 2012.
- ^ a b Rodger, Alan (April 1992). "Lord Macmillan's speech in Donoghue v Stevenson". Law Quarterly Review. Sweet & Maxwell. 108 (2): 236–259.
- ^ a b Heaven v Pender, 1883 11 QBD 503 (EWCA 1883).
- ^ a b MacPherson v. Buick Motor Co., 217 NY 382 (New York Court of Appeals 14 March 1916).
- ^ George v Skivington, 5 LR Ex 1 (Exchequer of Pleas 1869).
- ^ Smith, Roderick A (2008). "Railways and materials: synergetic progress" (PDF). Ironmaking and Steelmaking. Maney Publishing. 35 (7): 505–513. doi:10.1179/174328108X318888. Retrieved 20 October 2012.
- ^ Stone, Julius. The Province and Function of Law: Law as Logic, Justice, and Social Control, a Study in Jurisprudence., cited in Heuston, R. F. V. (1957). "Donoghue v. Stevenson in Retrospect". Modern Law Review. Wiley-Blackwell. 20 (1): 1–24 [6]. doi:10.1111/j.1468-2230.1957.tb00421.x. Retrieved 22 September 2012.
- ^ London Graving Dock Co. v. Horton, 1951 AC 737 (UKHL 9 May 1951).
- ^ a b c d Roger, Alan (1988). "Mrs Donoghue and Alfenus Varus". Current Legal Problems. Oxford University Press. 41: 1–22.
- ^ van Rijswijk, Honni (2010). "Mabel Hannah's Justice: a contextual re-reading of Donoghue v Stevenson". Public Space. UTSePress. 5: 1–26. Retrieved 26 September 2012.
- ^ a b c d Castle, Richard (2003). "Lord Atkin and the neighbour test: origins of the principles of negligence in Donoghue v Stevenson". Ecclesiastical Law Journal. Cambridge University Press. 7 (33): 210–214. doi:10.1017/s0956618x00005214.
- ^ Luke 10:30–37 (King James)
- ^ Buller, Francis (1817) [1768]. An Introduction to the Law relative to Trials at Nisi Prius. R Pheney and S Sweet. p. 24b. cited in Castle, Richard (2003). "Lord Atkin and the neighbour test: origins of the principles of negligence in Donoghue v Stevenson". Ecclesiastical Law Journal. Cambridge University Press. 7 (33): 210–214. doi:10.1017/s0956618x00005214.
- ^ a b Le Lievre v Gould, 1893 1 QB 491 (EWCA 3 February 1893).
- ^ Thomas v. Winchester, 6 NY 397 (New York Court of Appeals July 1852).
- ^ Linden, Allen M. (December 2002). "The American influence on Canadian tort law". University of California at Los Angeles Law Review. UCLA School of Law. 50 (2): 407–424.
- ^ Leviticus 19:18 (King James)
- ^ Lord Atkin (1932). "Law as an Educational Subject". Journal of the Society of Public Teachers of Law. The Society of Public Teachers of Law. 1932: 27–31.
- ^ Adler v Dickson, 1954 1 WLR 1482 (EWCA 17 December 1954).
- ^ Ashton-Cross, D. I. C. (October 1955). "Donoghue v Stevenson [1932] AC 562". Law Quarterly Review. Sweet & Maxwell. 71 (4): 472.
- ^ Pollock, Frederick (1933). "The Snail in the Bottle, and Thereafter". Law Quarterly Review. Sweet & Maxwell. 49 (1): 22–26.
- ^ a b c Buxton, Richard (2009). "How the common law gets made: Hedley Byrne and other cautionary tales". Law Quarterly Review. Sweet & Maxwell. 125 (1): 60–78.
- ^ Candler v Crane, Christmas & Co, 1951 2 KB 164 (EWCA 15 December 1950).
- ^ a b Hedley Byrne v Heller, 1964 AC 465 (UKHL 28 May 1963).
- ^ a b c d e f Home Office v Dorset Yacht Co, 1970 AC 1004 (UKHL 6 May 1970).
- ^ Smith, JC; Burns, Peter (1983). "Donoghue v. Stevenson: The Not so Golden Anniversary". Modern Law Review. Wiley-Blackwell. 46 (2): 147–163. doi:10.1111/j.1468-2230.1983.tb02511.x. Retrieved 27 September 2012.
- ^ Caparo Industries plc v Dickman, 1990 2 AC 605 (UKHL 8 February 1990).
- ^ Virgo, Graham (1999). The Principles of the Law of Restitution. Clarendon Press. p. 158. ISBN 0-19-876377-8.
- ^ Geoffrey Samuel. "The Reality of Contract in English Law". Tulsa Law Review.
- ^ Atherton, Trudie-Ann; Atherton, Trevor C. "The Legalities of Overbooking, Overcrowding, Delay and Disappointment: Lessons for the Sydney 2000 Olympics". New South Wales Law Journal.
- ^ a b Stephanie Todd (18 August 2003). "May owes fame to slug". BBC News. Retrieved 26 September 2012.
- ^ "New "snail bench" is in place". Paisley Daily Express. 20 April 2012. Retrieved 26 September 2012.
- ^ Stephanie Todd (18 August 2003). "Slug's trail to silver screen". BBC News. Retrieved 26 September 2012.


text:
'Manual of Love 3′ Trailer, With Robert De Niro and Monica Bellucci
Posted on Tuesday, January 4th, 2011 by Russ Fischer
When do a lot of people start to care about the third film in an Italian romance series? When one of the stories within features Robert De Niro as a divorced American professor romancing Monica Bellucci during a stay in Rome. We talked about Manual of Love 3 when the two actors were cast in the film, and now there's a trailer featuring their characters. See it after the break.
As in the first two installments of this series, the film is built out of a small collection of standalone stories, so don't worry about not having caught the previous installments. Neither of the first two films got theatrical distribution in the US, and I'm not sure they've ever been on DVD here. With Robert De Niro and Monica Bellucci involved in this one, however, there's a much better chance that it'll hit our shores. Italian audiences will see it on February 25.
Giovanni Veronesi directs this installment (he also directed the previous two films) which also stars Michele Placido, Laura Chiatti, Valeria Solarino, and Donatella Finocchiaro. I don't have very high hopes for the dramatic aspect of the film, but I can't argue that this one is pretty easy on the eyes. Nice to see De Niro throwing a punch, too. (And, yes, he'll be speaking some Italian in the movie as well.)
[Cinema Notizie via Bleeding Cool]
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accelerated nubus mac compatibility
i have a powermac 6100/60 with a newer g3 accelerator card.
as of 9f4 the system would hang when trying to load the accelerator extension during start-up. newer has told me that they would be releasing an os9 compatible update but checking their website does not turn up anything. does anyone have more news or have os9 gm running on a newer maxpower-g3 accelerated nubus powermac 61/71/8100? thanks in advance, piet |
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I was inspired to pick up this novel based on Rebecca's review. She was so enthusiastic about it that when I saw it just sitting there, untouched, at the library, I had to take it home and give it some love. I'm really glad I did because Rebecca was right – these stories are really, truly excellent.
The book is packed full of beautiful writing, of delicate stories that pull at your heart, draw you in, and don't allow you to forget them. The women in each of van den Berg's stories are searching for something, but there are so many more layers to what they are searching for than just the object itself. These stories are the kind that you need time to think about, they need to be examined and thought about and sat on for awhile. They are complicated and gorgeous and everything you hope from fiction.
I've said it before and I'll say it again – I think that it shows incredible talent as a writer to craft a short story that is both fully complete and one that I as a reader want to go on much longer than it does. Laura van den Berg has done exactly that with every story in this book – they were perfect as is, yet I wished I could have spent hundreds more pages with each of the women in the book.
I loved this one. If you love great writing, with quiet, contemplative stories and realistic characters, this is the book for you. There is a magic about this book that I can't quite explain. I would just encourage you to pick it up for yourself to see what I mean.


text:
I predict mayhem.
You remember the Duke Non-Rape Case, right? Well the woman at the center of that case is now free on bail.
She is accused of stabbing her boyfriend to death almost a year ago.
North Carolina has a law that says anyone on trial for something other than a capital offense is entitled to bail. That's because pre-trial confinement is not intended as a punishment, but merely as a way to make sure you show up for trial.
Sometimes that means letting the crazy people out. I guess that the same laws that protect this crazy woman also protect me.


text:
Journal of Correctional Health Care
The Journal of Correctional Health Care is the only national, peer-reviewed scientific journal to address correctional health care topics.
Published quarterly under the direction of editor John R. Miles, MPA, JCHC features original research, case studies, best practices, literature reviews and more to keep correctional health care professionals informed of important trends and developments. Topics addressed include clinical care, health services and support, personnel and staffing, ethical issues, medical records, quality improvement, risk management and medical-legal issues.
Continuing education credit for physicians, nurses, psychologists, CCHPs and others is available through a self-study exam in each issue.
Call for Papers: Please see Publishing Opportunities for potential topics of interest. Find author guidelines and submission instructions at the JCHC website at Sage Journals Online.
Call for Reviewers: If you would like to lend your expertise to help ensure that Journal articles are of the highest quality, consider becoming a reviewer.
Article Abstracts: All abstracts dating to Volume 1 are available at the JCHC website at Sage Journals Online.
Publisher Contact Info: Please address all subscription inquiries, orders, back issues, claims and renewals to:
Sage Publications
2455 Teller Road
Thousand Oaks, CA 91320
JCHC is published by Sage Publications, a well-regarded international publisher of journals, books and electronic media for the scholarly, educational and professional markets. This alliance benefits researchers and practitioners through expanded access to the best available research in this growing field. Together, NCCHC and Sage provide resources to enhance the practice of correctional medicine. Visit the JCHC archive at Sage Publications.
JCHC is indexed in the National Library of Medicine's PubMed database of biomedical citations and abstracts as well as PsycINFO, CINAHL and more.
Simplify Your CE!
The Journal of Correctional Health Care
Self-Study Exam is the simplest way to earn CE credits specific to correctional health care. The exam is available online exclusively, which means you will be able to take the test and print your certificate as soon as you finish reading the issue. To access the exam in its new online format, log in at orders.ncchc.org.
For detailed information about how to purchase and access the exam, download these step-by-step instructions.


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Nuts & Bolts - January 2014
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Thursday, September 04, 2008
I gave in and I'm watching the new 90210. I can't decide if it's awesome or if it's a disaster. But Kelly Taylor! Weird weird weird that Lori Laughlin is playing the Cindy Walsh character. Am I old?
OK and I am not admitting anything here but maybe I watched ten episodes of The OC over the weekend too.
7 comments:
- Jane said...
It's a good thing to admit, I have been a total TV slut lately, too! I'm going to check out that new 90210 eventually, seems weird - I'll be expecting all the original characters!
- Zach said...
Let me help... it's a disaster. I saw the first 3 minutes of it, and that was plenty. It's not going to hold a candle to the old one's early days (pre-soap-opera). Not even to the old one's later days. Bad bad bad.
Or maybe it's just me. - 9:16 PM
- Betsy said...
I've been waiting for this moment all my life.
- Ashley said...
I so love that you watched this, because so did I!
(And I have watched the OC recently as well. Maybe this 90210 will kind of fill the void.) - 10:58 PM
- jaredean said...
as one who had a little baseball like trading card of Kelly Taylor stuck to my car speedometer all through the late 80's/90's, i feel i'm qualified to say it was VERY strange seeing her...she still has that "sweetness" about her that I loved from the original, but it is almost like watching her mom act like she did...i can't fit the person with her being all growed up...
as far as the show is concerned - i'm not gonna lie - i will give it a chance, but hated the whole scene in the truck at the beginning...i read an interview with Shannen/Jennie about it and they were both pretty shocked/annoyed about it it seemed... - 12:32 AM
- TUG said...
I TiVoed it and will probably watch it tonight. I hope it's good.
- RO said...
OK What? The new 90210? Are you kidding me? Puh-lease. I've got to agree with Zach. There is no way you can bring that one back... successfully.
Does it still have the same theme song??? - 8:57 PM


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text:
Adobe Photoshop is a popular graphics program that allows the artist to draw, paint and design digitally. The many features offered in Photoshop assist in creating artwork that is comparable to traditional art styles. Making a digital cityscape is a great way to turn a city that exists only in your mind into reality. Use personal photographs as a template and a few of Photoshop's features and tools to create your one-of-a-kind city masterpiece.
- Skill level:
- Moderate
Other People Are Reading
Things you need
- Digital camera with USB adaptor
- Drawing tablet
Show More
- 1
Take photographs of buildings and skylines. One of the easiest ways to make a successful fantasy city is to borrow from images based in reality. Then take photographs of the sky at various times of day, such as morning, afternoon, sunset and night. Capture images of a road or other ground area. Plug the camera into the computer with the USB adaptor.
- 2
Open "My Computer" and double-click on the digital camera icon to view the photographs. Choose the photographs you want to use, selecting several building pictures, one sky and one ground photo. Hold down "Ctrl" while clicking to select multiple photographs. Then, click-drag the photos to the desktop. Close "My Computer" and unplug the camera.
- 3
Open Photoshop, then go to File > New to create a new image. Choose the desired size of the canvas. Make the resolution at least 300 dots per inch (dpi) for the best quality. Hit "OK."
- 1
Go to File > Place and choose one of the building photographs. Hit "OK." Repeat this process for each building photograph. Look at the Layers palette. Each photograph will have its own layer. Hit the eyeball icon to make all of the photographs invisible except one.
- 2
Select the "Polygonal Lasso" tool. Outline the building and other features in the first photograph you want to keep. Then, go to Select > Inverse. Hit "Ctrl+X" to remove the unwanted material.
- 3
Hit the eyeball icon next to the outlined photograph's layer to make it invisible. Turn on the eyeball icon for another photograph and repeat Step 2. Repeat Steps 2 and 3 for each building photograph and the picture of the road or other ground surface.
- 4
Make all building layers visible by turning on the eyeball icon next to each photograph in the Layers palette. Arrange the buildings on the canvas so that they make a collage-like city. Arrange layers by click-dragging them on the Layers palette to make buildings overlap one another.
- 5
Make the sky layer visible and arrange it so that it is behind all of the building layers. Hit "Ctrl+A" to select the entire sky photograph and hit "Ctrl+T" to activate the "Transform" tool. Click-drag one of the corners of the sky photograph while holding the "Shift" key to increase the size. Make the sky fills the entire background behind the buildings.
- 6
Hit the eyeball icon next to the ground photograph layer. Move the ground so that it sits under the buildings. Adjust the size by hitting "Ctrl+A" to select, then "Ctrl+T" to Transform.
- 1
Go to Layer > New > Layer to make a new layer. Label the layer "Outlines."
- 2
Select the "Paintbrush" tool. Choose a hard, round brush from the "Brush" drop-down at the top of the screen and adjust the size so the brush is relatively small. Outline the buildings, including windows, doors, grommets and other details. Make straight lines with the Paintbrush tool by holding down the "Shift" key while drawing. Outline over the ground area as well.
- 3
Go to Layer > New > Layer and label it "Color." Arrange the "Color" layer so that it is behind the "Outlines" layer, but in front of the photographs. Increase the size of the brush, then colour in the buildings and road, much like a colouring book. Change colours by double-clicking on the "Set Foreground Color" swatch in Tools palette. Layer several colours over each other for more depth. Click on the "Brush" drop-down, click the small arrow and select "Natural Brushes" to layer colours with rough-edged brush.
- 4
Make a new layer and label it "Sky Color." Select a large, round, soft brush and begin colouring over the sky photograph. Use the same colours as in the sky, or choose different colours to blend together. Make sure to keep the light source the same.
- 1
Create a new layer and label it "Shadows." Choose a black colour swatch. Click the "Opacity" drop-down at the top of the screen and lower the opacity to about 30 per cent. Change the Brush to a mid-sized, soft, round brush.
- 2
Shade in the areas with the Paintbrush tool. Look at the sky background to determine where the light source is coming from. Make areas darker by overlapping paint strokes.
- 3
Make a new layer and label it "Highlights." Choose a white colour swatch and adjust the opacity to about 30 per cent. Keep the brush soft and round.
- 4
Create highlights over the building colour. Keep the light source in mind. Make straight highlight lines by holding down the "Shift" key while drawing.
- 5
Select the "Smudge" tool and choose a soft, round brush. On the "Color," "Sky Color," "Shadows" and "Highlights" layers, smudge the paint so that it blends together. Hit the eyeball icons next to the photographic layers to make them invisible. Fill in any details or white spots in the various layers.
Tips and warnings
- Also download photographic references from the Internet.


text:
Use Unbound for Local DNS Resolution on Debian 6 (Squeeze)
Updated by Linode
This guide has been deprecated and is no longer being maintained.
In the default configuration, Linode systems are configured to query DNS resolvers provided by Linode. If you don't want to use a third party DNS service on your system, you may consider running an independent DNS resolving and caching service such as Unbound DNS resolver. Unbound is easy to install and configure, which makes it an ideal resolver for simple deployments.
If you are unfamiliar with DNS, you may want to consider our introduction to the DNS system. If you simply need to configure DNS services for your domain, you may want to consider using Linode's DNS manager. If you only need to modify the behavior of DNS for a small group of systems, consider using /etc/hosts to provide this functionality.
Set the Hostname
Before you begin installing and configuring the components described in this guide, please make sure you've followed our instructions for setting your hostname. Issue the following commands to make sure it is set properly:
1 2 | hostname hostname -f |
Install Unbound
Make sure your package repositories and installed programs are up to date by issuing the following commands:
1 2 | apt-get update apt-get upgrade --show-upgraded |
To install the packages for Unbound, issue the following command:
1 | apt-get install unbound |
This will install and start the Unbound server on your system. Note that the Unbound configuration file will be located at /etc/unbound/unbound.conf
Configure Unbound
Configure Unbound Interfaces
In the default configuration, Unbound will only listen for requests on the local interface. If you want Unbound to attach to additional interfaces, these interfaces must be configured manually. Possible interfaces include the public interface or the private networking interface. Specify those IP addresses after the server:
directive in the following format:
- server:
- interface: 220.127.116.11 interface: 192.168.3.105
Modify these
directives to conform with the actual addresses assigned to your Linode. In this example, these directives would configure Unbound to listen for requests on the publicly accessible address188.8.131.52
, and on the internal or private network address of192.168.3.105
Control Access to your Unbound Instance
By default, Unbound will only listen for and respond to requests for DNS queries on the localhost interface (i.e. from 127.0.0.1). Unbound must be configured to listen for requests on a given interface, as above, and be configured to allow requests from a given IP address before it can successfully provide DNS services. Insert lines modeled on the following example into the unbound.conf
file, following the server:
- server:
- access-control: 192.168.0.0/16 allow access-control: 220.127.116.11/32 allow
access-control: 184.108.40.206/24 deny access-control: 220.127.116.11/8 refuse
Unbound uses CIDR notation to control access to the DNS resolver. This allows you to permit or refuse DNS traffic to large or small groups of IP addresses in a simple and clear syntax. In the above example, you can see a number of different access control approaches.
In the first example, we allow all requests from the 192.168.0.0/16
net block, or all IP addresses beginning with 192.168.
, which corresponds to the local "private" network. Specify this if you have private networking configured on your Linode and would like to allow multiple Linodes in the same datacenter to resolve domain addresses using your server.
In the second example, we allow all requests from the IP address 126.96.36.199
. To specify specific IP addresses in CIDR notation, simply append /32
to the desired IP address. The remaining examples force Unbound to block access from two netblocks, or all IP addresses that begin with 12.34.56.
and the entire 34.
prefix. Specifying deny
causes Unbound to drop all traffic from this address or addresses. By contrast, the refuse
option returns an error message in response to requests from blocked sources.
To summarize, there are three possible access control behaviors:
- Unbound can
traffic. This means that requests will be filled when they originate from IP addresses belonging to specified netblocks. - Unbound can
traffic. In this case, Unbound will simply drop traffic and offer no error message. - Unbound can
traffic. This causes Unbound to send an error message in response to requests from disallowed sources.
When you have configured your Unbound server to acceptable parameters, issue the following command to restart Unbound:
1 | /etc/init.d/unbound restart |
Unbound is now active and functional.
Configure your System to Resolve DNS Using your Unbound Instance
Before you can begin using your Unbound instance to resolve DNS queries, you need to configure your /etc/resolv.conf
file to point to the new resolver. You can remove all existing lines from this file or comment them by prepending hash marks (e.g. #
) to every line.
Important: By default, Linodes use DHCP to assign networking settings, including the public IP address and DNS resolvers. For any systems that you intend to use a custom resolver with, you must follow our instructions for static networking. This will prevent your /etc/resolv.conf
file getting overwritten with the default resolvers after a system reboot.
If you're accessing your Unbound instance over the local interface, make sure your /etc/resolv.conf
resembles the following:
nameserver 127.0.0.1
If you're accessing your Unbound instance from another machine, modify the address to reflect the address on which Unbound is listening for requests. Ensure that Unbound's access control rules permit access from all clients that will be making requests to the server. If your Unbound instance is accessible on the public network, you can configure any machine on the Internet to resolve DNS using your Linode. While most Linux-based systems use the /etc/resolv.conf
method for configuring DNS resolution, consult your operating system's networking configuration interface to reconfigure your DNS settings.
More Information
You may wish to consult the following resources for additional information on this topic. While these are provided in the hope that they will be useful, please note that we cannot vouch for the accuracy or timeliness of externally hosted materials.
- Unbound Home Page
- Wikipedia article on Classless Interdomain Routing
- DNS Fundamentals
- Linode Manager for DNS
This guide is published under a CC BY-ND 4.0 license.


text:
Will the Bankruptcy Reform Work? An Empirical Analysis of Financial Reorganization in Canada
The new Bankruptcy Act has two clear aims: (i) to increase the number of firms opting for reorganization over liquidation, and (ii) to increase protection for wage earners at bankrupt firms. The paper examines a unique micro data set of 338 commercial financial reorganization proposals filed in Canada during the period 1978-87 to determine whether these aims are likely to be met. Estimates from a logit model of reorganization plan acceptance indicate that the new Act will result in a roughly 7 percentage point increase in the number of reorganization plans that creditors accept. Everything else being equal, these changes are estimated to save about 120 jobs per year in Canada. Thus, while the new Act will increase the rate at which creditors accept reorganization plans, the actual impact of a higher acceptance rate will be quite small.
If you experience problems downloading a file, check if you have the proper application to view it first. In case of further problems read the IDEAS help page. Note that these files are not on the IDEAS site. Please be patient as the files may be large.
As the access to this document is restricted, you may want to look for a different version under "Related research" (further below) or search for a different version of it.
Volume (Year): 20 (1994)
Issue (Month): 3 (September)
Pages: 265-277
Handle: | RePEc:cpp:issued:v:20:y:1994:i:3:p:265-277 |
Contact details of provider: | Postal: University of Toronto Press Journals Division 5201 Dufferin Street Toronto, Ontario, Canada M3H 5T8 Web page: http://economics.ca/cpp/ Email: |
Order Information: | Web: http://www.utpjournals.com/cpp/ Email: |
References listed on IDEAS
Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.:
- Jocelyn Martel, 1991. "Bankruptcy Law and the Canadian Experience: An Economic Appraisal," Canadian Public Policy, University of Toronto Press, vol. 17(1), pages 52-63, March.
- Hoshi, Takeo & Kashyap, Anil & Scharfstein, David, 1990.
"The role of banks in reducing the costs of financial distress in Japan,"
Journal of Financial Economics,
Elsevier, vol. 27(1), pages 67-88, September.
- Takeo Hoshi & Anil Kashyap & David Scharfstein, 1990. "The Role of Banks in Reducing the Costs of Financial Distress in Japan," NBER Working Papers 3435, National Bureau of Economic Research, Inc.
- Gunderson, Morley & Kervin, John & Reid, Frank, 1986. "Logit Estimates of Strike Incidence from Canadian Contract Data," Journal of Labor Economics, University of Chicago Press, vol. 4(2), pages 257-276, April.
- White, Michelle J, 1989. "The Corporate Bankruptcy Decision," Journal of Economic Perspectives, American Economic Association, vol. 3(2), pages 129-151, Spring.
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text:
Hello MyIGN and welcome to 2014! This should've been my first blog of the year, but I ran into a problem yesterday that needed to be addressed and I've posted that blog here in case you're interested. But yesterday's blog isn't what this blog is about: it's about what I have planned for this year and whether or not I'll accomplish them this year! Hell, I don't even know if I'll look at this blog next year and say I've accomplished either most of my goals or all of my goals. This isn't a New Years Resolution thing, but even if I had made a New Years Resolution, it would be pretty small anyway.
Knowing me, I have the tendency to do long blogs; this one will be no different. As a matter of fact, since we're on the subject, allow me to explain the first thing I plan on doing this year...
When I started to come back to blogging a couple years ago, I went all out crazy. I didn't think anybody would read any of my blogs, so I left no splits for readers' conveniences. Last year, I continued the split blogs, but there was only one problem: participation levels decreased the more parts I've posted. It didn't make sense to me back then and it doesn't make sense to me now. If I'm going to make this thing make sense, then I need to let go of doing split blogs and post the whole thing in full, readers be damned!
This will be a way for me to release the whole thing and not split things at once and leave me more room to create more blogs. I've been lacking the motivation to blog lately and the split blogs have been a culprit of it. If I ever do split blogs this year, it will be a rarity, but for now, starting this blog, there will be no more splits. Reader beware!
I know there might be some of you who aren't aware of this, but I will become a Power Ranger again this year. Last year, to celebrate the 20 year anniversary of Power Rangers, I decided to cosplay as the Blue Mighty Morphin Power Ranger. To make a long story short, I decided to cosplay as him because he was my favorite Power Ranger as a kid as I could relate to him and the last time I dressed up as him, I was wearing a plastic costume and it got ripped bad. I wanted to remedy that Halloween and I've succeeded. The smiles on kids' faces and the various picture requests made me want to do it all over again and I'm going to do exactly that.
I will cosplay as a new Power Ranger this year along with returning the Blue Power Ranger and I'm in the process of getting it completed. As of right now, I've received a couple of items for my cosplay and my helmet is currently being worked on at the moment. I'll buy the costume sometime this week, hopefully I'll find somebody who'll make the glove cuffs and boot cuffs and the weapon should come my way either late next month or sometime in March. Either way, I'll be ready come C2E2 2014 which will be April 25-27, 2014.
Last year in July, I was finally able to hit a milestone: go one year without having to reinstall Windows. To finish off the year, I went through all of 2013 without having to reinstall Windows once. Well actually that's a lie: I did have to reinstall Windows 7 once. But the thing is it wasn't for my PC: it was for my brother's brand new PC. I have no idea how much his new customized PC costs, but all I know is that when you use Intel and NVIDIA, it's bound to cost over $1,000 and we're not even counting his highly expensive 16GB memory (4 x 4GB DDR3 chips) nor his SSD drive. Seeing that has gotten me a little bit motivated to build my own PC, except I'm not going to go the expensive route like he did.
Since I messed up my AMD Athlon II X3 450, that ruled Socket FM2+ out of the equation, leaving me to stick with AM3+. I'm going to go the ATX route as I've discovered that my GPU will benefit greatly with room for the fan as opposed to microATX, which is what I'm currently using. I'll get 8GBs of DDR3 memory (2 x 4GB chips) as my brother needs 16GBs way more than I do. I'll get a case that has top USB slots as it'll be easier for me to plug my Wi-Fi adapter and not have it lose balance because of the 5dbi antenna that's attached to it. I'll also get either a 2TB or a 3TB hard drive as 1TB is starting to become too small for me. That's where I'll reinstall Windows 7 and I'll install it in AHCI mode instead of RAID as I'm officially done with it. With my as-of-now current PC, I don't know what to do with it once it's all said and done; we'll see in the future!
Each year for the past couple of years, I've posted a rant blog towards MyIGN for two reasons that are ironic with each other. The first year, I got mad at MyIGN for the lack of attention I was getting and last year, I got mad at IGN for the many negative attention I was getting. Knowing a trifecta is bound to happen, I could throw another rage blog by the end of May at the latest. What it will be about is anybody's guess. Out of all things listed here, this one is the most likely thing to fail, so I shouldn't have even bothered to put this on my list.
Why did I put it here? Because sometimes, I like to challenge myself. Of course, I'll be pissed if I fail the challenge, but it will be a good way to try to test my own patience and try to control my emotions on here towards the community. Lord knows we don't need Darkblood999 to post another rage blog of mines on her timeline like the last rage blog (and nobody outside those I'm following can comment on there)! Can I keep that from happening? Will some MyIGNers or non-MyIGNers try to coax me into doing another rage blog just because they want to see me fail in fulfilling this plan of mine for 2014? We got 12 months to find out!
I had some blogs I wanted to post last year, but after the rage blog of 2013, I lost pretty much all motivation to post the blogs I wanted to post last year. To be honest, it also caused me to lose motivation to get involved with the MyIGN community and from the look of things, MyIGN was a boring community in general the rest of the year; I guess MyIGN unintentionally revolves around me! I had some exciting blogs (and maybe controversial) I wanted to post and they were thought-insightful too, but I just didn't post them last year. I'm hopeful that I can post them all this year and here's a list of blogs I wanted to post, along with a brief description on what they're about...
I can't do one blog without the other, so this was a series I wanted to do that looked into games that I thought were sequels done wrong and sequels done right. To make things fair, I only limited my choices based on games I've played, so Mass Effect 3 isn't on either list Arieces!
I've been to two C2E2 events and two Wizard World Chicago events and both times C2E2 was better. As a matter of fact, last year's Wizard World Chicago was worse than the previous year's Wizard World Chicago, which makes it extremely hard for me to decide whether I should go to this year's event or not. On here, I mention everything I could remember about why I felt C2E2 is the better attraction, although many parts will have to be updated since some changes were made since the last time I typed it out.
Out of all the 2013 blogs I never posted on here, this one was my absolute favorite. This blog was done on the heels of Anita Sarkeesian releasing here Damsel in Distress Part 1 video and since it was posted during the time I couldn't blog because I sacrificed blogging for Lent, I typed it out and waited until after my C2E2 blogs were over before I could post the blog. I even mentioned on one of my blogs that I was going to post it in the future; I thought the future meant posting it sometime in 2013.
My Definition of a Damsel in Distress was going to be the very first blog I would post after Pics of Dat Ass @ C2E2 2013 just to show that I love women and I respect women contrary to what people might think, but because MyIGN couldn't follow my rules, I lost all motivation to post the My Definition of a Damsel in Distress blog. If I don't post all my missing 2013 blogs this year, I want to make sure this blog is one of the blogs that does show up in 2014.
MY INTRO BLOG TO MyIGN HAD I NOT JOINED CLUB IGN
There was at some point last year that a week was pretty much dedicated to MyIGN reading everybody's first blogs. My first blog was done back in April of 2006 when the blogging community was blogs.ign.com or rather Club IGN. Things were different back then and so unfair too, which reminds me: I should do a blog about that to anybody who weren't around Club IGN, but joined the blogging community since the formation of MyIGN. You guys are probably going to love it too!
Seeing some new members posting their first blog mentioning who they are, where they're from, how old they were, what their favorite games are and what they would like to do with their blogs in the future, I thought it would be interesting if I had done the same thing if I was to pretend that I never joined Club IGN, which is how I feel every time I think about the horribleness that is Club IGN. I'll have to update it a little bit since I had gotten a year older since the last time I typed that blog.
percy99's PC Building Wiki
I'm sorry, but people who do blogs or articles talking about how to build your own PC have left many details out. The most common one: excluding AMD on both GPU and CPU. It's like no matter how hard they try, they can't let their own bias get in the way of helping those who have no idea what to do. My blog was going to be the blog that corrects those mistakes and offer help on practically everything.
This blog would be so long that I would have no choice but to break my first plan and split the blog into parts. It would also probably be the split blog I wouldn't care if anybody commented on them or not as this blog's only purpose is to inform those who aren't into building PCs, but want to build their own PC and need some steps to take them in the right direction.
XBOX ONE vs. PS4 DEBATE
This is the last blog of 2013 I had done where I would argue with myself. This blog was a great blog in my opinion as I wasn't afraid to throw punches towards Microsoft and Sony with their systems. This one didn't get posted because of one reason and one reason only: Microsoft pulled an Xbox 180 before I could even post the blog! With that happening, it meant that my entire debate was useless and pointless, but the thing is I don't want this blog to go to waste. It should be fun to see how I could side with Microsoft and their ridiculous DRM scheme at the time; I just hope the debate doesn't give Microsoft any ideas.
So, those are the blogs I wanted to get done, and I would like to do something that will probably end in failure: I want you guys to vote for which blog you want me to blog about first. The blog that gets the most votes will be the blog I'll release first and the rest will go by total votes too. If nobody votes, then I'll get to choose which one will get posted first and the rest later.
I picked up the PSOne in 1997. I picked up the PS2 in 2002. I picked up the PS3 in 2008. Do you guys see the pattern here? In case you don't know, here's the pattern: I've picked up a PlayStation system in the second year of its existence! If that keeps up, then that means I will pick up a PS4 next year! I want to stop that trend and get the PS4 this year instead of next year.
The first half of the year's not looking so good as that's where I'll spend my money on cosplay and future computer parts. If I'm totally unlucky, then games as well. The second half is where I have the best chance to getting a PS4, especially if I decide to take a pass at Wizard World Chicago 2014 and Power Morphicon 4. But, I refuse to get a PS4 without getting a 1TB 7200RPM hard drive as 5400RPM is too slow, no matter how fast your system is. I'm experiencing it now with the PS3 and I hope to continue it with the PS4.
This is the 3rd year that I've been working out and so far, it's amazing. One thing I've learned about this exercise regime is that there is never a day where your body doesn't want to get into lazy mode. Even though I'm working out now out of habit instead of focusing on a future cosplay, I don't want to go back to how I looked at the start of 2012. I've worked so damn hard to get the body that I got today and I don't want to lose that figure and look ridiculous in my Blue Ranger or my future Ranger cosplay.
One way how I can inspire myself not to slack off is by looking at all my Comic Con photos from Wizard World Chicago 2012 to my latest photo where I'm wearing something I can't reveal just yet. I want to look just as good or even better than those pictures, so that'll be something to keep me going and I hope to stay that way for the entire 2014 year. And that concludes my plans!
Are there any plans you want to do for this year? Do you think I can do all the things I want to accomplish this year this year? Which unposted blogs do you think I should post first? I'll let you answer those questions for me and until next time,


text:
Cars Trucks
Fixes Reviews
Transmissions with variable line-fluid pressure (VLP) frequently adjust their internal fluid pressure to reduce parasitic losses from the pump and hydraulic system, increasing gas mileage and lengthening the transmission lifespan.
VLP was phased in throughout the Chrysler four-speed automatics, both car and truck versions, in model-year 2006 (actual production started in late 2005). In the first year, rear wheel drive automatics connected to the 2.7 liter and 3.7 liter V6 engines gained it; in 2007, all Chrysler transmissions used it.
The first related patent Allpar could find was issued to DaimlerChrysler (Auburn Hills, indicating Chrysler Group development) — patent 6,471,613 was issued for a regulator valve system with a variable force solenoid.
The inventors, Valentin Botosan and Berthold Martin, wrote that the ideal was to maintain a lower transmission fluid pressure without letting the clutch slip, because it increases both gas mileage and the transmission's lifespan. However, increased pressure is needed in low gears or under load, for better clutch-holding capability.
Choosing the desired line pressure was based on the output of input and output speed sensors, which combined provided an indication of clutch slip. The powertrain control module (engine computer) considered this information as well as the throttle angle and engine torque, so that under higher torque, higher throttle (indicating a forthcoming increase in torque), or clutch slip, pressure could be quickly raised.
In February 2006, Botosan and Martin filed another patent, this time for a revised hydraulic control system, still relying on a line pressure regulating valve activated by a solenoid.
Their initial work was refined over time, and June 2006, three other Chrysler engineers filed a patent for adaptive fluid pressure control. Weijia Cui, Gary K. Lowe, and Daniel H. Black set up a system which also considered transmission fluid temperature, engine speed, and battery voltage, so that fluid pressures would be set according to a table (open loop) or feedback (closed loop) depending on conditions. This refinement was most likely developed based on durability and driveability feedback.
Is there an error on this page? Let us know and you could win a prize!
More Mopar Car and Truck News


text:
Zimbabwe Stock Market Regulator Balks at Plan to Force Bank IPOs
Matthew HillZimbabwe's stock exchange regulator said a planned law to force banks to sell their shares on the local bourse will only work once the nation has addressed issues holding back equity valuations.
"Forcing companies to list, in my view, I don't think is the best," Tafadzwa Chinamo, chief executive officer of the Securities Exchange Commission of Zimbabwe, said in an interview today in Lusaka, the capital of neighboring Zambia. "If they're forced to go to the market now, they will feel like they're selling their assets for close to nothing."
Legislation requiring banks operating in the southern African nation to float shares on the Zimbabwe Stock Exchange within two years may come into effect on May 24, the state-controlled Herald newspaper reported today, citing Finance Minister Tendai Biti. The law will help banks raise capital, the Harare-based newspaper cited Biti as saying.
Once the government and the bourse have addressed factors affecting low valuations of listed companies, banks will consider listing as "a no-brainer," Chinamo said. These include holding national elections, introducing centralized script handling and automating share trading, said Chinamo, adding that he expects all of this to happen this year.
Zimbabwe, which holds the second-biggest chrome and platinum reserves after South Africa, plans to force banks to sell or cede 51 percent of their operations to black Zimbabweans or the government. Companies including Barclays Plc, Standard Chartered Plc, South Africa's Standard Bank Group Ltd. and Nedbank Group Ltd. have operations in the country.


text:
It may seem that I've vanished, but I have not. I haven't blogged for a week, which might actually be a record. This has been a very busy household, with guests and preparations for school, as much work as I could fit in and over it all, lots of not-deserty clouds, not-deserty humidity and very deserty, crushing temperatures.
Orion starts kindergarten tomorrow. Soon after I'll be back in the studio, and back here (more often.)
I used to stress over pauses. I don't anymore. The work will be what it is, and generally the stuff that happens in between finds its way in there too.
Thank you, as always, for checking in.
Monday, September 03, 2007
4 comments:
- Rubius said...
This is the time of year for crazy busy-ness.... boy do I understand waht you mean and I have no kids to send off to school. I hope Orion has a great day tomorrow.
- jordan's mom said...
Hooray for Orion!
What a wonderful adventure you are beginning (I'm counting on Mommy to read you this message...)
Have Mommy take your first-day-of-school picture for us. - 11:57 AM
- Carl V. said...
Sometimes I wish there were more pauses built in, it all seems to go by in way to big of a rush.
- Dan Guy said...
Today was Xander's first day of first grade. He seems to have survived it unscathed. Only time will tell. One day at a time!
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