Monday, December 30, 2019
The Role Of Social Media On The Children Of The 21st Century
As more immigrants flocked to America, they brought their original cultures with them and refused to conform to the popular cultures held by Americans. By keeping their traditions alive, they turned America into the melting pot of cultures we see today. The new generation, known as ââ¬Å"millennialsâ⬠, are surrounded by different cultures and religions. The millennials engage in cultural appropriation unknowingly; by being exposed to the different cultures through media, music and even fashion. In my research, I found some authors who speak about cultural appropriation and the newer generations overlapping. Newer generations, however, often feel they deserve everything and owe nothing. Most donââ¬â¢t see cultural appropriation as being a ââ¬Å"bad thingâ⬠because most donââ¬â¢t even know what it truly means. Social media has been a big influence on the children of the 21st century. As Donna Alvermann goes into more detail in her article, ââ¬Å"Media, Information Communication Technologies, and Youth Literaciesâ⬠, she gives a few examples on how people use social media in their day to day lives ââ¬Å"the Internet, instant messaging, and e-mailââ¬âto communicate with their peers and relatives, to stay current in what matters to them, to shop, to relax, to create personal Web pages, and yes, to complete homework assignments, among other thingsâ⬠(Alvermann, 78). In those few examples, she covers how people stay in touch and use the internet for what accommodate their needs. Most millennials now a day donââ¬â¢t knowShow MoreRelatedTeacher s Role Of 21st Century : Personal Debate - Module / Week 51385 Words à |à 6 PagesTeacherââ¬â¢s Role in 21st Century: Personal Debate - Module/Week 5 The purpose of this paper is to fulfill the assignment objectives by clarifying the characteristics of a 21st century teacher, and considering them against the characteristics of the ââ¬Å"traditionalâ⬠teacher. The writing will the work to evaluate whether the role of teachers in the 21st century is changing and if so, whether ââ¬Å"traditionalâ⬠teachers versus those considered to be equipped with 21st century skills are going to be more or lessRead MoreClassroom Is Not The Classroom Of Yesterday1050 Words à |à 5 PagesPartnerships for 21st century learning developed an education framework with teachers, educational and business leaders that provides a list of skills students need to succeed in work, life and social community. The framework sees the core subjects of reading, writing, and numeracy supported by learning and innovation skills (critical thinking, communication, collaboration, and creativity). Furthermore, the 21st century learner would see further life and career skills, information, media and technologyRead MoreEffects Of Technology On Socialization1300 Words à |à 6 Pages Anti-social socialization: The effects of Technology on socialization of the youth in the 21st century Robert Elz University of North Georgia Abstract In the 21st century, technology is integrated in examines that to every aspect of our lives. It is prevalent is all sections of our culture, our homes, our schools and our communities. But what kind of effect is it having on those in their formative years? Does the abundance of technology have an effect on the newer generationsRead More Source 1: Essay1001 Words à |à 5 Pages This article discusses the future role of the library media specialist, which describes that they need to have a bigger role in education. Many believe that librarians are the original specialists so they call it ââ¬Å"the information perspectiveâ⬠(Lowe, 2000). This is where the library media specialists look at the curriculum, assignments, and learning in terms of information resources, processes, and technologies required for student success. The library media specialists are going to be the ââ¬Å"pioneersâ⬠Read MoreThe Era Of Growing Technologies1634 Words à |à 7 PagesThe Era of Growing Technologies The term technology originates from two Greek terms which are tekhne and logia, these two terms mean arts and crafts. Technology has started in the 17th century, however it is still a growing thing in the 21st century. Technology does not always have to be about computers and new smart phones because back then they did not have all of this stuff but technology back then was still growing. Technology is very identifiable for this era since the technology is constantlyRead MoreThe Dangers Of Internet Addiction Essay1645 Words à |à 7 Pagesyou can find information about whatever happened almost immediately. This speed of information transfer has become a vital role in people s lives, jobs, and even ideas and perspectives on certain issues. However, along with all these advantages, some real problems have developed as a result of its pervasiveness in our lives. The pervasiveness of the internet in our 21st century has caused a huge amount of danger in our everyday lives. The most im portant danger being addiction. Internet addiction isRead MoreGender Identity And Children And Gender1335 Words à |à 6 PagesGender Identity Children and Gender Gender Identity refers to how we feel and express our gender. From the time we are born, we are identified as being a male or a female. We learn gender identity from others and interaction helps produce it. A baby by the age of 1 knows if they are a boy or girl and by the age of 2 to 3 they form an opinion about the way they feel about their gender. Children take cues from their environment and the people around them to form gender identity. Anthony SchulloRead MoreObesity : The Disease Of The 21st Century947 Words à |à 4 PagesObesity is known as the disease of the 21st century. The occurrence of obesity is increasing globally, with nearly half a billion of the world s population now considered to be overweight or obese. There are many factors in todayââ¬â¢s society that contribute to this growing epidemic including media, technology and demographics. With the media having more influence over our daily habits now more than ever, it is extremely easy to slip into a lifestyle that will lead to weight related healthRead MoreAdvancement in Technology Shapes the Lives of Children and Adults1050 Words à |à 5 Pagesstay updated on the latest trends. In the 21st century, technology shapes the lives of numerous adults, but as well as their children. While once the fad being to play outside with friends and riding bikes, children and teens today have been caught up with a variety of social media sites and devices that help to locate them. ââ¬Å"By 2010, two-thirds of children ages 4 to 7 had used an iPhone, according to the Joan Ganz Cooney Center, which studies childrens mediaâ⬠(Rosin 60). Whether it be a cell phoneRead MoreExodus Code And The Gate Keepers1683 Words à |à 7 PagesThe 21st century marks the start of a new millennium were technology is at the center of everything that is anything, where a vast majority of our population can carry computers in their pockets. As well as how constant advancements in every field, from space exploration all the way down to something as primal as farming, are being made. Truly the human race is at the top of its game. And itââ¬â¢s because knowledge and its understanding is valued through out our society. This statement can be seen throughout
Sunday, December 22, 2019
Mass Media And Social Construction - 1438 Words
Mass Media and Social Construction Mass media has a large influence over perception of news articles, and the way it is portrayed to the public particularly in the case of crime and deviance; differing perspectives cause an array of reactions within society. Crime is commonly defined as an act that defies the laws set by the government, however deviance is a greater challenge to characterize as it is an idea that is socially constructed, primarily by the media. For example; an individual may see smoking as being deviant, however, another may see the act as simply a way of life. The media has such an imposing influence in the current era due to availability to the individual. Newspaper articles are easily accessible from any smart phone, along with social media sites, movies, books and more. This document aims to explore two criminological perspectives; Marxism and Pluralism in order to discuss a range of competing angles. These two theories demonstrate the gaps in civilization, and the varying points of view that cha nge the way in which crime is defined. Marxism is a theory derived from the workings of Karl Marx, an economist and political philosopher born in 1818. The theory is based on capitalist ideologies, and the concept that a class structure should be in place in order for society to function. Marxists have the belief that people should live in a hegemonic society with the public existing within their stereotypes (Marx, K. and Engels, F. 1848), without question orShow MoreRelatedSocial Construction And Its Impact On Society Essay1323 Words à |à 6 PagesSocial construction: an idea or belief regarding a specific element that is created due to external societal meanings. The principle of a social construction is used in society today as a method to explain how certain elements in society received its meaning. Although social constructions present the meaning behind specific objects, today it is now commonly used to explain and depict societal groups, including the behaviors and beliefs of individuals in these groups. In our modern society, the socialRead MoreMaking Meanings Essay1692 Words à |à 7 Pagesï » ¿CURTIN UNIVERSITY OF TECHNOLOGY SCHOOL OF MEDIA, CULTURE AND CREATIVE ARTS ASSIGNMENT COVER SHEET To be attached to all assignments (ALL SECTIONS MUST BE COMPLETED) STUDENT NAME:â⬠¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦.................. STUDENT ID:â⬠¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦ UNIT NAME AND NUMBER:â⬠¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦ DUE DATE:â⬠¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦. WORD COUNT:â⬠¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦1408â⬠¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦.â⬠¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦Ã¢â¬ ¦. TUTORIAL DAY ANDRead MoreThe And Dissemination Of Cultural Values, Ideologies, And Hierarchies832 Words à |à 4 PagesThe analysis on the construction and dissemination of cultural values, ideologies, and hierarchies is as varied as the historian. Again semantics and semiotics, important issues to understand the full web of the ââ¬Å"word-conceptâ⬠culture, dominate much of the theory and practice. The most common debates are over naming eras and redefining terms like popular, culture, popular culture, etc. Despite the debate, the historiography maintains four important foci for the construction of cultural values: industrializationRead MoreEssay about Criminal Justice Myths and Facts1363 Words à |à 6 Pages Compare and contrast crime myths and facts. The media plays a huge role in forming peoples perceptions of crime. Without the media we would remain ignorant to occurrences outside our direct social groups. The media and especially news coverage therefore provides us with an important point of contact with the rest of society. In evaluating its effect on popular perceptions of crime it becomes important to consider where most of the information comes from and how representative it is onRead MoreHarassment And Bullying On Social Media1568 Words à |à 7 PagesHarassment and Bullying on Social Media What is the history of this topic? Since the beginning of time people have always had an instinct for the desire to survive. Through this instinct of survival comes competition, where people feel the need to surpass others to get what they want, which has not changed as humans have evolved (Donegan, 2012, p.34). The aspect of competition occurs in many aspects of our life including in our education, social and economic systems. In the U.S., capitalistic societyRead MoreMass Communication Theory Of George Gerbners Cultivation Theory731 Words à |à 3 PagesGeorge Gerbnerââ¬â¢s *cultivation theory* a macro-level system theory that examines mass communication by studying institutions, message systems, and cultivation analysis (1967; 1970; Gerbner Gross, 1973; Gerbner et al., 1980; Potter, 2014). Theorized during the ââ¬Å"Age of Televisionâ⬠(Shanahan Morgan, 2004), the theory has been applied to newspapers and other media formats, assuming that media institutions ââ¬Å"cultivate facts, norms and values of s ocietyâ⬠(Gerbner, 1970; Gerbner Gross, 1976). SpecificallyRead More The Media As A social Problem Essay1731 Words à |à 7 PagesThe Media as a Social Problem nbsp;nbsp;nbsp;nbsp;nbsp; nbsp;nbsp;nbsp;nbsp;nbsp;The mass media plays a large role in modern society. Indeed, many have argued that people spend more time in ââ¬Å"mass-mediatedâ⬠interaction than in actual human interaction. The mass media, then, would seemingly be an excellent position to initiate social change, positively affect social problems, and help combat social ills that are considered normal patterns of behavior. Yet, the mass media has largelyRead MoreThe Media as a Social Problem Essay1748 Words à |à 7 Pages The Media as a Social Problem The mass media plays a large role in modern society. Indeed, many have argued that people spend more time in mass-mediated interaction than in actual human interaction. The mass media, then, would seemingly be an excellent position to initiate social change, positively affect social problems, and help combat social ills that are considered normal patterns of behavior. Yet, the mass media has largely failed in addressing and helping to solve social problemsRead MoreThe Constructions of Gender1094 Words à |à 4 PagesConstructions of Gender Authors name Authors institutional affiliation Authors note Constructions of Gender There are many different ways that people understand what their culture prescribes as appropriate behavior for males and females. While there are a variety of ways that people are socialized and acculturated with respect to gender, mass media, in its various forms, is the primary way that people learn how to act as a girl or boy. Mass media is a powerful method of communication, entertainmentRead MoreEssay about encoding decoding1125 Words à |à 5 Pagesmore than people at bottom Ideology legitimizes, justifies and naturalizes social system To analyse ideology we must uncover how the status quo provides large advantages to those who already have more power and privilege John Thompson (1990) defines ideology as ââ¬Å"meaning in the service of powerâ⬠ââ¬Å"Hegemonyâ⬠= dominance by consent (but it is never complete) ââ¬Å"The challenge facing us as students of the mass media is to examine the workings of, and sometimes the tensions between, dominant
Saturday, December 14, 2019
How do artists use skin as a cultural material Free Essays
Introduction Skin is a hugely significant part of every individualââ¬â¢s life and story. It can identify our race, health and even consumerism. Our body is what we are, and we are all aware of our own body. We will write a custom essay sample on How do artists use skin as a cultural material? or any similar topic only for you Order Now We can observe the body in different ways, especially if we consider it in the media and a cultural material. In this essay, I need to be able to distinguish between if the skin is a material object, a piece of meat or if it is something divine, something that has been given to us. Our skin is one part of us that gives the human body its own language, due to this it gives us a means of understanding life. We become inspired to explore our human body as a text (a language) that we can read and reveal to us a great deal of cultural information. ââ¬Å"This symbolic function of the body applies not only to the taboos and rituals, but to parts of the body, to representations of the human body ââ¬â in art works, medical texts, racial ideology, and advertisements ââ¬â and to decorations and modifications of the flesh, from ornaments, hair fashion, cosmetics, masking, costuming, tattooing, piercing, and scarification, to body fattening or thinning, muscular development, and cosmetic surgery. However extreme or seemingly whimsical the practise; it always has meaning, always is shaped by the sociocultural context in and through which people act.â⬠[1] This quote is a perfect starting point as an example of hoe diverse the literal idea of skin can be. All these changes can be made physically, but also require a certain amount of emotional and mental consideration as well. The idea my chosen essay question poses to me though, is that is this skin that we have a cultural material, and do artists make it that? Looking at the idea that skin most defiantly is used as a cultural material, we can go back as far as to look at early representations of people, and consider the work of artists such as, Botticelli. His painting of Venus and Mars is a clear depiction of his understanding of the personification of beauty, looking at the skin of Venus, we know that at the time Botticelli was producing this piece, no contemporary woman of that age would have had such perfect features and alabaster skin. This gives us a clear notion of the idealization that artists of the 15th century had about what they considered beautiful. Even in this era, the depiction of what was considered aesthetically beautiful was still highly regarded, and remained significant in the paintings produced at this time. This figure of Venus is perfectly symmetrical; Botticelli has created the ideal woman that is not only the perfection of physical attractiveness but also the philosophical level of beauty that was demanded by the scholars of the time. Though looking at the painting we can hardly ignore the extremely sexually provocative depiction of Mars, not only has Botticelli created his perfection of womanhood, but the god-like physique and classical features he has given Mars revel a greater depth of understanding to this piece as we begin to understand the artist and the requirements of the culture that surrounded him. Following this idea of skin depictions through the ages we can go on to look at the 18th century, and in particular on image by Jacques- Louis David, ââ¬ËThe death of Maratââ¬â¢ (1793). This one painting by David is a perfect representation of the ideals held in high esteem at the time, and the importance of the portrayal of significant figures in society. His image is telling us about the death of Marat, a man that was an important Jacobin, and who was also friends with the artist himself. Due to his role in the convention and as editor-in-chief of Lââ¬â¢Ami du Peuple, he was murdered as he bathed. As I am concerned with the idea of skin as material culture the importance of Maratââ¬â¢s portrayal in his bath, is crucial to this piece. Marat suffered from a disfiguring skin disease that required him to bath for hours in order to treat It, however as we look upon this piece we can clearly see that there is no trace of such a disease. David has created an idealized image of Marat, partly due to the fact that when he came to produce this portrait, Maratââ¬â¢s body was too badly decomposed. He has painted him as a healthy young man, and although his face is marked by suffering it is also gentle and immersed by a growing of peacefulness. The use of the elements such as light upon the skin are also vital to the composition, as Davidââ¬â¢s subtle interplay between these factors highlight his blend of compassion and outrage that he felt towards the victim of the piece. Baudelaire wrote in 1846, ââ¬Å"The drama is here, vivid in its pitiful horror. This painting is Davidââ¬â¢s masterpiece and one of the great curiosities of modern art because, by a strange feat, it has nothing trivial or vile. What is most surprising in this very unusual visual poem is that it was painted very quickly. When one thinks of the beauty of the lines, this quickness is bewildering. This is food for the strong, the triumph of spiritualism. This painting is as cruel as nature but it has the fragrance of ideals. Where is the ugliness that hallowed Death erased so quickly with the tip of his wingNow Marat can challenge Apollo. He has been kissed by the loving lips of Death and he rests in the peace of his metamorphosis. This work contains something both poignant and tender; a soul is flying in the cold air of this room, on these cold walls, around this cold funerary tub.â⬠[2] In this quote Baudelaire is restoring Davidââ¬â¢s work to its honour after being mistake by the Romantics as cold classicism. The idea of skin as material culture is so apparent here as the masking of a disease is known. I need to now enquire as to why things such as that are hidden and disguised, why is it important to sustain such a perfect ideal. Bibliography Onians, J. ââ¬Ëthe biological basis of renaissance aesthetics: in F, Ames ââ¬â Lewis, M, Rogers, eds. Concepts of beauty in renaissance artââ¬â¢, Aldershot: ash gate publishing Ltd. 1998. Walters, S. ââ¬ËMaterial girls: making sense of feminist cultural theory.ââ¬â¢ University of California press, Ltd. London, England. 1995. Pitts, V. ââ¬ËIn the flesh: the cultural politics of body modification.ââ¬â¢ Palgrove Macmillan TM. 2003. Tilley, C. ââ¬ËReading material culture.ââ¬â¢ Blackwell publishers, Ltd. 1990. Hall, S. ââ¬ËCultural identity and Diaspora ââ¬â theorizing Diaspora: a reader.ââ¬â¢ Wiley-Blackwell, 2003. http://www.bc.edu/bc_org/avp/cas/his/CoreArt/art/neocl_dav_marat.html http://sirl.stanford.edu/~bob/teaching/pdf/arth202/Haughton_Renaissance_beauty_JCosmeticDermatology04.pdf http://science.jrank.org/pages/8480/Body-SOCIAL-SKIN.html How to cite How do artists use skin as a cultural material?, Essay examples
Thursday, December 5, 2019
The Concept Of Corporate Veil And Examine
Question: Critically examine the concept of corporate veil? Answer: Under the company law a company is generally considered as a juristic person. The result is that it has the same rights and the duties and can also own real property, enter into contracts in its own name and the company also has the capacity to sue and be sued using its own name. The result is that a company is considered as a juristic individual and mostly, it is considered as a natural person. At the same time, a major factor that motivates the registration of a company is the benefit of limited liability provided to the stockholders. As a result of this doctrine, the shareholders of the company are liable only to the amount of their shares. However, a significant exception is present to the doctrine of limited liability. Therefore, under some circumstances, the court may decide to pierce the veil for the purpose of looking through the corporation (Robert, 1991). This act of the court is known as piercing the veil. In such a case, the court can treat the shareholders personally acc ountable for the obligations that may otherwise be imposed only against the company. The principle of lifting the veil is invoked in cases where the distinction between the corporation and its shareholders has been blurred. At this point, it has to be mentioned that although a company enjoys a legal identity, that is separate from its members however the company can act only with the help of human agents. The result is that to main methods at present through which a company can be held liable. These are the direct liability (in cases of direct infringement) and through secondary liability (related with the acts of human agents acting course of employment). In this way, after a company has been registered, it starts to enjoy a legal personality and is considered as a juristic entity. The company enjoys an identity of its own and it is separate from the owners, shareholders of the members of the company (Farrar, 1990). As mentioned above, certain rights are provided to the company in such a case. Similarly the most significant consequence of the incorporation of a company is the advantage of limited liability offered to its shareholders. Limited liability has been introduced with a view to provide a minimum insurance to the investors regarding the investments made by them in the business and their personal lives. The effect of this doctrine is that the member of the company is liable only to the extent of the amount paid by the member for the shares owned by such a member in the company. On the other hand, the creditors having claimed that is the company can only recover their dues from the assets of the company and generally they are no t allowed to sue the personal assets belonging to the members of the company (Ford, Austin and Ramsay, 1999). As a result of this doctrine, a significant advantage was enjoyed by the investors as a cap has been imposed on the risk faced by them. Under these circumstances, it is clear that the companies exist, at least partly, for the purpose of protecting the shareholders from any personal liability regarding the liabilities of the corporation. The notion of limited liability emerged in England during the 17th century because before this doctrine, individuals were afraid of investing in a company because all the partners are considered as being equally responsible for the liabilities of the business. On the other hand, as a lot of capital was required for the purpose of financing large projects, and as a result much more money was required to be raised, the investors were not coming forward to finance owing to the risk that was involved in standing guarantee for the whole debt of the corporation. In Salomon v Salomon Co, the court affirmed the legal principle according to which, after its incorporation, a corporation is generally known as a separate entity. The rule provided by the court in this case is still relevant today and is applied by the courts. It was firmly established as a result of this decision that a company can act in its own right and name. Similarly in another case (Gas Lighting Improvement Co Ltd v Inland Revenue Commissioners, 1923), the court stated that between an investor, and the undertaking carried on, the company is interposed by the law as a real, although artificial person. Therefore the business that is carried on in such a case is the business of the corporation and similarly the capital used in the undertaking is the capital of the company and it cannot be considered as the capital of the shareholders, provided the company has been duly incorporated and it is not sham. Another legal notion established by this case was that under the common law, the shareholders can be considered as liable for the debts of the corporation, beyond the amount invested by them in the shares of the company (Ian and Noakes, 2005). Similarly, they do not have any proprietary rights over the property owned by the company. In this regard, it has been mentioned in The King v Portus (1949), for example that while deciding if the employees of the corporation that was controlled by the Federal Govern ment can be considered to be employed by the Federal Government itself, it has to be kept in mind that a company is detached from the stockholders. The stockholders can be responsible for the creditors of the corporation regarding their debts. Similarly, the property of the company is not owned by its shareholders. But sometimes, the court may decide to lift the corporate veil. This act is totally opposite to the concept of limited liability. Although, the idea of limited liability has several merits, it may sometimes results in the problem of over inclusion that maybe disadvantageous for the creditors. Therefore, it has been claimed that the law has over sheltered limited liability. When the court lifts the veil the shareholders personal assets may also be sued as is the case in a sole proprietorship or partnership. A registered corporation has its own legal identity that is distinct from the owners (shareholders) or the controllers (directors) of the company. However there are certain circumstances where the law allows records to ignore the rule of the limited liability of the companies and in this way, lift the corporate veil. In such circumstances, the members are individually held responsible for the actions of the company although the limited liability rule provides that the company has a distinctive identity that is separate from its participants. At this point, it should be noted that piercing the corporate veil is considered as one of the most litigating issues under the company law of the UK (Bainbridge, 2001). However before arriving at the decision to use the corporate veil in a particular case, there are certain factors that have to be considered by the courts. It is also worth mentioning that generally the courts are unwilling to do so and in this way, they like to maintain the sepa rate identity of the companies. However there are certain circumstances where a court may arrive at the conclusion that the separate identity of the company should be ignored, for example where they are acting as a single economic unit or for the purpose of achieving justice. In the same way, the corporate veil can be lifted by the courts when the argument of a sham or facade has been made and the same is the case with the agency argument. In this way, after the legendary decision given in Salomon v Salomon (1897), the courts have recognized the number of factors due to which the corporate veil may be lifted by the courts. The Single Economic Unit Argument: In the leading case titled as Adams v Cape (1990) it has been argued that in case of a group of companies, the basic principle is that each company of the group has to be considered as having its own distinct identity. But there are certain circumstances when this basic principle can be ignored by the courts and therefore, the companies of the group can be considered as a single company. Therefore in this case, the court arrived at the conclusion that the group of companies can be considered as a single company where it has been allowed by a particular law or by the provisions of the contract between the parties otherwise the rule provided in Salomon's case will apply (Hawke, 2000). In the same way, another leading case in this regard is that of DHN Food Distributors Ltd v Tower Hamlets London Borough Council (1976) where the court considered a group of corporations as a single economic entity and as a result, compensation can be paid for the compul sory purchase of land. In this way, these decisions can be considered as a "short step" that has been taken in the direction of the proposition that the principal provided in Salomon's case can be disregarded by the courts if doing so can be considered as just and equitable. However, these days, such situations are treated as very rare and at the same time, doubts have also been raised on several occasions regarding the decision of the court given in DHN Case, for example in Woolfson v Strathclyde Regional Council (1978). The Achieving Justice Argument: In the same way, the corporate been calculated by the courts when doing so is required in the interests of justice or where any impropriety has taken place. In this regard, it has been argued that the courts can pierce the veil if doing so is necessary for the purpose of achieving justice, regardless of the legal efficacy of the corporate structure that is being considered in a particular case. However in Adams v Cape Industries, the arguments made in favor of piercing the corporate veil in the interest of justice have been rejected by the court (Ball Jr., Matthew and Nelson, 1997). In the same way, in Trustor v Smallbone (2001), doubts have been expressed by the courts if the veil can be impaled by the courts on the basis of impropriety. Under these circumstances, it can be said that the veil can be lifted in the interests of justice if there is also evidence present to suggest that the Corporation is a sham or a facade. In the same way, in Woolfson v Strathclyde Regional Council (1978), the House of Lords had stressed upon the fact that the principle of the separate identity of a corporation that has been provided in Solomon's case cannot be disregarded whenever doing so is required by justice or equity. The Sham/faade Argument: As mentioned above, the Court has recognized in Adams v Cape Industries that it is well recognized that the court may decide to impale the veil and hold the directors all shareholders responsible if the corporate structure is only a facade designed to conceal the real facts (Easterbrook and Fischel, 1985). For example in this case, the court arrived at the conclusion that one of the companies of the group can be considered to be falling in this category. In the same way, the House of Lords has also discussed the argument of facade in Woolfson's case although the meaning of this term has not been explained by Lord Keith. However, regardless of the exact meaning of the term considered by the courts while applying this argument, it was clearly stated by the House of Lords that the Salomon principle cannot be disregarded if it is required by justice or equity. However, it is generally recognized as an exception to the general principle and therefore the corporate field can be pierced by the courts if the Corporation is a sham that has been designed with a view to commit a fraud or for the purpose of avoiding any present contractual obligation (Baxt, 1991). An example in this regard can be given of Gilford Motor Co v Horne where respondent was previously acting as a director of Gilford and had signed an agreement with the company that he will not solicit the customers of the company, in case he quits the business. Under the circumstances, the former director and his wife incorporated a company that was used for the purpose of breaching the terms of this agreement. As a result, the court arrived at the conclusion that the new company incorporated by the defendant and his wife was merely a sham or a cloak and therefore the defendant was liable for the breach of the agreement. However it needs to be noted in this context that the veil is not lifted if the new company has been established with a view to avoid future liabilities. In this regard, it has been argued by some commentators that in these cases, the piercing the veil is not involved at all (Griffin, 1996). However the argument of sham or facade is the strongest argument that may prompt the court to impale the corporate veil in a given case. In this regard it also needs to be mentioned that this argument is very close to the argument of fraud, although generally this argument can stand in the court on its own. This argument is available when a company can be considered as merely a facade or a sham. Such a situation takes place when the corporate form has been incorporated or used for the purpose of hiding the real purpose that the Comptroller of the corporation has. In Sharrment Pty Ltd v Official Trustee (1988), it has been stated by Lockhart J that "a 'sham' can be described as something that had been created with an intention to be erroneously believed to be something else or something that is in reality not but it imports to be. In this way, it is a disguise or a spurious imitation. In this context, it also needs to be mentioned that the argument of sham or facade can be made independently, without arguing fraud. The Agency Argument: In some cases, the court arrived at the conclusion that the corporate veil should be lifted where the company in question is only the 'alter ego' of its shareholders. In such a case, it is said that the corporation is the 'agent' or the 'alter ego' of the corporation's shareholders as in this case it does not perform its own business but it merely carries on business on behalf of the shareholders. In this context, an agent can be described as a person who acts on the basis of the directions given by another person, called the principal and in such a case, all the actions of the agent are considered to be binding for the principal. For example in case of corporations, in some cases a subsidiary can be treated by the law as the agent of the parent corporation (Farrar and Hannigan, 1998). For example in Salomon's case, it was stated by Williams J that the company can be considered as an agent of Salomon. But on appeal, the House of Lords arrived at the conclusion th at a corporation cannot be considered as an agent of its shareholders only on the ground that it was a one-man company. Therefore on the basis of this decision, it can be said that the presence of an agency situation is not indicated by the fact that all the shares of the company are owned by a single person. As a result, the facts and circumstances of each case has to be considered separately. Smith Stone and Knight Ltd v Birmingham Corporation (1939) is a leading case that is related with the agency exception. The question that had to be decided was if the subsidiary can be considered as carrying on the business of its parent company or in the eyes of law, the subsidiary was carrying on its own business. In this case, the two companies were treated by the law as a single entity. This case is considered as a significant case related with the agency argument because in this case, the significant factors that have to be considered while deciding the question if the agency relationship is present between holding company and its subsidiaries were mentioned in detail by the court in this case. However, it needs to be noted that these factors act only as guidelines and as a result, each case has to be decided by the courts on the basis of individual facts and circumstances that are present in each case. For example, it has to be considered who's going to receive the profit, who has the authority to appoint and another very crucial factor in this regard is to see who has constant and effective control over the business of the company. When affirmative answers have been given to these questions, it can be said that the group of companies has to be considered by the court as a single entity. In the end, it can be said that the decision to lift the corporate veil is still one of the most controversial matters under the corporate law. However in this work, an attempt has been made to discuss the principles related with the application of the rule of piercing the veil. For this purpose, the arguments that are generally made in favor of piercing the veil by the court have also been discussed References Bainbridge, S.M. 2001, Abolishing Veil Piercing, 26 J. Corp Journal of Corporate Law Spring, 479 Ball, C. Jr., Matthew M. S. and Nelson C. S. 1997, The corporate veil. When is a subsidiary separate and different from its parent? Cornerstone Research Foundation Baxt R, (1991) Ultra Vires Has it Been Revived? 1 Company and Securities Law Journal 101 Farrar, J and Hannigan, B (1998) Farrar's Company Law (4th edn), p.75 Farrar, J. (1990) 'Fraud, Fairness and Piercing the Corporate Veil, 16 Canadian Business Law Journal 474 Ford, H. A. J., Austin R. P. and Ramsay, I. M. 1999, Ford's Principles of Corporations Law, 9th Ed Frank H. Easterbrook Daniel R. Fischel, (1985) Limited Liability and the Corporation, 52 U. CHI. L. REV, 89 Gower and Davies (2003) Principles of Modern Company Law (7Ed) London Sweet and Maxwell Griffin, S. (1996) Company Law Fundamental Principles (2nd edn), p.19 Hawke, N. 2000, Corporate Liability, London Sweet and Maxwell, p. 108. Ian R. M. and Noakes, D.B. 2005 Piercing the Corporate Veil in Australia, Melbourne University Press Robert B. 1991, Thompson, Piercing the Corporate Veil, an Empirical Study, 76 Cornell L. REV. 1036 Case Law Adams v Cape Industries [1990] Ch 433 DHN Food Distributors v Tower Hamlets LBC [1976] 3 A11 ER 464 Gas Lighting Improvement Co Ltd v Commissioners of Inland Revenue [1923] AC 723 R v Portus; Ex parte Federated Clerks Union of Australia (1949) 79 CLR Salomon v Salomon Co [1897] AC 22 Sharrment Pty Ltd v Official Trustee in Bankruptcy [1988] FCA 179 Smith, Stone Knight Ltd v Birmingham Corp [1939] 4 All ER 116 Trustor v Smallbone [2001] 1 WLR 1177 Woolfson v Strathclyde Regional Council (1978) ALT 159
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