Progressivism from the Grassroots to the Whitehouse free essay sample

American society. Emerging at the end of the nineteenth century, it established much of the tone of American politics throughout the first half of the century (Harrier, 1999). The United States was experiencing a period of urban growth, economic distress, labor unrest, unemployment, low wages, unfair labor practices, and deplorable living conditions. Large numbers of international immigrants arrived daily to work in this newly established industrialized society, while escaping the harsh realities of their native countries.As the shift from agriculture to mind gusty/manufacturing droves of people relocated from rural to urban northern communities. As in most societies, the focus had moved to commerce versus the needs of the people. In the midst of a religious awakening after visiting the settlement house in London, England, Jane Addams noted how this new movement was impacting London and challenged social Darwinism theory of survival of the fitness. Families were bettered because of the social work being done. We will write a custom essay sample on Progressivism from the Grassroots to the Whitehouse or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page She and a fellow seminary student, Lillian Wald started the Hull House in the Chicago ghetto. This mansion became the center of life for thousands of immigrants, munching the settlement house movement in the United States. The houses confronted the social problems by reforming individuals and society. Efficiency and expertise became the watchwords of the progressive vocabulary. Childrens services were provided, namely nurseries, kindergarten and aftershock programs, mothers were taught simple skills and working women later formed trade unions for laborers. Training programs were developed to ensure that welfare and charity work would be undertaken by trained professionals.Child labor laws were enacted giving hillier the opportunity t to go to school, organized labor unions were formed supporting goals of eight-hour work days, improved safety and health conditions, workers compensation laws and minimum wages for women. The movement picked up momentum and was joined by church leaders seeking social purity by pushing prohibition. Progressivism became prominent at every level of government, giving voters direct voice in legislative and judicial matters with initiatives, referendum and recall. Some of the notable politicians who subscribed to the progressivism philosophy were: MayorThomas Loft Johnson from Cleveland, Ohio who fought for fair taxation. Hiram Johnson, California Governor (191 1-1917) and U. S. Senator (1917-1945), promised to return the government to the people free of corruption and corporate influence. The focus became to give honest public service. From 1 901 to 1 909, President Theodore Roosevelt steered away from the persistent passivity of his predecessors and promised the American people a Square Deal, emphasizing that the average citizen would get a fair share under his policies. He demonstrated his willingness to challenge large reparations (trusts) by using the power of the government to control businesses. He championed the railroad reform giving power to the Interstate Commerce Commission (ICC), the establishment of the Pure Food and Drug Act (banning impure or falsely labeled food and drugs from being made, sole and shipped) and the Meat Inspection Act (banning misleading labels and preservatives that contained harmful chemicals).One of his most lasting legacies was his significant role in the creation of 1 50 National Forests, five national parks, and 18 national monuments, among other works of inspiration. In total, Roosevelt was instrumental in the conservation of approximately 230 million acres (930,000 km) of American soil among various parks and other federal projects (l. E. Cadenced, 1974). Initially the Progressive movement sought to improve the lives of white middle class citizens, it than expanded to include women and lower classes. Many of the core principles of the Progressive Movement focused on the need for efficiency in all areas of society. Purification to eliminate waste and corruption was a powerful element (Descants, 2000). Jane Addams once aid, Unless our conception of patriotism is progressive, it cannot hope to embody the real affection and the real interest of the nation (Jane Addams). Now the movement encompasses persons whose civil rights are challenged, such as the minorities, such as: GLUT (Gay rights), immigrants, and Socialists.

5 Uses of Infinitives

5 Uses of Infinitives 5 Uses of Infinitives 5 Uses of Infinitives By Mark Nichol An infinitive is a phrase, consisting of the word to and the basic form of a verb, that functions as a noun, an adjective, or an adverb. Here’s a discussion of the five types of infinitives. 1. Subject An infinitive can constitute the subject of a sentence. For example, in â€Å"To go, even after all that trouble, didn’t seem worthwhile anymore,† â€Å"to go† is the action that drives the sentence. 2. Direct Object In the sentence â€Å"We all want to see,† â€Å"to see† is the direct object, the noun (or noun substitute) that receives the action of the verb. â€Å"To see† refers to a thing being done or, in this case, desired to be done: the act of seeing. 3. Subject Complement In â€Å"My goal is to write,† â€Å"to write† is the subject complement. A subject complement looks just like a direct object, but the difference is in the type of verb preceding it. The verb in the previous example, want, is a transitive verb. (Transitive verbs have two defining characteristics: They precede a direct object, and they express an action.) In â€Å"My goal is to write,† the verb is a copular, or linking, verb one that links a subject to a word or phrase that complements it. (In this sentence, â€Å"to write† is the goal, so it’s the complement of goal. Note that in the previous example, â€Å"to see† is what those referred to as we want, but it’s not the complement of we.) 4. Adjective In â€Å"She didn’t have permission to go,† â€Å"to go† modifies permission it describes what type of permission is being discussed so the phrase serves as an adjective. 5. Adverb In â€Å"He took the psychology class to try to understand human behavior,† â€Å"to understand (human behavior)† explains why the taking of the class occurred, so it’s an adverb modifying the verb took. Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Grammar category, check our popular posts, or choose a related post below:Compared "to" or Compared "with"?Rules for Capitalization in Titles20 Criminal Terms You Should Know

New Year Greetings and Quotes

New Year Greetings and Quotes Do you want to send a special New Year greeting to your friends? Here is a great collection of New Year greetings. Some of the greetings convey worldly wisdom, while others present a diverse perspective about the New Year. Choose from this collection of New Year greetings to send good wishes to your near and dear ones. Thomas MannTime has no divisions to mark its passage; there is never a thunderstorm or blare of trumpets to announce the beginning of a new month or year. Even when a new century begins it is only we mortals who ring bells and fire off pistols.Hamilton Wright MabieNew Years Eve is like every other night; there is no pause in the march of the universe, no breathless moment of silence among created things that the passage of another twelve months may be noted; and yet no man has quite the same thoughts this evening that come with the coming of darkness on other nights.Charles LambNo one ever regarded the first of January with indifference. It is that from which all date their time, and count upon what is left. It is the nativity of our common Adam.Alfred Lord TennysonRing out the old, ring in the new,Ring, happy bells, across the snow:The year is going, let him go;Ring out the false, ring in the true.William Ellery ChanningI will seek elegance rather than luxury, refinement rather than fashion. I will seek to be worthy more than respectable, wealthy and not rich. I will study hard, think quietly, talk gently, and act frankly. I will listen to stars and birds, babes and sages, with an open heart. I will bear all things cheerfully, do all things bravely await occasions and hurry never. In a word, I will let the spiritual, unbidden and unconscious grow up through the common.Ann LandersLet this coming year be better than all the others. Vow to do some of the things youve always wanted to do but couldnt find the time. Call up a forgotten friend. Drop an old grudge, and replace it with some pleasant memories. Vow not to make a promise you dont think you can keep. Walk tall, and smile more. Youll look ten years younger. Dont be afraid to say, I love you. Say it again. They are the sweetest words in the world.Maria EdgeworthThere is no moment like the present. The man who will not execute his resolutions when they are fresh upon him can have no hope from them afterwards: they will be dissipated, lost, and perish in the hurry and scurry of the world, or sunk in the slough of indolence. P. J. ORourkeIt is better to spend money like theres no tomorrow than to spend tonight like theres no money.Ogden NashEvery New Year is the direct descendant, isnt it, of a long line of proven criminals?George William CurtisThe New Year begins in a snowstorm of white vows.Ellen GoodmanWe spend January 1 walking through our lives, room by room, drawing up a list of work to be done, cracks to be patched. Maybe this year, to balance the list, we ought to walk through the rooms of our lives, not looking for flaws, but for potential.Samuel JohnsonSurely, it is much easier to respect a man who has always had respect, than to respect a man who we know was last year no better than ourselves  and will be no better next year.Friedrich NietzscheNo, life has not disappointed me. On the contrary, I find it truer, more desirable and mysterious every year ever since the day when the great liberator came to me: the idea that life could be an experiment of the seeker for knowledge and not a duty, n ot a calamity, not trickery. Henry Wadsworth LongfellowLook not mournfully into the past. It comes not back again. Wisely improve the present. It is thine. Go forth to meet the shadowy future, without fear, and with a manly heart.Kersti BergrothIt is difficult not to believe that the next year will be better than the old one! And this illusion is not wrong. Future is always good, no matter what happens. It will always give us what we need and what we want in secret. It will always bless us with right gifts. Thus in a deeper sense, our belief in the New Year cannot deceive us.Albert EinsteinI feel that you are justified in looking into the future with true assurance  because you have a mode of living in which we find the joy of life and the joy of work harmoniously combined. Added to this is the spirit of ambition which pervades your very being, and seems to make the days work like a happy child at play.

Pestle Framework of Business Essay Example | Topics and Well Written Essays - 2000 words

Pestle Framework of Business - Essay Example From this discussion it is clear that  regarding the influence of the political environmental factors, matters of restrictions, policy, and other derivatives of the environment determine the nature of operations in ways that determine the trends of business. These factors have the capacity of enhancing the nature of business just as they have the potential of providing some robust framework that is used for the general performance of the business.This discussion highlights that it is important to consider some of the issues attending to the processes of business in terms of the various issues that affect and are in turn affected by the environmental factors. An awareness of these factors is necessary for the processes of planning, strategizing, budgeting, and the general management of the business. The development of strategy is usually determined by the ability of the business to use all the positive values and qualities that are necessary for the sustenance of the business. In es sence, the levels of success or failure of a business is necessarily determined by the manner in which the business connects with environmental factors as considered within the aspect of reality.  The political environment usually occurs in ways that are generally available for the determination of the levels of performance of the business. It is important to consider the fact that the political factors are connected to the other macro-economic factors that determine the nature of the operating environment.... The political environment usually occurs in ways that are generally available for the determination of the levels of performance of the business. It is important to consider the fact that the political factors are connected to the other macro-economic factors that determine the nature of the operating environment. Political factors in the environment of business could be conducive or hostile depending on a range of factors. Political environments that feature stringent conditions and policies will essentially stifle the aspect of competition within the process (Murray-Webster, 2010, p. 121). The realization of the range of factors that attend to the issues and values of the organization will essentially lead to the development of issues based on some of the matters that attend to matters of relevance and the determination of a range of factors that attend to the issues related to commerce and enterprise. Some of the issues that affect the operations of business are largely regulated by the fact that issues affecting business are essentially regulated by concerns in the world of business. Regarding the economic forces, certain economic factors have a direct impact on the manner in which businesses operate as understood within the framework of environmental factors. Generally, some of the issues that attend to the matter of challenge are necessarily controlled by the manner in which certain issues and processes are regulated. Economic growth and exchange rates are some of the economic factors that affect the performance of businesses within certain economic environments (Cheverton, 2005, p. 30). Economic growth encompasses a range of factors such as the availability of efficient banking services and robust and dependable

The Transition From Youth to Adulthood Essay Example | Topics and Well Written Essays - 1250 words

The Transition From Youth to Adulthood - Essay Example It is a journey adddressed in both The All-American Poem, by Matthew Dickman, and This is Our Youth, by Kenneth Lonergan The All-American Poem is a collection of poetry that describes a variety of experiences had by a young adult, most centered around either awakenings or memories. This Is Our Youth takes us along as two young men attempt to make a drug deal with a stolen fortune. Though the language is very different – The All-American Poem is lyrical and image-rich, This is Our Youth rough and conversational – they both reach a common conclusion: youth does not die easy. Both works characterize the transition from youth to adulthood with a period of denial, when a young person responds to an adult situation, or to the transition itself, in a childish way. Is Our Youth, for example, begins with a literal physical split between Warren and his father. Tired of Warren's pot habit, his father kicks him out of the house. Warren responds with a casualness that marks him as m ore childlike than he would care to admit: â€Å"...'there's some cash, now pack up your shit and get out before I beat your fuckin' head in. And I was like, â€Å"Whatever.' So he went on a date with his whore, and I packed up my stuff and left.† (Lonergan I.i) The leaving of one's childhood home is perhaps the most literal transition to adulthood, and here Warren responds with a shrug and one-word response worthy of any teenager. Although the langauge is less rough, a similar situation plays out in the poem â€Å"V† in The All-American Poem. The narrator is fantasizing about a girl, but the images of his fantasies are extremely childlike. â€Å"I could show her my comic books/And PlayStation. We could pull out/My old D&D cards/ and sit in the basement with a candle lit.† (Dickman 33) The contrast here between an adult action and youthful pastimes suggest that, like Warren, the narrator has not yet departed childish attitudes. Although these lines are mixed wi th references to physics and math, the lack of many adult references in this portion of the poem suggests that the narrator's thoughts are, like Warren's, more childish than he knows. The difference between the two characters, however, is that the poem's narrator engages in childlike thoughts and adult actions. Warren's situation plays out in an opposite way; the action of leaving home is adult, but his reaction to that leaving betrays a childish mindset. Childish thoughts aside, however, these situations describe the brink of adulthood in a way that becomes more obvious when the scales begin to tip. On the following page, the language of â€Å"V† becomes significantly more adult, with many sexual and physical references and stark language that startles in its transition from the poem's earlier innocence. Dickman writes, â€Å"It's been talking sleazy to all of us/And there's nothing about the hydrogen bomb/That makes me want to wear a cock ring,† and â€Å"Maybe she wants to be measured beyond/The teaspoon shadow of an anus†. (34) The more adult themes appear abruptly, invoking the image of a quick and violent change. Unsurprising because This is Our Youth is significantly longer than â€Å"V,† Warren's attitude takes longer to change. At first, he responds to his exile by stealing money from his father, with the same casual attitude: â€Å"....hopefully he'll think one of his cohorts ripped him off. Or, like, his slut did it.† (Lonergan I) But when he and his friend Dennis decide to take the money and buy

Psychology, Theology and the Spiritual Life in Christian Counseling Essay Example for Free

Psychology, Theology and the Spiritual Life in Christian Counseling Essay 1. This paper is a book review that will deal with the above work by McMinn and the nature of Christian counseling in general. The work is a whole is designed to be easily read, and reads very quickly at the price of sophistication. Its ultimate purpose is one of integration on wto levels: first, the integration of the â€Å"broken† person back into loving relationships, chiefly with God, who is a God of healing, and second, the immensely important integration of theology with the aims of counseling. Counseling without God is a far less complex affair than Christian counseling. The secular counselor can be safely utilitarian, whatever helps heal the person might be tried or advocated. However, with Christian counseling, the idea of integration is all important. Christians have a specific view of the personality that cannot be ignored in counseling. These ideas on the human personality is based around our inherent sinfulness and â€Å"brokenness. † (McMinn, 1996, 32). This is central, all of humanity is in need of counseling of some sort, but the final end of counseling, that of union with God in and by healthy relationships with other persons, provides far more difficult challenges than the more utilitarian secularist. Furthermore, the idea of the integration of the ego out of its sinful (yet natural) drive to self-sufficiency (cf. 35-40ff) is another specifically Christian idea when coupled with the important idea of Grace, the Grace that is, by its very function, a healing balm. Hence, the counselor must also know how to â€Å"give way† to grace, grace that is not in the control of the counselor. The notion of the â€Å"abuse of power† so important to the chapter on â€Å"Sin†is precisely not realizing the fact that the Christian counselor must act as a conduit of grace and not its â€Å"dispenser. † Thus, the counselor that does not realize this gap, the gap between the counselor and the will of God for the broken victim has failed in his duty. The grace for the believer is always present, and Christian counseling must have a sense that his duty is to help the victim find it. The basic thesis of the book is sound from a theological and a psychological point of view: the modern secular mentality stresses ego satisfaction and ones â€Å"control† over ones life. But this is little more than the institutionalization of original sin: this is the problem, not the solution. This desire, natural to fallen man, to be self-sufficient is the root of all psychological problems. Hence, the work takes this fundamental insight through the various ideas that develop in the process of counseling: prayer, scripture, forgiveness, etc. Each concerns itself with bringing the patient to a fuller understanding of the nature of his alienation, both from others an from God. 2. In the section on prayer, I was struck by several things, things that I recall myself going through. I was always taken aback by the attacks on prayer by both mainline psychology and society at large: why would one pray if God is all knowing? Of course this is not an easy question, and the church fathers dealt with it in some detail. I began to see prayer as being of 2 kinds: the intercessory prayer, or the literal meaning of prayer in the sense as â€Å"to ask. † This is not a part of Christian counseling to any great degree. But the second form of prayer, that of communion and oneness, is. The prayerful meditation of the ancient monks has healing properties even apart of belief. Prayer, as McMinn points out, reduces stress, creates a bond with the counselor, and places the problems of man in a theological context (66ff). The same might be said for his section on Scripture: is not Job an excellent case study for the Christian counselor? Is not David and his sins even better? (Cf. 100) It seems to me that the development of my own prayer life since being involved with counseling has more to do with dealing rather than asking. , In other words, it seems to me that pure prayer is not about asking for things: God knows what we need. Pure prayer is about dealing with that which God has given us in our own development. Suffering is no a bad thing with a prayerful attitude: it permits us to reject the world and its comforts, and to seek our rest in God alone. Christians involved in counseling should avoid, as my experience has shown, treating prayer as a means of â€Å"getting† things. This can lead to disappointment and a belief that God is merely a great cosmic vending machine that exists to grant wishes. I recall my older view that prayer was about â€Å"getting,† instead of â€Å"dealing. † Prayer as a means of communing with God in the midst of suffering is both a very Christian idea as well as a powerful tool in counseling Christians. 3. A major issue that arises from reading this book is the difficulty of the task. The author is writing for a popular audience, and hence, can not get into the deep psychology and theology necessary to make his this work. Theology is the highest of the sciences, and this is because the understanding of Christ as Logos gives both the efficient and final cause of creation, including our minds. The Logos is the being of all things so far as they exemplify a cosmic reason, an interconnectedness that makes nature understandable and law-abiding. But our problem arises, both as Christians and as counselors, when we are forced to deal with the affects of the fall: a nature that bears God’s energy (though not her person), but is only poorly reflected in our minds that have been darkened by sin. Christianity has been worried about this healing since St Gregory of Nyssa and Augustine, who have dealt with the church and the Christian life as primarily a psychological affair, an affair of the consciousness, but a consciousness whose own drives seek to obliterate God and his presence in the interests of self centeredness. The very nature of the book in question cannot get into these issues except in trite examples. The book needs to build upon Christ as Logos before any serious psychology can be done. Putting this differently, the point is that Christ is to be found in the human mind in that it bears traces, fingerprints of the creator, but the creator as the Son, the image of the Father. The cosmic reason found in all things. This is an ontological problem, one that needs to inform all Christian psychology. Th reality is that this book is far too simple, far to â€Å"easy† and cannot gt to th heart of the matter. 4. In terms of action, I want to take from McMinn’s section on Scripture. This is likely the most valuable part of the work, and Scripture, to say the least, is only rarely considered a bok of counseling or psychology. Yet, the scriptures are saturated with psychological insight. Hence, my action here is to begin bringing scriptural sources into counseling. Even with secular patients, the Bible, even if the patient does not necessarily believe its divine origin, still contains many positive and negative examples for people to consider. The sins of David, including murder, are helpful is showing the example of repentance and the fact that a spiritual giant like David can be so flawed. I might say the same of Noah, after his drunkenness. God can forgive anything. The prophets such as Jeremiah or Amos were all persecuted for their beliefs and complete refusal to compromise. For people to be treated harshly because of their faith is something Christ explicitly mentions as the lot of the Christian: scripture is about God’s presence amidst a world that does not recognize him, whether it be the establishment of Judah or the Jewish Pharisees. The Christian Will suffer–there is no getting out of that, it is built into the process of both living and counseling. Christ Himself is such an example. Therefore, in dealing with patients, the Scriptures will be the central component in counseling for the examples they contain: examples of righteous suffering, but suffering with a purpose. Suffering with a purpose is bearable, suffering for no reason is not,. There is not a major figure in the Scriptures that is not persecuted for one reason or another by a world that does not understand te godly life. For us as counselors, nothing can be more important, useful or inspiring.

Essay on Jake Barns as a Code Hero in Ernest Hemingways The Sun Also Rises :: Hemingway Sun Also Rises Essays

Jake Barns as a Code Hero in The Sun Also Rises Ernest Hemingway is a renowned American author of the Twentieth century who centers his novels on personal experiences and affections.   He is one of the authors named "The Lost Generation." He could not cope with post-war America, and therefore he introduced a new type of character in writing called the "code hero".   Hemingway is known to focus his novels around code heroes who struggle with the mixture of their tragic faults and the surrounding environment.   Traits of a typical Hemingway Code Hero are a love of good times, stimulating surroundings, and strict moral rules, including honesty.   The Code Hero always exhibits some form of a physical wound that serves as his tragic flaw and the weakness of his character.   In Ernest Hemingway's The Sun Also Rises Jake Barnes is the character who maintains the typical Code Hero qualities; while Robert Cohn provides the antithesis of a Code Hero. Jake Barnes, the narrator and main character of The Sun Also Rises, is left impotent by an ambiguous accident during World War I.   Jake's wound is the first of many code hero traits that he features. This physical wound, however, transcends into an emotional one by preventing Jake from ever consummating his love with Lady Brett Ashley.   Emotional suffering can take its toll on the Code Hero as it did with Jake Barnes.   Despite the deep love between Jake and Lady Brett, Jake is forced to keep the relationship strictly platonic and stand watch as different men float in and out of Lady Ashley's life and bed. No one other than Jake and Brett ever learn the complexity of their relationship because Jake's hopeless love for Brett and the agony it entails are restricted to scenes known to themselves alone. Therefore, Jake suffers in silence because he has learned to trust and rely only upon himself, which is conducive to the Hemingway Code as well. Jake is an American who travels to Europe to satiate his appetite for exotic landscapes and to escape his pain.   Jake tries to live his life to the fullest with drinking, partying, and sporting with friends.   With these pastimes, Jake hopes to hide from his fault and get on with the life he has been made to suffer.   Watching and participating in sports help accentuate the Code Hero's masculinity and provide the sense of pride Jake has lost.

Succubus Revealed Chapter 11

It was hard leaving Seth's side in the morning. We'd had too few nights together recently, and each day that passed only served to remind me I was that much closer to the transfer. Lying in his arms, watching him sleep in the early sunlight, I thought back to what he'd said about Andrea getting better. If that was true, if she was healing, then there was a chance the ties keeping Seth here might lessen. I felt selfish even thinking that way, but surely it wasn't too terrible a thing to wish we could all get a happy ending. After a leisurely breakfast, Seth and I went over to the Mortensens'. He was on babysitting duty while Andrea went to a doctor's appointment, and I was there to pick up Brandy. Chaos met us at the door, and Brandy practically flew outside, breathless and laughing. â€Å"Don't go in there,† she warned me, after I gave Seth a quick kiss good-bye. She and I headed toward my car. â€Å"It's crazy. Mom and Dad slept in, and Grandma let Kendall and the twins ‘help' with breakfast.† â€Å"What are they making?† â€Å"Waffles,† she said. â€Å"From scratch. I don't know which was scarier: Kendall mixing the batter or Morgan and McKenna on duty with the waffle iron. They set the smoke detector off twice.† I couldn't help but laugh as I pulled out of the driveway. â€Å"And you and Kayla didn't help?† â€Å"No way,† Brandy replied. â€Å"I stayed away from that mess, and Kayla was in one of her silent moods today.† â€Å"Aw.† I kind of wished now that I'd taken a moment to go inside. Tiny Kayla had a special place in my heart. Though she was better than she used to be, she still had a tendency to simply watch her world without a word, and it could be difficult coaxing conversation from her. Some of this was shyness, and some of this – I suspected – was from the fact that Kayla was psychic. Her skills were still undeveloped, but she was sensitive to the workings of the supernatural world, which I had to imagine would make anyone of any age silent at times. â€Å"She'll be fine. She loves waffles.† Brandy smiled, and I was happy to see her so upbeat for a change. She shouldered just as much stress as the adults. â€Å"If any actually get made.† We drove downtown, and I quizzed Brandy about what she was looking for in a dress. She had little to offer, which was both charming and kind of heartbreaking. Brandy wasn't a tomboy, but with all of her family drama, dresses had been understandably off her radar. In fact, when her face lit up at all the downtown lights and decorations, it became clear that family had really been the only thing in her life recently. â€Å"I haven't seen any of the holiday stuff this year,† she told me, gazing out the windows. A pang in my heart reminded me that this would be my last year to see Seattle in all its holiday finery. â€Å"We usually always come down here so that the girls can see Santa. There's been no time.† â€Å"The girls haven't seen Santa?† I asked, snapping out of my moment of self-pity. â€Å"That's not fair, especially considering I see a little too much of him.† It made me wonder how many drinks it would take to coax Walter into a house call. It also convinced me more than ever to make this a special day for Brandy. I couldn't expect her not to worry about her mom, but today, with Andrea on the mend and Seattle's shopping wonderland ready to explore, Brandy was entitled to worry just a little less than usual. She deserved to think about herself. I took her on a whirlwind tour of designer stores, chastising her for looking at price tags. I wanted this to be about more than the dress itself. I wanted her to have an experience, to feel like a princess. I made sure the salespeople were falling all over themselves to help her, which wasn't always so easy to do at such a busy time of the year. Brandy's radiant expression told me it was worth the effort, and we finally hit gold at our third store, finding what was unquestionably the dress. It was made of dark pink satin wrapped around to create a sheath silhouette that could still show off her figure without being pornographically tight. Satin flowers near the top added a whimsical edge, and the straps and knee-length made me feel it wouldn't get her kicked out of a church function. We spent the next hour finding the perfect shoes and jewelry for it, and although each new purchase clearly made her uneasy, she stopped questioning me about the cost. She didn't know about Margaret's f unding, but it had long since been spent. Exhausted and triumphant with our purchases, we went to lunch at an Italian restaurant frequented by other ladies of leisure. It was inside a larger, elegant shopping complex, and just as we were about to enter the restaurant, I saw a familiar face emerge from a nearby store. Something in my chest clenched, and I spoke before I could help myself. â€Å"Doug!† It took him a moment to figure out who'd called to him. When he did, a series of emotions played over his face. I wondered then how the encounter would have been different if Brandy hadn't been there. Would he have even acknowledged me? Maybe. Maybe not. But Brandy's presence guaranteed politeness. No matter how angry Doug might be at me, he wouldn't snub her. â€Å"Kincaid,† he said, strolling over to us. â€Å"And little Brandy. How's it going?† â€Å"Good,† she said cheerfully. The two of them, I realized, could have been related if Seth and Maddie had ended up getting married. The weird fallout from their breakup hadn't had as big an effect on Brandy as the rest of us, though, and she was genuinely happy to see him. â€Å"We're shopping.† He favored her with a smile, and I wondered if he was avoiding eye contact with me. â€Å"Last minute Christmas gifts?† he asked. â€Å"Not a chance,† I said. â€Å"This is all for Brandy. She's going to a dance tonight.† â€Å"Oh, I see how it is,† he said. â€Å"Getting ready to break some hearts for the holidays, huh?† She turned bright red. â€Å"No! It's at my church!† Teasing girls was familiar and easy territory for Doug. â€Å"Yeah?† he said, forcibly keeping a straight face. â€Å"Then why are you blushing? Church boys' hearts break just as easily as us sinners', you know. I'm sure you'll leave a trail of hundreds in your wake.† â€Å"No,† she protested. â€Å"Not hundreds – â€Å" â€Å"Just one?† he asked slyly. Brandy looked to me for help, and I laughed. â€Å"I knew there was someone.† â€Å"You guys are terrible,† she said, though she didn't look that upset. â€Å"Can I go put our name on the list?† â€Å"Sure,† I said, still laughing. But the instant she was inside the restaurant, Doug's playful manner vanished. â€Å"Well, I've got to go,† he said, starting to turn away. â€Å"Wait, Doug, I . . .† He looked back at me, but I was at a loss. What could I say? That I was sorry for sleeping with his sister's fiance? That I was sorry for lying to all of them and breaking her heart? How could you apologize for something like that? â€Å"It . . . it was good to see you,† I said at last. â€Å"You too,† he said, though he didn't sound convincing. He nodded toward the restaurant. â€Å"And her. I hope she has fun.† â€Å"Me too. She deserves it, what with everything else going on.† He had attempted to leave again, but my words made him pause. â€Å"How's her mom?† I shrugged. â€Å"Good days and bad days. It's up and down. . . . sometimes it seems hopeless, sometimes it's like everything's fixed. Wreaks havoc on everyone. . . . you just can't assume anything, you know? She's having some good days right now, but it's been a hard road for all of them. We just never know what's going to happen next and have to hang in there as best we can. I'm trying to help, but I don't know. . . . I don't feel like it's enough. But what could be?† I promptly shut up, realizing I was rambling. Doug said nothing, his dark eyes studying me for several heavy seconds. Then, his gaze shifted to Brandy, speaking to the hostess, for a few more moments before returning to me. â€Å"You're a good person, Kincaid,† he said softly. And this time, he did leave. Nothing else he might have said could have surprised me more. In all the imagined conversations I'd had with Doug, I'd expected frigid politeness at best – and that had seemed like a long shot. More often than not, I'd envisioned him telling me terrible, hurtful things, things I deserved. As much as a secret part of me yearned for him to forgive me so that we could be friends again, I really didn't think I deserved that forgiveness. I watched him walk away until Brandy stuck her head out from the restaurant door and called that they had a table. Despite how pensive my meeting with Doug left me, I was still able to enjoy the rest of the afternoon with Brandy. We were both in good spirits when we arrived back at the Mortensen home, and mine soared even higher when I saw Seth's car in the driveway. I hurried inside, eager to see him, only to have my mood shatter when I saw his face. Margaret and Terry wore similar expressions. Brandy, normally so observant, was too keyed up over her purchases to notice that there had been a significant mood shift in the house, compared to the bubbly chaos of this morning. â€Å"We had such a great time,† Brandy told them, face shining. â€Å"I got the best dress.† Margaret gave her a tight smile. â€Å"Why don't you try it on for us?† Brandy didn't need to be told twice, and Kendall and the twins followed her uproariously to the bedroom, offering to â€Å"help.† The instant they were gone, I turned to the adults. â€Å"What happened?† â€Å"Bad prognosis at the doctor's,† said Seth, when no one else spoke right away. â€Å"But she was improving,† I argued. I looked at them all for confirmation. â€Å"Right?† â€Å"We thought so,† said Terry. â€Å"At the very least, she seemed to be feeling better. But in these situations . . . well, cancer tricks you that way. It's why people go so long without ever knowing they have it. She woke up feeling bad this morning, and the doctor confirmed our fears.† I was kind of in awe at how calmly he managed to deliver that. I wasn't sure I could have without breaking down. Honestly, I didn't know how he'd been able to handle any of this with as much strength and determination as he had. If this were happening to the love of my life, I was pretty sure I'd crawl into in a corner and cry. Or would I? Looking at Seth, at those beloved features and compassionate expression, I suddenly knew that wasn't true. If the one I loved needed my strength, then I would give all I had within me. â€Å"We're not telling Brandy yet,† said Seth. â€Å"We're not going to keep it from her, but we figured it would be best to wait until after tonight.† I nodded slowly, having no words. I was usually so quick with a quip or soothing line, but what response could I make to that? Especially when, moments later, Brandy came bounding back down the stairs in the pink dress. Each twin held a shoe, and Kendall carried the glittering chandelier earrings we'd found just before lunch. I was reminded of Cinderella's mouse retainers. Brandy's tastes had been foremost in my mind while shopping, but I'd also had half an eye on what I thought her family would approve of in fashion. As she spun around for them, however, I realized it didn't matter. I could've brought her home in rags, and they would've loved it so long as she wore the look of radiance on her face that she did now. That was what sold it, one spot of pure joy in the dark cloud that kept hanging over this family. The adults were too overcome with emotion to speak, so Kendall did it for us. â€Å"Doesn't she look like a princess?† She kept trying to smooth nonexistent wrinkles out of the skirt, much to Brandy's dismay. â€Å"I want a dress like this.† Morgan sat down on the floor and tried to forcibly push the shoe on Brandy's foot while she still stood, furthering my Cinderella images. McKenna joined in as well, and both nearly succeeded in knocking their older sister over. â€Å"Well?† Brandy laughed. â€Å"What do you think?† â€Å"It's beautiful,† said Margaret. â€Å"You're beautiful,† said Terry. Having successfully dislodged the twins, Brandy stepped into the shoes, flushing under the praise of her family. â€Å"I hope I don't fall in these. How stupid would that look?† â€Å"I don't think anything could make you look stupid,† said Seth. â€Å"You're perfect from head to toe.† â€Å"Okay, you guys,† said Brandy, growing embarrassed. â€Å"Now you're just pushing it.† The â€Å"head to toe† comment suddenly reminded me of something. â€Å"Oh. I won't be here to do your hair. I have to go to work soon.† At that moment, calling in sick seemed like a reasonable idea. Nothing seemed more important than giving her a perfect night. â€Å"That's okay,† said Brandy. â€Å"I can do it. Or maybe Mom can.† â€Å"She's been kind of tired today,† said Terry neutrally. â€Å"But I know she'll want to see you before you leave.† â€Å"I can do a French twist,† said Margaret, surprising us all. â€Å"If you want to wear it up.† â€Å"Will you show me?† asked Brandy. Margaret nodded. â€Å"Sure, let's go upstairs.† Before they did, Brandy paused to give me a giant hug. â€Å"Thank you so much, Georgina. For everything.† They went upstairs, followed by the littler girls, all of whom thought there was nothing so wonderful as dressing up their older sister. Actually, I realized, that wasn't entirely true. Not all of them felt that way. â€Å"Where's Kayla?† I asked. She hadn't been in the entourage. Terry sighed and ran a hand through his hair, in a way similar to what I'd often seen Seth do. â€Å"In the living room, I think. She's been out of sorts today. Sometimes I think she can figure out what's going on, even when we don't tell her.† With Kayla's abilities, I didn't doubt it was true. I remembered Brandy saying Kayla had been in a â€Å"silent mood† since this morning and wondered just how much of her mother's illness the little girl was in tune with. I left the brothers to seek her out and found her curled up in a corner of the overstuffed sofa, making herself so small that she was almost lost in the cushions. â€Å"Hey, you,† I said, sitting down beside her. â€Å"How's it going? Don't you want to see Brandy's dress?† Kayla shifted her face, looking at me with huge blue eyes. â€Å"Georgina,† she said. â€Å"You have to make it stay away.† My thoughts were on the dress, so it took a moment for me to follow what she was saying. â€Å"Make what stay away, honey?† â€Å"The Darkness.† There was something in the way she said the word that let me know she wasn't referring to shadows. When she said â€Å"Darkness,† I could feel the personification in her word, the looming threat of something – or someone – tangible. With a pang, I remembered that Kayla had been able to sense Nyx when she'd escaped her angelic captors. I leaned toward Kayla, glad Seth and Terry were preoccupied. â€Å"Kayla, are you talking about . . . about the creature you felt before? The one you could sense on me?† Nyx's return would be a complication I most certainly didn't need in my life right now. She shook her head. â€Å"A different one. The Darkness comes here, to my house. To see my mommy. Will you make it go away?† â€Å"Is it here now?† I asked uneasily. â€Å"No. Just sometimes.† â€Å"How many times?† Kayla thought about it. â€Å"Two.† A cold feeling crept over me. â€Å"Was last night one of those times?† She nodded. â€Å"Have you seen it?† I asked her. â€Å"No. But I feel it. I can tell where it's at when it's here.† She peered at me beseechingly. â€Å"Will you make it stop?† I had no clue what this Darkness was or what I could do to stop it, but theories were running wild in my head. I kissed her forehead. â€Å"I'll do what I can, baby. I promise. I've got to leave now, but I'll see what I can find out for you, okay? We'll make sure the Darkness doesn't come back.† Like the flip of a switch, Kayla's whole demeanor changed. Whereas she'd been sad and withdrawn moments ago, she was now beaming and hopeful. All that faith – in me. With my empty assurance to take on something I didn't understand, she was able to put aside all of her fears and worries. All was right in her world now, thanks to me. She put her arms around me and kissed me back, and I felt like my heart would break when I finally untangled myself from her. Holiday cheer was calling, as well as a burning need to suddenly talk to Roman. Seeing as how we kept missing each other lately, I sent him a text with a reminder of when I'd be home tonight and that I had important information for him. He was so caught up in his conspiracy theories that I wasn't sure if he'd want to make time for what he'd probably see as a little girl's fantasies. Kayla's perceptions – despite her difficulties in articulating them – had proven accurate before. I didn't know what she was sensing this time, but if there was a force inside the Mortensen household, I intended to stop it.

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Luckily, I met a new English teacher in my secondary school. In that time, our class girls were enthralled by an American pop stars -Jesse McCarty. We often played his song in leisure time. The teacher knew that she used Jesses song to teach us the meaning of lyrics. Also she encouraged we should be form interest to learning. Usually she recommended American drama and movie to us. I appreciate such teacher to understand student's situation, so that since that time we concentrate on English classes till now.In addition, I am going to attend a high diploma life for 20 months. I recognize that I have to enter the society after these months so I will enjoy my student life and through the regular classes and supplementary course to improve my English tankard Indeed, I have to say that I love to attend EPA classes because I can learn different kind of English as well as some aspect of knowledge such like What is consciousness, In this topic, I may attempt to figure out what is the differen t between science and philosopher.Then, there are some passages are very interesting like exploring the nature of illness; I find that we are often insensible to use irrational methods but related to our culture. It is vital to enhance my comprehension in reading English. Moreover, there are many opportunities for students to have conversations with there in English and a lot of presentations in school. Besides, the teacher usually gives us spaces to argue and fight for our own opinions, like Do you agree canned foods is important when we are in foods of shortage?I foresee that participating in all these section, I will get my skill of presentation well. Furthermore, it can train my speaking in English fluently. Since I lack of confident on English performance, through this practice I can speak confidently in English. On the other hand, there are completely using English in classes so that I have a great environment to listen and peak English accurately What is more, I have Joined t he course of English for metropolitan life.It is a good complementary system to use at home or in school. During these 20 months, I would like to take the class, use telephone English and Join the activities to cultivate an English environment. I have heard from my classmate there are having fun in activities, he said that you are easy to express yourself in English because you are playing games. At last, In order to obtain a chance to be a university student, I would like to Join LILTS examination after 20 months. I hope that I will score 6. 5.

Essay on Pinker Essays

Essay on Pinker Essays Essay on Pinker Essay Essay on Pinker Essay Two Sides of a Bad Coin â€Å"Fucking†. How is that for a start of an essay? Does it pack a punch? Does it surprise you? Well, that is how Steven Pinker, a professor of psychology at Harvard, decided to start his article â€Å"What the F***† in The New Republic. It seems inappropriate that a Harvard professor would start any piece of writing in this way; however, as the piece goes on, his stance on cursing loses its initially crude air and becomes a more credible, scientific argument. By introducing cursing in a new scholarly light, Pinker is able to morph the reader’s initial repulsion to cursing into a thoughtful deliberation of its advantages and disadvantages. This purpose is not evident from the start though because he is preoccupied with trying to pull the readers into reading his article. He does this by first unbalancing the readers with his unconventional beginning. He then mentions the contemporary example of Bono cursing as he accepted a prize for his group to interest the readers a bit more. Finally, he drops the expletives â€Å"asshole† , â€Å"cocksucker†, and â€Å"motherfucker† all in the same sentence and finishes brilliantly with â€Å"nigger† and â€Å"cunt†. Usually this flagrant lack of indiscretions would deter the general reader from venturing on, but in Pinker’s case, the controversial nature of his beginning is utilized to hook the readers in. In this way, it is a bit like a Michael Moore movie. All of them do not take the time to be subtle and are shockingly biased. Yet, all types of people still watch his movies: liberal thinkers are attracted to the freedom with which taboos are mentioned while conservatives gravitate towards them, itching for the chance to disarm the argument. Both are interested for completely different reasons but the end result is the same: everyone is interested in learning more about the content. Unlike Michael Moore though, Pinker does not continuously pelt the reader with fact after fact, story after story, in an effort to get the reader completely on his side. He takes a more gradual approach and tries to get the reader to slowly understand his side of the story. In a matter of a few paragraphs, I was surprised to find that I, a long-time dissenter of cursing, had already become habituated to reading f, c, n, m, and etc. -bombs. I appreciated how, instead of approaching cursing as a black and white subject and having a very partisan tone, he approached it in a very technical manner. He did not handle the topic of swearing as the shunned topic it is usually treated as, but he manipulated his diction and made cursing a more sophisticated science which, according to him, â€Å"raises many other puzzles† and incorporates â€Å"linguistic, neurobiological, literary, [and] political† issues. Who has ever described cursing using these types of words? He then goes on to analyze the different parts of the brain-the limbic system and the neocortex-which are activated when people curse. He even categorizes cursing into different types as a biologist would categorize different cell types. There is cathartic swearing, there is vulgar swearing, and there are figures of speech swearing. When I first read the article, it seemed that he was simply using this technical jargon to make his argument more intellectual and credible; however, it soon became clear that although his utilization of language did accomplish this feat, it was also a technique of his to get the reader to a less prejudiced standpoint about cursing. Children grow up under the impression that cursing is wrong. Some children grow up to respect this belief and not curse while others decide to rebel and curse. Both sides though have their one-dimensional viewpoints in common. Cursing is rarely ever a neutral ground of conversation for anyone, but Pinker, by analyzing and discussing cursing, is able to separate the reader from the negative connotations of cursing just long enough so he could insert the idea that there is a beneficial side of cursing. He understands that people feel comfortable with facts so he takes his evaluation and observations of cursing and throws it at the reader so they think about the data instead of dwelling on the negative undertone of the topic being discussed. Then, at the end, he finally introduces arguments which are pro-cursing. According to psychology, everyone has a confirmation bias: a tendency for people to only rely upon information which confirms their beliefs and disregard material which does not. If Pinker had just listed reasons cursing was fine from the beginning, the reader would have probably either taken them in hungrily or downright rejected them according to their opinions. As a professor of psychology at Harvard, Pinker was probably well aware of this occurrence and therefore decided to soften the readers’ predispositions to cursing and then persuade them. As support for his pro-cursing stance, he states how cursing is necessary sometimes because of the extra flavor that it can add to a conversation and that sometimes the employment of a curse word is the most effective way to express a certain sentiment. Pinker refers to the film adaptation of Isaac Bashevis Singer’s Enemies: A Love Story Curse in which a Polish girl curses after being slapped by a her Jewish husband who she had hid, fed, and kept safe during the Nazi occupation. In this awful situation there are no other words which could have had the same impact in such a concise manner. She had every right to curse at her husband. Pinker also mentions that cursing has lost much of the crude image it used to have and that many people, even people in high positions, curse frequently. To support his point Pinker referred to the colorful usage of the English language by Lyndon Johnson, our former president, to illustrate how common cursing is in everyday society and that even people who would not be expected to curse do. Since everyone is cursing it cannot possibly be that bad. As per Pinker, swear words are nothing to be feared or dreaded; they are just words in the English Language which can be used whenever necessary and just like any other word, there is no need to over-use them, but in the correct situation, they can be the perfect words to evoke a feeling and impart the full impacted desired. It still seems a bit strange that a Harvard professor would decide to write an article that seems as casual as this- a more scholarly article would seem more appropriate. But, I think he made a wise choice of deferring from the usual course of action because the techniques which he applied were very effective. Although I still feel that cursing is wrong and I don’t feel very comfortable with it, Pinker has successfully tempered my attitude towards it and has given me a new understanding of cursing.

Although the foetus has no right to life, its interests are adequately protected by English law.

There is currently no direct right to life that is provided to a foetus, yet the law in the UK does make some attempt to protect its interests. This essay will focus on the interests that are provided to foetus’ in order to consider whether adequate protection is in place. In doing so, it will be examined whether every woman should have a right to abortion on demand or whether the interests of the foetus should be given due consideration. Accordingly, it will be shown that because there are arguments for and against the interests of the foetus, it is necessary for the law to strike a balance between the two competing interests. This does appear to have been achieved to a certain degree since the interests of the mother are being preserved, whilst also providing some protection to the foetus. The right to life The right to life is provided to all individuals under Article 2 of the European Convention of Human Rights (ECHR) 1951, as incorporated by the Human Rights Act (HRA) 1998. Whether or not a foetus has a right to life, however, is a highly contested topic because although the foetus does not have a right to life per se, it appears as though its interests are still being protected by the law to a certain extent.[1] On the one hand, it is believed that all women should have the right to do as they wish with their own bodies and that they should therefore have a right to abortion, yet on the other it is believed that the interests of a foetus should be provided with adequate protection.[2] The law in England does seem to have attempted to strike a balance between these two competing interests by permitting abortion, whilst at the same time imposing some restrictions. Under English law (Human Fertilisation and Embryology Act 1990) abortion is permitted until the 24th week of a pregnancy. Whilst this provides women with the right to choose what to do with their own bodies, it prevents them from having abortions in the later stages of pregnancy. Because abortion is not legally available at the request of the woman, it has been argued by the Abortion Rights Campaign that; â€Å"women’s access to abortion can be and is still threatened.†[3] This is because, once a woman has decided that she wants to have an abortion, she will first be required to persuade two doctors to agree to her decision taking into consideration certain restrictive legal criteria.[4] Therefore, even though women are capable of having an abortion up until the 24th week of pregnancy, it will be the doctors that make the final decision. And, if they do not agree that the relevant criterion has been satisfied, they will not have to carry out the abortion. This protection is in place to enable the rights of the unborn child to be ascertained in circumstances which would render an abortion unlawful. However, the extent to which such rights are being adequately protected is in fact arguable. Confliction continues to arise in this area because of the difficultly in striking a balance between the rights of the foetus and the rights of the mother. It cannot be said that this balance is currently being achieved as there remains strong opposition of both viewpoints. As pointed out by Mason and Laurie; â€Å"attitudes to abortion depend almost entirely on where the holder stands in respect of, on the one hand, the foetal interests in life and, on the other, a woman’s right to control her own body.†[5] Consequently, because the difference in opinions is based upon moral values rather than empirical facts, it is unlikely that such confliction will ever be resolved.[6] In effect, it is unlikely that a solid understanding of the rights in this area will ever be made as the controversy surrounding abortion will continue to exist. The Foetus’ Right to Life It is believed that the Abortion Act 1967 violates Article 2 of the Convention on the Rights of the Child on the basis that a child’s rights are not being adequately protected if women are able end their pregnancy if they so wish.[7] Section 1 of the 1967 Act provides that; â€Å"a person shall not be guilty of an offence under the law relating to abortion when a pregnancy is terminated by a registered medical practitioner.† In effect, women will not be found guilty of an offence is they decide to have an abortion. Whilst this section does appear to undermine the rights of the foetus, the fact that the termination must be conducted by a registered medical practitioner acting in good faith suggests that some form of protection will still be in place. Furthermore, as put by Herring; â€Å"for an abortion to be lawful, the abortion must comply with the requirements of the 1967 Abortion Act.†[8] Section 1 will therefore only apply if certain provisions can also be sa tisfied. Nevertheless, because abortions are rarely ever refused, it could be said that the provisions under Article 2 are being undermined and that the interests of the foetus are not, in reality, being adequately protected. In view of this, it has therefore been argued by Foster that the 1967 Act is not being used in the way that Parliament intended and that abortion are instead being used as another form of contraception.[9] This demonstrates how abortion is easily accessible to women, which limits the protection that is currently being provided to the foetus. It is likely that doctors will only refuse to conduct an abortion if the woman’s pregnancy has gone past the 24 week threshold or if the circumstances are exceptional. This signifies how the rights of unborn children are not being preserved, yet it is debatable whether further protections ought to be in place. The right to life is an extremely sensitive subject since it basically provides a right to every human being not be killed.[10] However, much complexity exists when considering the right to life in the context of unborn children. It is difficult to determine whether the mother’s rights should prevail over the rights of the unborn child or vice versa. However, it has been said that the right to life is a human right that is â€Å"inviolable and must be protected at all costs.†[11] If this statement was to be taken strictly, every abortion would be considered a violation of one’s human rights and would not be permitted. However, in order to ensure that the rights of the mother are also being protected it is necessary that abortions are permitted in certain circumstances. This would ensure that a balance is attained between the two competing interests by allowing abortions to take place only if it is deemed necessary. Consequently, abortions should not be used carelessly as another form of contraception and this would means that the rights of the mother are being given greater consideration than the rights of the foetus. Abortions should therefore not be as accessible as they currently are and should only be permitted in limited situations. It is unclear what extent the interests of the foetus are actually being considered and it seems as though the right to life is being violated by the abortion process and so further protections may need to be provided to the foetus so that the rights of unborn children are given the same considerations as the mother. At present, it appears as though the rights of the mother prevail over the rights of the foetus, despite the restrictions that are in place. In order to ensure that the foetus right to life is being protected, it is necessary to impose further restrictions upon the mother’s ability to have an abortion. At present, a mother is capable of aborting a foetus for various reasons including the fact that the child will suffer from a disability. Many people do not agree that this should be a reason to end the life of a foetus, though it is legal in the UK for a woman to abort a baby on grounds of disability up to birth. As a result of this many parents opt for an abortion if pre-natal screening reveals that their baby is suffering from a disability. Moreover, it has also been suggested that the parents are even put under pressure to do so.†[12] The Society for the Protection of Unborn Children strongly disagrees with this approach and believes that; â€Å"a person with a disab ility has the right to life along with every other member of society: aborting a baby because he or she has, or even might have, a disability, is the ultimate form of discrimination.†[13] It cannot be said that the foetus’ right to life is being upheld as a result of this since they can be terminated at any point if they are found to have a disability. Not only does this undermined their right to life but it also discriminates against them on the grounds of their disability. As such, the provisions under the Disability Discrimination Act 1995 are too not being complied with. In Vo v France,[14] however, it was made clear that Article 2 of the Convention is â€Å"silent as to the temporal limitations of the right to life, and in particular does not define ‘everyone’ whose life is protected by the Convention.† Effectively, it is clear that because Article 2 does not provide a definition as to who shall be protected, it is likely that the rights of the foetus will continue to be restricted. Jackson does not believe that the moral status of the foetus should be sufficiently wide enough to make abortion unlawful,[15] however, and it seems as though the European Court of Justice is also reluctant as identified in Open Door and Dublin Well Woman v Ireland.[16] Furthermore, in the case of X v United Kingdom[17] the ECJ also stated that the right to life would be subject to an implied limitation in order to respect the mother’s life even if this was at the expense of the foetus’ right to life under Article 2. Furthermore, it was also expressed in Paton v United Kingdom[18] that; â€Å"the life of the foetus is intimately connected with, and cannot be regarded in isolation from, the life of the pregnant woman.† This limited the rights of the foetus even further as it was demo nstrated that the right to life under Article 2 was not available even though the abortion was not considered necessary to protect the life of the mother. This was also identified in H v Norway,[19] which illustrates that even if an abortion occurred as a result of the mother’s choice and there lacked any specific reason for terminating the pregnancy, Article 2 will still not be capable of providing protection to a foetus if this is at the expense of the mothers rights. This seems to indicate that unborn children are not actually provided with any rights despite the fact that Article 2 initially seemed to protect such interests. The termination of a pregnancy will continue to be a morally and ethically complex issue, particularly if the reason for aborting relates to a foetal abnormality.[20] It has been pointed out that a clear legal framework is needed because of the complexities that exist in this area, though it was noted that this continues to prove extremely difficult to create.[21] The Rights of the Mother Whilst it is believed by many that the rights of the foetus should be given due consideration, it is equally argued that the rights of women should be considered foremost when deciding whether an abortion is lawful or not. This was shown in Roe v Wade[22] where it was made clear by the Court that a person has a right to abortion unless the foetus has become viable. This means that the foetus does not become a human being until it is capable of living outside the mother’s womb without any artificial aid.[23] Although this decision was made by a Court in the US, it sparked a significant amount of debate. It was argued on the one hand that a foetus becomes a child whilst it is still in the womb and that the decision whether or not to allow abortion to take effect should not be based upon whether a foetus has the capacity to enjoy life as a person.[24] It has been said that the decision in this case effectively allows an abortion on demand to take place.[25] On the other hand, how ever, it has been expressed by Loveland that; â€Å"the judgment neither produced abortion on demand nor allowed states to prevent late-stage terminations.†[26] The decision in Planned Parenthood v Casey[27] imposed further limitations on the rights of the mother when it was found that the viability period would be reduced from 24 weeks to 22 weeks. It is questionable whether this was sufficient in ensuring that the right to life of the foetus under Article 2 was being provided with greater protection since the rights of the mother will continue to prevail in the majority of situations. It could be said that it is necessary for the mother’s rights to be ascertained over the rights of the unborn child because women should be regarded as individuals as opposed to being merely containers for the foetus. In accordance with this, greater consideration should be given to the rights of the mother, though some protections should also be available for the unborn.[28] Arguably, it is important that both the rights of the mother and the unborn child shall be considered, though much more weight ought to be given to the mother’s interests as she is already considered a viable person. It has been contended by Herring that; â€Å"women who want an abortion should not be required to continue with the pregnancy.†[29] Therefore, although Article 2 expressly states that the right to life is to apply to â€Å"everyone†, the extent to which this applies to the foetus is arguable in view of the confliction that exists between the rights of the mother and the rights of the foetus. In A-G’s Reference (No 3 of 119)[30] it was noted that a foetus is not regarded as a â€Å"person† and will therefore not be directly protected by Article 2 of the Convention. It was further added that the only right to life in which a foetus has is implicitly limited by the mother’s rights and interests. This suggests that a foetus will only be provided with the right to life indirectly from the mothers right under Article 2. It is unclear whether this completely undermines a foetus’ right to life, though it seems likely given that that Article 2 will not be violated if a pregnancy is terminated. The Courts have expressed great reluctance to elucidate on this matter, by assessing whether Article 2 will provide rights to the foetus or not, because of the existing moral and ethical considerations. As a result, great complexity continues to exist within this area of the law and unless Article 2 is more clearly defined, complexity will continue to ensue. Yet, because of the moral issues that are prevalent throughout, it seems as though a single approach would not be workable. Therefore, the decision as to whether an abortion should be permitted or not will continue to be decided on a case by case basis. As such, it will depend primarily upon the circumstances of each case. This allows a certain degree of flexibility to exist which is necessary given that each case will differ from the next. However, it is likely that the rights of the mother will continue to be favoured over the rights of the unborn child. Nevertheless, because of the politics that surround abortion, the European Court of Human Rights has been said to be â€Å"wary of making a general rule concerning the legal status of the foetus, preferring to leave this question to the margin of appreciation.†[31] It cannot be said that this is acceptable given the ambiguity that arises within this area. But because there is no right or wrong answer as to whether the rights of the mother should prevail over the rights of the foetus the legal status of the foetus could not be defined by the Courts without attracting opposition. It could be said that the UK has made some attempt to identify the rights of the foetus despite the fact that no right to life exists, yet the extent to which these interests are being protected will be likely to remain debated. When the case of Vo was brought before the ECHR they appeared to focus more on the question as to when life begins as well the nature and characteristics of the foetus, as opposed to focusing on the relationship between the mother and her potential child and the others right to reproductive freedom and autonomy.[32] Therefore, the approach taken by the ECHR should have been based upon the recognition of foetal interests as well as the loss of a mother’s relationship. Whilst this would not have addressed all of the difficulties that arise in this area, it would have provided some recognition as to the interests of the foetus. Much more needs to be done if foetal interests are to be provided with greater protected, whilst at the same time maintaining the rights of the mother. The rights of the mother appear to be protected in favour of the rights of the foetus, yet it has been said that this ensure the human dignity of the mother is being preserved.[33] This is because if a mother was not provided with the choice to terminate a pregnancy, it is likely that their human dignity would be violated. Whilst this this may be at the expense of the rights enshrined in Article 2, it is deemed necessary in protecting the mother’s interests. Balancing the Rights It is doubtful that the rights of the foetus and the rights of the mother are being balanced since the rights of the foetus continue to be undermined. Whilst there are some protections in place to preserve the interests of the foetus, these do not appear sufficient and so it seems as though tighter restrictions ought to be implemented to ensure that abortion is not easily accessible. This would allow for a more acceptable balance to be attained because at present it seems to be largely one-sided. If abortion was only permitted in extreme circumstances, it would not be capable of being used as another form of contraception and the interests of the foetus would be better recognised. On the contrary, it is argued that further limitations would limit the mothers freedom to choose and their own rights would be undermined if Article 2 was to provide express rights to unborn children. Therefore, whilst abortion should still be permitted, limitations should be imposed so that the rights of the foetus are given better protection. It is unclear whether judges should be left to make a decision on whether an abortion is lawful or not since opinions will differ significantly on this subject. Thus, it cannot be said that judges should be left to decide upon moral issues. Whilst one judge may agree with abortion, another judge may not as individuals have different perceptions on what is and what is not morally right. This is why the courts have been quite reluctant to use a single approach when deciding upon the interests of a foetus and it seems that the matter is better left undefined. This was identified by Sandel when it was argued that there are differences of opinions as to whether abortion is morally reprehensible and therefore worthy of prohibition, whilst many avoid passing judgment on the morality of these practices.[34] The ECHR appears to have adopted the latter approach, by failing to provide a decision on the legal status of foetus’. This lack of definition may actually be in the interests of the foetus since rights are capable of being provided that may not have been had a definition been in place. The determination as to whether abortion should be a mother’s choice or not will be capable of being assessed differently in all cases. This is necessary given the diverging opinions that exist since it will continue to be argued by many that Article 2 should provide a right to â€Å"anyone† including unborn children, whilst others will continue to be of the view that the decision should be left with the freedom of choice as protected u nder Article 13 of the Convention. The current practice that is being adopted in striking a balance between the two competing interests does appear to be the most plausible approach to take since each case will be determined by its facts. This could, however, lead to judicial activism occurring, which appears to have happened in the Roe case above which was described by Thielen as â€Å"an incredible reach of judicial activism.†[35] Judicial activism occurs when a ruling is said to be based upon political or personal considerations as opposed to being based upon existing law.[36] Therefore, if when Courts are provided with the ability to decide upon matters concerning abortion, judicial activism is likely to emerge which undermines social policy and, in some instances, human rights. Still, as put forward by Ewing and Gearty; â€Å"English judges have shown a powerful engagement with the rights of the unborn in the past,†[37] yet whether violations of one’s huma n rights are arising out of this is likely and it seems quite difficult for a balance to be achieved between the rights of the unborn with the rights of the mother. Conclusion This area is extremely controversial and because of this it is difficult for legislators as well as the judiciary to make a decision as to whether a foetus does have rights. Many people are of the view that every woman should have the right to choose whether or not to have an abortion, yet not all agree with this. Instead, it is argued that women are capable of using abortion as a form of contraception because of how easily accessible it is. Whilst there are some restraints in place to prevent this from happening, such as the requirement to obtain permission from two doctors, it cannot be said that such measures are effective. This is because it is highly unlikely that an abortion would be refused unless the stages of pregnancy have gone past the 24 week threshold. Furthermore, because women are permitted to have an abortion past this stage if the unborn child is suffering from a disability, the rights of the foetus are being undermined even further. It is therefore questionable whet her the current law is effective in preserving the interests of the foetus since the law has not made it difficult for abortions to be performed. Therefore, it could be said that further restrictions are needed so as to balance the rights of the mother with the rights of the unborn child. Conversely, because there is a limit on the number of weeks a person can abort a foetus, it could be said that their interests are being adequately protected to a certain degree. Whether this is sufficient, however, is likely to remain a contestable subject for many years to come as there will continue to be differing opinions as to whether abortion should be so easily available. In effect, there are both strengths and weaknesses for right to abortion, yet it is questionable whether the strengths do in fact outweigh the weaknesses. BIBLIOGRAPHY Cases: A-G’s Reference (No 3 of 119) [1998] AC 245 H v Norway (1992) 73 D R 155 Open Door and Dublin Well Woman v Ireland (1992) 14 EHRR 244 Paton v United Kingdom (1980) 3 EHRR 408 Planned Parenthood v Casey (1992) 404 U.S. 833 Roe v Wade (1973) 410 U.S. 113 Vo v France Judgement of 8 July 2004 40 EHRR 12 X v United Kingdom (1980) 19 D R 244 Legislation: Abortion Act 1967 Disability Discrimination Act 1995 European Convention of Human Rights 1951 Human Fertilisation and Embryology Act 1990 Human Rights Act 1998 Textbooks: Herring, J. Law Express: Medical Law (Revision Guide), Longman, 2nd Edition, (2009). Herring, J. Medical Law and Ethics, OUP Oxford, 3rd Edition, (2010). Hope, T., Savulescu, J. and Hendrick, J. Medical Ethics and Law: The Core Curriculum, Churchill Livingstone, 2nd Edition, (2008). Kaczor, C., The Ethics of Abortion: Women’s Rights, Human Life, and the Question of Justice, (Routledge: London, 2013). Kennedy, I., Grubb, A., Laing, J. and McHale, J. Principles of Medical Law, OUP Oxford, 3rd Edition, (2010). Jackson, E. Medical Law: Text, Cases and Materials (Text, Cases and Materials), OUP Oxford, 2nd Edition, (2009). Mason, K. and Laurie, G. Mason and McCall Smith’s Law and Medical Ethics, OUP Oxford, 8th Edition, (2010). Articles: Abortion Rights Campaign, Why women need a modern abortion, law and better services, Available [Online] at: http://www.abortionrights.org.uk/content/view/180/121/ BBC, Women’s Rights Arguments in Favour of Abortion, Ethics Guide, (1992), Available [Online] at: http://www.bbc.co.uk/ethics/abortion/mother/for_1.shtml K.D and Gearty. CA, Terminating Abortion RightsNew Law Journal, 142 NLJ 1969, Issue 6579, (04 December, 1992). C, Forty Years On, New Law Journal, 157 NLJ 1517, Issue 7295, (02 November, 2007). Frankenburg, G., ‘Human Rights and the Belief in a Just World’ International Journal of Constitutional Law, Volume 12, Issue 1. Holetzky, S. What is Judicial Activism(04 February, 2010), Available [Online] at: http://www.wisegeek.com/what-is-judicial-activism.htm Human Rights, Right to Life: Not just an abortion issue, Available [Online] at: http://www.abouthumanrights.co.uk/right-life-not-just-abortion-issue.html I, A Vacancy in the Supreme Court, New Law Journal, 144 NLJ 537, Issue 6644, (22 April, 1994). McCrudden, C. Human Dignity and Judicial Interpretation of Human Rights, European Journal of International Law, EJIL 2008 19 (655), Issue 4, (01 September, 2008). O’Donovan, K. Commentary, Medical Law Review, Med Law Rev 2006 14 (115), (01 March, 2006). Sandel, M. J. Symposium: Law, Community, and Moral Reasoning Moral Argument and Liberal Toleration: Abortion and Homosexuality, California Law Review, 77 Calif. L. Rev. 521, (May, 1989). The Society for the Protection of Unborn Children, SPUC, Abortion and disability or eugenic abortion, Available [Online] at: http://www.spuc.org.uk/students/abortion/disability Thielen, D. Overturn Roe v Wade, Liberal and Loving It, (2005), Available [Online] at: http://www.davidthielen.info/politics/2005/08/overturn_roe_vs.html Wicks, E., Wyldes, M. and Kilby, M. Late Termination of Pregnancy for Foetal Abnormality: Medical and Legal Perspectives, Medical Law Review, Med Law Rev 2004.12 (285), (01 September, 2004). Although the foetus has no right to life, its interests are adequately protected by English law. There is currently no direct right to life that is provided to a foetus, yet the law in the UK does make some attempt to protect its interests. This essay will focus on the interests that are provided to foetus’ in order to consider whether adequate protection is in place. In doing so, it will be examined whether every woman should have a right to abortion on demand or whether the interests of the foetus should be given due consideration. Accordingly, it will be shown that because there are arguments for and against the interests of the foetus, it is necessary for the law to strike a balance between the two competing interests. This does appear to have been achieved to a certain degree since the interests of the mother are being preserved, whilst also providing some protection to the foetus. The right to life The right to life is provided to all individuals under Article 2 of the European Convention of Human Rights (ECHR) 1951, as incorporated by the Human Rights Act (HRA) 1998. Whether or not a foetus has a right to life, however, is a highly contested topic because although the foetus does not have a right to life per se, it appears as though its interests are still being protected by the law to a certain extent.[1] On the one hand, it is believed that all women should have the right to do as they wish with their own bodies and that they should therefore have a right to abortion, yet on the other it is believed that the interests of a foetus should be provided with adequate protection.[2] The law in England does seem to have attempted to strike a balance between these two competing interests by permitting abortion, whilst at the same time imposing some restrictions. Under English law (Human Fertilisation and Embryology Act 1990) abortion is permitted until the 24th week of a pregnancy. Whilst this provides women with the right to choose what to do with their own bodies, it prevents them from having abortions in the later stages of pregnancy. Because abortion is not legally available at the request of the woman, it has been argued by the Abortion Rights Campaign that; â€Å"women’s access to abortion can be and is still threatened.†[3] This is because, once a woman has decided that she wants to have an abortion, she will first be required to persuade two doctors to agree to her decision taking into consideration certain restrictive legal criteria.[4] Therefore, even though women are capable of having an abortion up until the 24th week of pregnancy, it will be the doctors that make the final decision. And, if they do not agree that the relevant criterion has been satisfied, they will not have to carry out the abortion. This protection is in place to enable the rights of the unborn child to be ascertained in circumstances which would render an abortion unlawful. However, the extent to which such rights are being adequately protected is in fact arguable. Confliction continues to arise in this area because of the difficultly in striking a balance between the rights of the foetus and the rights of the mother. It cannot be said that this balance is currently being achieved as there remains strong opposition of both viewpoints. As pointed out by Mason and Laurie; â€Å"attitudes to abortion depend almost entirely on where the holder stands in respect of, on the one hand, the foetal interests in life and, on the other, a woman’s right to control her own body.†[5] Consequently, because the difference in opinions is based upon moral values rather than empirical facts, it is unlikely that such confliction will ever be resolved.[6] In effect, it is unlikely that a solid understanding of the rights in this area will ever be made as the controversy surrounding abortion will continue to exist. The Foetus’ Right to Life It is believed that the Abortion Act 1967 violates Article 2 of the Convention on the Rights of the Child on the basis that a child’s rights are not being adequately protected if women are able end their pregnancy if they so wish.[7] Section 1 of the 1967 Act provides that; â€Å"a person shall not be guilty of an offence under the law relating to abortion when a pregnancy is terminated by a registered medical practitioner.† In effect, women will not be found guilty of an offence is they decide to have an abortion. Whilst this section does appear to undermine the rights of the foetus, the fact that the termination must be conducted by a registered medical practitioner acting in good faith suggests that some form of protection will still be in place. Furthermore, as put by Herring; â€Å"for an abortion to be lawful, the abortion must comply with the requirements of the 1967 Abortion Act.†[8] Section 1 will therefore only apply if certain provisions can also be sa tisfied. Nevertheless, because abortions are rarely ever refused, it could be said that the provisions under Article 2 are being undermined and that the interests of the foetus are not, in reality, being adequately protected. In view of this, it has therefore been argued by Foster that the 1967 Act is not being used in the way that Parliament intended and that abortion are instead being used as another form of contraception.[9] This demonstrates how abortion is easily accessible to women, which limits the protection that is currently being provided to the foetus. It is likely that doctors will only refuse to conduct an abortion if the woman’s pregnancy has gone past the 24 week threshold or if the circumstances are exceptional. This signifies how the rights of unborn children are not being preserved, yet it is debatable whether further protections ought to be in place. The right to life is an extremely sensitive subject since it basically provides a right to every human being not be killed.[10] However, much complexity exists when considering the right to life in the context of unborn children. It is difficult to determine whether the mother’s rights should prevail over the rights of the unborn child or vice versa. However, it has been said that the right to life is a human right that is â€Å"inviolable and must be protected at all costs.†[11] If this statement was to be taken strictly, every abortion would be considered a violation of one’s human rights and would not be permitted. However, in order to ensure that the rights of the mother are also being protected it is necessary that abortions are permitted in certain circumstances. This would ensure that a balance is attained between the two competing interests by allowing abortions to take place only if it is deemed necessary. Consequently, abortions should not be used carelessly as another form of contraception and this would means that the rights of the mother are being given greater consideration than the rights of the foetus. Abortions should therefore not be as accessible as they currently are and should only be permitted in limited situations. It is unclear what extent the interests of the foetus are actually being considered and it seems as though the right to life is being violated by the abortion process and so further protections may need to be provided to the foetus so that the rights of unborn children are given the same considerations as the mother. At present, it appears as though the rights of the mother prevail over the rights of the foetus, despite the restrictions that are in place. In order to ensure that the foetus right to life is being protected, it is necessary to impose further restrictions upon the mother’s ability to have an abortion. At present, a mother is capable of aborting a foetus for various reasons including the fact that the child will suffer from a disability. Many people do not agree that this should be a reason to end the life of a foetus, though it is legal in the UK for a woman to abort a baby on grounds of disability up to birth. As a result of this many parents opt for an abortion if pre-natal screening reveals that their baby is suffering from a disability. Moreover, it has also been suggested that the parents are even put under pressure to do so.†[12] The Society for the Protection of Unborn Children strongly disagrees with this approach and believes that; â€Å"a person with a disab ility has the right to life along with every other member of society: aborting a baby because he or she has, or even might have, a disability, is the ultimate form of discrimination.†[13] It cannot be said that the foetus’ right to life is being upheld as a result of this since they can be terminated at any point if they are found to have a disability. Not only does this undermined their right to life but it also discriminates against them on the grounds of their disability. As such, the provisions under the Disability Discrimination Act 1995 are too not being complied with. In Vo v France,[14] however, it was made clear that Article 2 of the Convention is â€Å"silent as to the temporal limitations of the right to life, and in particular does not define ‘everyone’ whose life is protected by the Convention.† Effectively, it is clear that because Article 2 does not provide a definition as to who shall be protected, it is likely that the rights of the foetus will continue to be restricted. Jackson does not believe that the moral status of the foetus should be sufficiently wide enough to make abortion unlawful,[15] however, and it seems as though the European Court of Justice is also reluctant as identified in Open Door and Dublin Well Woman v Ireland.[16] Furthermore, in the case of X v United Kingdom[17] the ECJ also stated that the right to life would be subject to an implied limitation in order to respect the mother’s life even if this was at the expense of the foetus’ right to life under Article 2. Furthermore, it was also expressed in Paton v United Kingdom[18] that; â€Å"the life of the foetus is intimately connected with, and cannot be regarded in isolation from, the life of the pregnant woman.† This limited the rights of the foetus even further as it was demo nstrated that the right to life under Article 2 was not available even though the abortion was not considered necessary to protect the life of the mother. This was also identified in H v Norway,[19] which illustrates that even if an abortion occurred as a result of the mother’s choice and there lacked any specific reason for terminating the pregnancy, Article 2 will still not be capable of providing protection to a foetus if this is at the expense of the mothers rights. This seems to indicate that unborn children are not actually provided with any rights despite the fact that Article 2 initially seemed to protect such interests. The termination of a pregnancy will continue to be a morally and ethically complex issue, particularly if the reason for aborting relates to a foetal abnormality.[20] It has been pointed out that a clear legal framework is needed because of the complexities that exist in this area, though it was noted that this continues to prove extremely difficult to create.[21] The Rights of the Mother Whilst it is believed by many that the rights of the foetus should be given due consideration, it is equally argued that the rights of women should be considered foremost when deciding whether an abortion is lawful or not. This was shown in Roe v Wade[22] where it was made clear by the Court that a person has a right to abortion unless the foetus has become viable. This means that the foetus does not become a human being until it is capable of living outside the mother’s womb without any artificial aid.[23] Although this decision was made by a Court in the US, it sparked a significant amount of debate. It was argued on the one hand that a foetus becomes a child whilst it is still in the womb and that the decision whether or not to allow abortion to take effect should not be based upon whether a foetus has the capacity to enjoy life as a person.[24] It has been said that the decision in this case effectively allows an abortion on demand to take place.[25] On the other hand, how ever, it has been expressed by Loveland that; â€Å"the judgment neither produced abortion on demand nor allowed states to prevent late-stage terminations.†[26] The decision in Planned Parenthood v Casey[27] imposed further limitations on the rights of the mother when it was found that the viability period would be reduced from 24 weeks to 22 weeks. It is questionable whether this was sufficient in ensuring that the right to life of the foetus under Article 2 was being provided with greater protection since the rights of the mother will continue to prevail in the majority of situations. It could be said that it is necessary for the mother’s rights to be ascertained over the rights of the unborn child because women should be regarded as individuals as opposed to being merely containers for the foetus. In accordance with this, greater consideration should be given to the rights of the mother, though some protections should also be available for the unborn.[28] Arguably, it is important that both the rights of the mother and the unborn child shall be considered, though much more weight ought to be given to the mother’s interests as she is already considered a viable person. It has been contended by Herring that; â€Å"women who want an abortion should not be required to continue with the pregnancy.†[29] Therefore, although Article 2 expressly states that the right to life is to apply to â€Å"everyone†, the extent to which this applies to the foetus is arguable in view of the confliction that exists between the rights of the mother and the rights of the foetus. In A-G’s Reference (No 3 of 119)[30] it was noted that a foetus is not regarded as a â€Å"person† and will therefore not be directly protected by Article 2 of the Convention. It was further added that the only right to life in which a foetus has is implicitly limited by the mother’s rights and interests. This suggests that a foetus will only be provided with the right to life indirectly from the mothers right under Article 2. It is unclear whether this completely undermines a foetus’ right to life, though it seems likely given that that Article 2 will not be violated if a pregnancy is terminated. The Courts have expressed great reluctance to elucidate on this matter, by assessing whether Article 2 will provide rights to the foetus or not, because of the existing moral and ethical considerations. As a result, great complexity continues to exist within this area of the law and unless Article 2 is more clearly defined, complexity will continue to ensue. Yet, because of the moral issues that are prevalent throughout, it seems as though a single approach would not be workable. Therefore, the decision as to whether an abortion should be permitted or not will continue to be decided on a case by case basis. As such, it will depend primarily upon the circumstances of each case. This allows a certain degree of flexibility to exist which is necessary given that each case will differ from the next. However, it is likely that the rights of the mother will continue to be favoured over the rights of the unborn child. Nevertheless, because of the politics that surround abortion, the European Court of Human Rights has been said to be â€Å"wary of making a general rule concerning the legal status of the foetus, preferring to leave this question to the margin of appreciation.†[31] It cannot be said that this is acceptable given the ambiguity that arises within this area. But because there is no right or wrong answer as to whether the rights of the mother should prevail over the rights of the foetus the legal status of the foetus could not be defined by the Courts without attracting opposition. It could be said that the UK has made some attempt to identify the rights of the foetus despite the fact that no right to life exists, yet the extent to which these interests are being protected will be likely to remain debated. When the case of Vo was brought before the ECHR they appeared to focus more on the question as to when life begins as well the nature and characteristics of the foetus, as opposed to focusing on the relationship between the mother and her potential child and the others right to reproductive freedom and autonomy.[32] Therefore, the approach taken by the ECHR should have been based upon the recognition of foetal interests as well as the loss of a mother’s relationship. Whilst this would not have addressed all of the difficulties that arise in this area, it would have provided some recognition as to the interests of the foetus. Much more needs to be done if foetal interests are to be provided with greater protected, whilst at the same time maintaining the rights of the mother. The rights of the mother appear to be protected in favour of the rights of the foetus, yet it has been said that this ensure the human dignity of the mother is being preserved.[33] This is because if a mother was not provided with the choice to terminate a pregnancy, it is likely that their human dignity would be violated. Whilst this this may be at the expense of the rights enshrined in Article 2, it is deemed necessary in protecting the mother’s interests. Balancing the Rights It is doubtful that the rights of the foetus and the rights of the mother are being balanced since the rights of the foetus continue to be undermined. Whilst there are some protections in place to preserve the interests of the foetus, these do not appear sufficient and so it seems as though tighter restrictions ought to be implemented to ensure that abortion is not easily accessible. This would allow for a more acceptable balance to be attained because at present it seems to be largely one-sided. If abortion was only permitted in extreme circumstances, it would not be capable of being used as another form of contraception and the interests of the foetus would be better recognised. On the contrary, it is argued that further limitations would limit the mothers freedom to choose and their own rights would be undermined if Article 2 was to provide express rights to unborn children. Therefore, whilst abortion should still be permitted, limitations should be imposed so that the rights of the foetus are given better protection. It is unclear whether judges should be left to make a decision on whether an abortion is lawful or not since opinions will differ significantly on this subject. Thus, it cannot be said that judges should be left to decide upon moral issues. Whilst one judge may agree with abortion, another judge may not as individuals have different perceptions on what is and what is not morally right. This is why the courts have been quite reluctant to use a single approach when deciding upon the interests of a foetus and it seems that the matter is better left undefined. This was identified by Sandel when it was argued that there are differences of opinions as to whether abortion is morally reprehensible and therefore worthy of prohibition, whilst many avoid passing judgment on the morality of these practices.[34] The ECHR appears to have adopted the latter approach, by failing to provide a decision on the legal status of foetus’. This lack of definition may actually be in the interests of the foetus since rights are capable of being provided that may not have been had a definition been in place. The determination as to whether abortion should be a mother’s choice or not will be capable of being assessed differently in all cases. This is necessary given the diverging opinions that exist since it will continue to be argued by many that Article 2 should provide a right to â€Å"anyone† including unborn children, whilst others will continue to be of the view that the decision should be left with the freedom of choice as protected u nder Article 13 of the Convention. The current practice that is being adopted in striking a balance between the two competing interests does appear to be the most plausible approach to take since each case will be determined by its facts. This could, however, lead to judicial activism occurring, which appears to have happened in the Roe case above which was described by Thielen as â€Å"an incredible reach of judicial activism.†[35] Judicial activism occurs when a ruling is said to be based upon political or personal considerations as opposed to being based upon existing law.[36] Therefore, if when Courts are provided with the ability to decide upon matters concerning abortion, judicial activism is likely to emerge which undermines social policy and, in some instances, human rights. Still, as put forward by Ewing and Gearty; â€Å"English judges have shown a powerful engagement with the rights of the unborn in the past,†[37] yet whether violations of one’s huma n rights are arising out of this is likely and it seems quite difficult for a balance to be achieved between the rights of the unborn with the rights of the mother. Conclusion This area is extremely controversial and because of this it is difficult for legislators as well as the judiciary to make a decision as to whether a foetus does have rights. Many people are of the view that every woman should have the right to choose whether or not to have an abortion, yet not all agree with this. Instead, it is argued that women are capable of using abortion as a form of contraception because of how easily accessible it is. Whilst there are some restraints in place to prevent this from happening, such as the requirement to obtain permission from two doctors, it cannot be said that such measures are effective. This is because it is highly unlikely that an abortion would be refused unless the stages of pregnancy have gone past the 24 week threshold. Furthermore, because women are permitted to have an abortion past this stage if the unborn child is suffering from a disability, the rights of the foetus are being undermined even further. It is therefore questionable whet her the current law is effective in preserving the interests of the foetus since the law has not made it difficult for abortions to be performed. Therefore, it could be said that further restrictions are needed so as to balance the rights of the mother with the rights of the unborn child. Conversely, because there is a limit on the number of weeks a person can abort a foetus, it could be said that their interests are being adequately protected to a certain degree. Whether this is sufficient, however, is likely to remain a contestable subject for many years to come as there will continue to be differing opinions as to whether abortion should be so easily available. In effect, there are both strengths and weaknesses for right to abortion, yet it is questionable whether the strengths do in fact outweigh the weaknesses. BIBLIOGRAPHY Cases: A-G’s Reference (No 3 of 119) [1998] AC 245 H v Norway (1992) 73 D R 155 Open Door and Dublin Well Woman v Ireland (1992) 14 EHRR 244 Paton v United Kingdom (1980) 3 EHRR 408 Planned Parenthood v Casey (1992) 404 U.S. 833 Roe v Wade (1973) 410 U.S. 113 Vo v France Judgement of 8 July 2004 40 EHRR 12 X v United Kingdom (1980) 19 D R 244 Legislation: Abortion Act 1967 Disability Discrimination Act 1995 European Convention of Human Rights 1951 Human Fertilisation and Embryology Act 1990 Human Rights Act 1998 Textbooks: Herring, J. Law Express: Medical Law (Revision Guide), Longman, 2nd Edition, (2009). Herring, J. Medical Law and Ethics, OUP Oxford, 3rd Edition, (2010). Hope, T., Savulescu, J. and Hendrick, J. Medical Ethics and Law: The Core Curriculum, Churchill Livingstone, 2nd Edition, (2008). Kaczor, C., The Ethics of Abortion: Women’s Rights, Human Life, and the Question of Justice, (Routledge: London, 2013). Kennedy, I., Grubb, A., Laing, J. and McHale, J. 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