Tuesday, December 31, 2019

The Silent Way - 6367 Words

I. The Silent Way On the years of 1960s’ the Audiolingual Method was under a strong challenge in the form of the Cognitive Code and an educational trend known as Discovery Learning. These concepts most directly challenged the idea that language learning was all about mimicry and good habit-formation. An emphasis on human cognition in language learning addressed issues such as learners being more responsible for their own learning - formulating independent hypotheses about the rules of the target language and testing those hypotheses by applying them and realizing errors. When students create their own sets of meaningful language rules and concepts and then test them out, they are clearly learning through a discovery/exploratory†¦show more content†¦Language learning is usually seen as a problem solving activity to be engaged in by the students both independently and as a group, and the teacher needs to stay out of the way† in the process as much as possible. It has been stated that the Silent Way is also well known for its common use of small color rods of varying length (cuisenaire rods) and color coded word charts depicting pronunciation values, vocabulary and grammatical paradigms. It is a unique method and the first of its kind to really concentrate on cognitive principles in language learning. We can state that the benefits of this method are that the students arrive to produce independent and experimental language activities at the same time that develop their own interior criteria for the accuracy. For sure, the students would like this method. B. Background and Principles Caleb Gattegno, a mathematician and psychologist, developed the Silent Way approach. To give an exact description of how the lessons are structured is a little complicated. It has been found that Gattegno himself points out that â€Å"it is not a structural or a linguistic or a direct (or any other) method of teaching languages. Basically, one can say that the teacher provides very little verbal input for most of the lesson s/he is indeed silent, as we have said. Through body language and gestures, the teacher encourages his/her students to participate actively in the learning process. It has been said that theShow MoreRelatedThe Silent Cinema872 Words   |  4 PagesAs Richard Abel observes, â€Å"The materiality of silent cinema†¦has become so unfamiliar to us, so different from that of our own cinema in the late twentieth century† that it is difficult to view silent film as anything but anachronistic (4). However, with 2011’s The Artist—an homage to silent film—winning Best Picture at the Academy Awards, it may be worthwhile to examine the nature and appeal of silent film. In a way, silent film does something that the modern day special effects spectaculars doRead MoreSilent Night840 Words   |  4 PagesSilent Night Many people look at the Holocaust in ways that are indescribable. They talk about it but do not believe that something so tragic could happen in this world. With the book Night, Elie Wiesel takes readers on a path to show them the true story of what it really was. With so many in-depth details, Wiesel describes a horrific place filled with hatred and fear that not one person could likely survive today. He describes just how the concentration camps were and how most people only wishedRead MoreZabriskie Point by Michelangelo Antonioni1757 Words   |  7 PagesPhoenix. Daria is going to Phoenix to meet her boss at his desert house. While traveling Daria is also searching for a man from Los Angeles that helps emotionally distributed children. She never finds this man, but runs into some children along the way and continues driving. Mark spots Daria driving and begins to continuously fly dangerously close to her car. Finally, a confused Daria stops her car, runs out, and lies in the sand; and Mark meets Daria on the ground. Mark asks Daria for a ride soRead MoreAn Age Of Inclusion : The Silent Movie Era903 Words   |  4 Pages An Age of Inclusion: The Silent Movie Era in Deaf History â€Å"[Charlie Chaplin] is able both to make himself understood and to understand me. He is an artist† (Schuchman, 1988, p. 24). This was told by Granville Redmond, a prominent deaf actor and painter in Hollywood during the silent movie era, with the height of his career mainly in the late 1910s. He was a close friend to Chaplin, acting in multiple movies with him and being a documented member of Chaplin’s close group of friends. This descriptionRead MoreSilent Spring, By Rachel Carson1711 Words   |  7 Pagescausing a change and reshaping a perception. Rachel Carson, best known as the author of Silent Spring, is said to be one of the most influential women in environmental history, according to her fellow authors and conservationists. Carson has been recognized worldwide in history and science books for her campaign against DDT, her work as a conservationist, and her efforts to change society’s view of the planet. In Silent Spring Ms. Carson brought the adverse effects of a toxic commonly, used pesticideRead MoreMiriam Meyerhoff Doing And Silence Summary731 Words   |  3 Pageslinguist, whenever a person is silent it is always superficially the same—silence is, after all, by definition, the absence of speech or phonetic content—but that hardly means all silence is the same†. In this chapter Meyerhoff mostly focuses on women and how they communicate by being silent. Then Mererhoff mentions the thought of being silent, and how silence leaves behind words women could have said. After that, Mererhoff tries to explain how sociolinguist is a way to be extralinguistic. MererhoffRead MoreVenturing into the Writing of Jane Austen1114 Words   |  4 PagesWhen venturing into Jane Austen, I started reading her letters one of them was her talking to her niece about marriage, and went more into her life and the way she chose to live it. After learning how she lived and about her life I Watched the BBC version of Mansfield Park, just to get a hold of what Mansfield Park really is. After the movie was done I had a discussion about it comparing to the PBS version of Mansfield Park. Then Compared Mansfield Park to Persuasion followed by Sense and SensibilityRead MoreSilent Sam, By Julia Craven908 Words   |  4 PagesSilent Sam â€Å"UNC can no longer say silent on Silent Sam,† Julia Craven from the Huffington Post wrote. Silent Sam is a memorial in the middle of the University of North Carolina’s campus built to honor students who left school and fought in the Civil War. The Civil War was a war between the northern and southern states fought over slavery. Many students now think that the statue is offensive because the people that it honors fought for the South and supported slavery. Silent Sam was erected inRead MoreLabyrinth Of Sewer Tunnels Of Underworld1527 Words   |  7 Pagesbeing used by Underworld’s inhabitants. By showing his wife the correct to move the concrete by taking advantage of the apparent crevices, they were able to make their way to the main entrance into Underworld. Compared to the sewer tunnels, the pathways leading to Underworld’s main entrance was completely pitch black, with the only way for someone to navigate through the darkness was the sight of the fortified gate, the walls next to them sporting manned machine gun nests with emplaced MG42s, and theRead MoreCritique Of Silent Spring1669 Words   |  7 PagesTamesha Barnes October 9, 2014 Paper #1 Environmental Health 301W I pledge that I have neither given nor received any aid on this work_________Tamesha Barnes_________. Critique of Silent Spring Silent Spring was a controversial, yet brilliant book that brought to light an environmental issue that many people knew nothing about, or at least tried not to. â€Å"Each chapter describes the major developments by decade using a mixture of fact and anecdote, generality, major news items and

Monday, December 23, 2019

Suicide - 3873 Words

Teen Suicide Research Paper People need to be informed on why teens commit suicide and what signs to look for. Teens are slowly slipping away because of this deadly subject and people need to start noticing. Sometimes people can get caught up in their own personal lives and not even notice when a loved one is considering suicide. In the seven articles read, there were a variety of things that people seem to overlook often. Why teens are committing suicide and what people can do to help victims who are considering, are two main points that are important for people to know. In a Kids Health article about teen suicide, it talks about teen suicide and different things people need to know about it. According to the Centers for Disease†¦show more content†¦There can be many attributes to teen suicide but knowing the risks may help someone in need. Suicide can occur after experiencing a stressful life event for teens. Perceived failure at school, a break up with a boyfriend or girlfriend, the death of a loved one, a divorce or a major family conflict. Here is a list below From Kids Health that gives some signs to look for when a teen might be considering suicide. * Talk about suicide or death in general * Talk about â€Å"going away† * Pull away from friends or family * Lose the desire to take part in favorite things or activities * Have trouble concentrating or thinking clearly * Experience changes in eating or sleeping habits * Self-destructive behavior (drinking alcohol, taking drugs, or driving too fast, for example) In a recent article by Jane Brody in the New York Times, she summarized research showing major risk factors for teen suicide. 1. Depression - often not recognized. 2. Substance abuse. Sometimes teens try alcohol or other drugs to relieve depression. 3. Behavioral problems - getting in trouble in school or with the law, fighting with parents - is the third risk factor for suicide. 4. Availability of a gun. This makes the consequences of an impulsive act much more lethal. 5. Previous attempts. Half of all children who haveShow MoreRelatedSuicide : Suicide And Suicide1404 Words   |  6 Pages Suicide is a wildly talked about subject in this day and age. There are movies, books, papers, journals, and a wide spread of personal experiences. These experiences can be from thinking about suicide, making a gesture of attempting suicide or from people who knew somebody who went through with suicide. The experiences of suicide can lead to complications of survivors grieving process and also the stigmas that are associated with suicide. Unfortunately, we see a wide variety of suicide thatRead MoreSuicide And The Death Of Suicide1079 Words   |  5 Pages Suicide, a Permanent Solution to a Temporary Problem Good afternoon, I’m Jasmyne here to talk about suicide and how big of a problem it is. Suicide is defined as an act of one intentionally killing themselves. Why is suicide such a big problem? Well, suicide takes the lives of nearly 40,000 Americans every year; also it is more likely someone will die from suicide than from homicide. For every two people killed by homicide, three people die of suicide. Children young as 10 years of age have evenRead MoreTeen Suicide And Suicide1145 Words   |  5 Pagesthem? Today suicide is one of the most prevalent causes of death for teenagers in the United states. The suicide rates for teens are astronomical. Writer Stephanie Pappas mentions teen suicide rates in her article Suicide: Statistics, Warning Signs and Prevention. In the article, Pappas writes â€Å"In 2015, suicide was the second leading cause of death in people 15 to 34 years of age and third leading cause of death in children aged 10 to 14, according to the CDC.’’ (Stephanie Pappas, Suicide: StatisticsRead MoreThe Problem Of Suicide And Suicide Essay1435 Words   |  6 Pagesending misery. How do they cope? What are their ways of dealing? Most students live in denial. Others have friends to confide in. For the devastating part, most students are not as open to these ideas and it leaves them with this alternative: suicide. Suicide is the third leading cause in teens the ages 14 to 19 within rural underserved areas. Suicidal ideation (SI), suicidal thoughts, were surveyed in over 12 high schools and it was found that in the past year, thoughts of (SI) were not shared withRead MoreThe Theory Of Suicide And Suicide1339 Words   |  6 Pagesthat suicide rates skyrocket progressively across all age: children and adolescent (McClure, 1994), Middle-age (Manton et al., 1987) and the elderly (Draper, 1996), studying suicide have become an important issue in sociology. Suicide is a complex issue which may combine several factors such as development factors, social factors, and culture factors (Goldsmith, 2002). However, Durkheim (1897) provided a classical model including four types of suicide: altruistic suicide, fatalistic suicide, egoisticRead MoreThe Death Of Suicide And Suicide891 Words   |  4 Pages, 2015 Suicide is an occurrence in life that society does not want to talk about. Social knowledge is minimal at best about how to approach communication with those affected by suicide. The stigma about suicide is vastly misunderstood, unfounded and should not exist. Learning about suicide is very important not only for society but for those who have to suffer and live with the â€Å"social blight† society has created about this sad problem. There are various reasons for attempted suicide such asRead MoreThe Issue Of Suicide And Suicide1557 Words   |  7 PagesThe topic I chose to elaborate on as a criminal act in some countries but considered deviant or conventional in others is the issue of suicide from the basis of attempt and assisted. While suicide is a very enigmatic and incomprehensible subject for many, it becomes the area of focus on how criminal it becomes to take one’s life or aid in the process. How in control is someone of their life that it becomes a toler able decision and even supportive in some instances by medical professions. Is itRead MoreSuicide : Suicide And Depression1389 Words   |  6 PagesSuicide and Depression in Prisons Suicide is the leading cause of death in prisons across the United States (Marzaro, Hawton, Rivlin, Fazel, 2011). According to the United States Department of Justice, nearly 23% of state prisoners report symptoms of depression each year (Pardini et al., 2014). With, one out of seven inmates met the diagnostic criteria for major depressive disorder (Pardini et al., 2014). Marzaro, Hawton, Rivlin, and Fazel (2011) proposed that probable representations ofRead MoreThe Suicide And Suicidal Suicide1381 Words   |  6 PagesDurkheim once stated that suicide is, â€Å"all cases of death resulting directly or indirectly from a positive or negative act of the victim himself, which he knows will produce this result† (Jones, 1986). However, suicidal ideation is considered when an individual has thoughts or feelings of suicide, but does not attempt or complete suicide. Suicidal gesture, is when the individual has attempted the act of ending their life, if they were to be acciden tally successful, then the suicide is completed (LemingRead MoreSuicide And Youth Suicide1234 Words   |  5 Pages Suicide is the 10th leading cause of death in the US. The percentage of gun deaths by suicide is 64%.Youth suicide rates are going up at an alarming rate in the years. The number one method that people go to is firearms, 49.8% of suicidal people chooses this method.They found that in 2014, the most recent year for which data is available, the suicide rate for children ages 10 to 14 had caught up to their death rate for traffic accidents (source 1). In all, 425 children ages 10 to 14 killed themselves

Sunday, December 15, 2019

The 10 commandments of employee discipline and dismissal Free Essays

Last year alone, hundreds of adverse rulings were slapped upon scores of companies, resulting to millions of liabilities. It is sad to note that many employers today, either abetted by their HR and personnel managers, or against the professional advice of HR and lawyers, do not really adhere to the provisions of the Labor Code, on the rules of dealing with their own workers in the matter of discipline and dismissal. Despite all the seminars, workshops and symposia, that HR personnel attend regularly, management never seems to learn. We will write a custom essay sample on The 10 commandments of employee discipline and dismissal or any similar topic only for you Order Now The result could be very damaging, if not disastrous. An adverse decision by the NLRC and the Supreme Court entails not only an order to reinstate workers and pay them full backwages but also moral and exemplary damages. The greatest damage is upon the good name and corporate image and goodwill of the companies, or an irreparable damage on the harmonious relations between employees and management, resulting to declines in productivity, quality and profits. To help address this problem, this writer is now embarking on an advocacy through the PMAP, the official association of people managers in order to address this problem. Last week, I was in Baguio, then to Iligan. Today, I am in Davao then later this week, to Cagayan de Oro, in July in Tacloban, Bicol and Batangas. By August, I will conduct seminars in Cebu, Mandaue, and Mactan on the critical need to go back to the rule of law in leading and managing people. I have 10 commandments on employee discipline and dismissal. First, management should respect the workers’ rights in the exercise of the employers’ prerogatives to hire and fire people, to transfer, promote and demote. The Labor Code is explicit and unequivocal. The DOLE, NLRC and the Supreme Courts are strict and uncompromising. The second commandment is that management should adhere to the specific just causes for termination of employment, under Article 282 of the Code, like serious misconduct, insubordination, fraud, breach of trust, gross and habitual negligence and crimes. Third, employers should follow the authorized causes under Article 283, like redundancy and retrenchment, labor-saving devices and closures. Fourth, the strict rules on due process, under Article 277 (b) should never be compromised. Fifth, management should always bear in mind that, in illegal dismissal cases, it is the employers and not the complainants who have the burden of proof. Sixth, the proof must be enough to qualify, under the law, and controlling doctrine, as falling within the quantum of substantial evidence. In Cebu alone, many firms failed to comply with these basic principles. The seventh commandment is that management should master the art and science of proper and adequate documentation, from hiring to retiring. Legal forms should be prepared following the intricate procedures and formalities. The advice of expert lawyers should be sought. Some lawyers may be excellent in criminal and civil laws but are absolutely clueless in the practice of labor laws and labor relations. Any mistake could endanger the viability of the business and the career of CEOs and COOs and some HR executives. Commandment number 8 is the crucial choice of lawyers and consultants and the proper handling of labor cases before the Labor Arbiters and the NLRC, the appellate and the Supreme Court. The ninth commandment is knowing how to respond to summons, adverse decisions, writs of executions and other legal processes. Out of sheer lack of knowledge or worse, lack of respect for law and fundamental workers’ rights, many monumental mistakes had been committed. The tenth is for management to proactively train their executives, managers and HR staff how to avoid and prevent cases to be filed against the company. A small investment in these forward-looking, developmental and empowering seminars can go a long way in saving the business from the adverse effects of unfavorable court rulings. How to cite The 10 commandments of employee discipline and dismissal, Papers

Saturday, December 7, 2019

Business Law Small Business and Working with the Australian Consumer

Question: Discuss about theBusiness Law for Small Business and Working with the Australian Consumer Law. Answer: Introduction Australian Consumer Law is directed towards promoting fair-trading and ensuring that the rights of the consumers are protected. Consumer law is applicable to both big and small business enterprises. However, there is always a controversy regarding the quantum of protection granted to the small business enterprises. In the present business environment where big business houses are constantly expanding themselves by resorting to inorganic expansions such as takeovers, mergers, amalgamations etc. an important question always comes to the forefront do small businesses need more protection. The most recent development in this field was granting unfair contract terms protection to small business houses in 2014 by the Commonwealth[1]. The objective of this essay is to discuss the legislative framework applicable to small businesses and the manner in which small businesses perform in the given framework. Legislations and Case Law Precedents The legislative framework is mainly composed of two pieces of legislations The Competition and Consumer Act of 2010 (Act) and the Australian Consumer Law contained in Second Schedule of the former legislation[2]. The Act mainly stipulates rules and regulations to prevent anti-competitive conducts by business organisations while dealing with their customers. It ensures that fair and effective competition exists among business organisation in the course of conducting their business activities[3]. The Australian Consumer Law (ACL) provides for rules and regulations that organisations are required to abide by while they are dealing with their customers. In short, it provides for the rights and responsibilities of the customers and the organisation. The ACL is applicable to all business entities irrespective of their size and nature. The Australian Competition and Consumer Commission (ACCC) is the governing body that oversees the application and of the ACL[4]. Situations where financial services are involved, provisions of the Australian Securities and Investment Commission Act 2001 will be applicable in protecting the rights of the consumers. Majority of the legislative provisions contained in the ACL relates to the conduct of business organisations known as unconscionable conduct. According to the ACCC, it a conduct that is generally against good conscience and business organisations are required to avoid such conducts at all times. A recent notable case in this regard is the case of ACCC vs. Coles Supermarkets Australia Pty Ltd (2014). Critical Evaluation As mentioned earlier, consumer law is applicable to every business entity and it includes small businesses as well. Small businesses are required to practice fair trade policies in order to promote healthy competition within the industry. It has the responsibility of protecting the rights of its consumers and abstains from violating the legislative provisions of the Act. Nevertheless, the importance of small business units in the business fraternity cannot be denied as they contribute significantly to the economy of the country[5]. However, it has been often seen that large business houses resort to effective corporate tactics in order to eliminate competition. Small business units fall prey to such expansion strategies and had to agree to unfair contract terms proposed by bigger business units. In light of the present situation, it had become necessary to provide legislative protection to such small business units so as to enable them to survive and undertake their business activiti es in a proper manner. In the month of June 2015, the Treasury Department of the Commonwealth introduced legislative measures that will provide protection to small businesses from unfair contract terms similar to the kind of protection that the consumers enjoy. It has been seen that small business units sometime do not have any power to influence the market and are thrust upon unfair contractual terms while conducting business. The legislative reform came in the form of the Treasury legislation Amendment (Small Business and Unfair Contract Terms) Bill 2015[6]. The bill amends both the ACL and the ASIC Act in order to accommodate the changes made in the legislative structure. The practical implications of the amendments are huge as it changes the definition of business contracts with respect to a small business[7]. According to the new definition, a small business contract is a contract when any one of the contracting parties employs less than 20 employees and the price payable upfront does not exceed $300, 000 for contract whose tenure is less than one year. Under the provisions of the new amendments, unfair contract terms will be treated as void and this effect will extend extra protection to small business units[8]. In essence, a court will be able to strike off a term or terms from a small business contract, it deems such terms to be unfair and unjust to one of the contracting party or parties. In such a situation, if any contracting party tries to enforce such an unfair term, remedies can be sought from the courts and the court will be authorised to award compensation to the aggrieved party or parties[9]. Therefore, it can be seen that the amendments expands the scope of survival for small businesses and provides them with legislative protections under the existing legal framework. Conclusion It can be seen from the above discussion that the working of small businesses is very much influenced by the operation of the Australian competition and consumer laws. Both the legislations are applicable to every business organisation irrespective of their nature and size. They are required to comply with the provisions and shall prohibit themselves from engaging in any kind of unfair trade practices. The primary objective of these legislations is to uphold the rights of the consumers. On the other hand, large business houses try to influence the business of small units. Often, to eliminate competition, large business houses offer unfair contractual terms to smaller units and they are left with no option than to agree with them. This situation forced the legislators to pass the amendment bill that ensured protection to small business units under the consumer law. Small businesses received protection that is similar to that received by consumers. This opened up a new avenue for small businesses and helped them to take a step forward towards survival. References "Australian Consumer Law - The Law Handbook".The Law Handbook. Last modified 2015. Accessed June 2, 2016. https://www.lawhandbook.org.au/07_03_01_australian_consumer_law/. "Australian Consumer Law And Your Business".Business.Gov.Au. Last modified 2016. Accessed June 2, 2016. https://www.business.gov.au/info/run/fair-trading/australian-consumer-law-and-your-business. "COMPETITION AND CONSUMER ACT 2010".Austlii.Edu.Au. Last modified 2016. Accessed June 2, 2016. https://www.austlii.edu.au/au/legis/cth/consol_act/caca2010265/. "COMPETITION AND CONSUMER ACT 2010 - SCHEDULE 2The Australian Consumer Law".Austlii.Edu.Au. Last modified 2016. Accessed June 2, 2016. https://www.austlii.edu.au/au/legis/cth/consol_act/caca2010265/sch2.html. "Extending Consumer Like Protections To Small Businesses Across Australia | The Hon Bruce Billson MP".Bfb.Ministers.Treasury.Gov.Au. Last modified 2016. Accessed June 2, 2016. https://bfb.ministers.treasury.gov.au/media-release/056-2015/. "Federal Government Passes New Laws Extending Unfair Contract Terms Protections To Small Business Contracts - Holding Redlich Lawyers - Law Firm Melbourne Sydney Brisbane Australia".Holdingredlich.Com. Last modified 2016. Accessed June 2, 2016. https://www.holdingredlich.com/corporate-commercial/federal-government-passes-new-laws-extending-unfair-contract-terms-protections-to-small-business-contracts. "Small Business Forgotten And In Need Of Protection From Unfairness?".Www.Austlii.Edu.Au. Last modified 2016. Accessed June 2, 2016. https://www.austlii.edu.au/au/journals/UWALawRw/2013/8.pdf. "Small Business The Competition And Consumer Act".Australian Competition And Consumer Commission. Last modified 2013. Accessed June 2, 2016. https://www.accc.gov.au/publications/small-business-the-competition-and-consumer-act. "The Australian Consumer Law The Australian Consumer Law".Consumerlaw.Gov.Au. Last modified 2016. Accessed June 2, 2016. https://consumerlaw.gov.au/the-australian-consumer-law/. [1] "Australian Consumer Law - The Law Handbook",The Law Handbook, last modified 2015, accessed June 2, 2016, https://www.lawhandbook.org.au/07_03_01_australian_consumer_law/. [2] "Small Business The Competition And Consumer Act", Australian Competition And Consumer Commission, last modified 2013, accessed June 2, 2016, https://www.accc.gov.au/publications/small-business-the-competition-and-consumer-act. [3] "Australian Consumer Law And Your Business", Business.Gov.Au, last modified 2016, accessed June 2, 2016, https://www.business.gov.au/info/run/fair-trading/australian-consumer-law-and-your-business. [4] "COMPETITION AND CONSUMER ACT 2010", Austlii.Edu.Au, last modified 2016, accessed June 2, 2016, https://www.austlii.edu.au/au/legis/cth/consol_act/caca2010265/. [5] "Federal Government Passes New Laws Extending Unfair Contract Terms Protections To Small Business Contracts - Holding Redlich Lawyers - Law Firm Melbourne Sydney Brisbane Australia", Holdingredlich.Com, last modified 2016, accessed June 2, 2016, https://www.holdingredlich.com/corporate-commercial/federal-government-passes-new-laws-extending-unfair-contract-terms-protections-to-small-business-contracts. [6] "Extending Consumer Like Protections To Small Businesses Across Australia | The Hon Bruce Billson MP", Bfb.Ministers.Treasury.Gov.Au, last modified 2016, accessed June 2, 2016, https://bfb.ministers.treasury.gov.au/media-release/056-2015/. [7] "The Australian Consumer Law The Australian Consumer Law", Consumerlaw.Gov.Au, last modified 2016, accessed June 2, 2016, https://consumerlaw.gov.au/the-australian-consumer-law/. [8] "COMPETITION AND CONSUMER ACT 2010 - SCHEDULE 2The Australian Consumer Law", Austlii.Edu.Au, last modified 2016, accessed June 2, 2016, https://www.austlii.edu.au/au/legis/cth/consol_act/caca2010265/sch2.html. [9] "Small Business Forgotten And In Need Of Protection From Unfairness?", Www.Austlii.Edu.Au, last modified 2016, accessed June 2, 2016, https://www.austlii.edu.au/au/journals/UWALawRw/2013/8.pdf.