title: Vidkun Quisling

text: Having spent nine of the previous twelve years abroad, but with no practical experience in party politics outside the Norwegian Army, Quisling returned to Norway in December 1929, bringing with him a plan for change he termed "Norsk Aktion," meaning "Norwegian Action." The planned organisation consisted of national, regional and local units with the intention of recruiting in the style of the Soviet Communist Party. Like "Action Française" of the French right, it advocated radical constitutional changes. The Parliament of Norway, or "Storting," was to become bicameral with the second chamber made up of Soviet-style elected representatives from the working population. Quisling focused more on organisation than the practicalities of government; for instance, all members of "Norsk Aktion" were to have their own designation in a militaristic hierarchy.


title: Vidkun Quisling

text: Quisling next sold a large number of antiques and works of art that he had acquired cheaply in post-revolutionary Russia. His collection stretched to some 200 paintings, including works claimed to be by Rembrandt, Goya, Cézanne and numerous other masters. The collection, including "veritable treasures," had been insured for almost 300,000 kroner. In the spring of 1930, he again joined up with Prytz, who was back in Norway. They participated in regular group meetings that included middle-aged officers and business people, since described as "the textbook definition of a Fascist initiative group," through which Prytz appeared determined to launch Quisling into politics.


title: Vidkun Quisling

text: After Nansen died on 13 May 1930, Quisling used his friendship with the editor of the "Tidens Tegn" newspaper to get his analysis of Nansen onto the front page. The article was entitled "Politiske tanker ved Fridtjof Nansens død" ("Political Thoughts on the Death of Fridtjof Nansen") and was published on 24 May. In the article, he outlined ten points that would complete Nansen's vision as applied to Norway, among them "strong and just government" and a "greater emphasis on race and heredity." This theme was followed up in his new book, "Russia and Ourselves" (), which was serialised in "Tidens Tegn" during the autumn of 1930. Advocating war against Bolshevism, the openly racist book catapulted Quisling into the political limelight. Despite his earlier ambivalence, he took up a seat on the Oslo board of the previously Nansen-led Fatherland League. Meanwhile, he and Prytz founded a new political movement, "Nordisk folkereisning i Norge," or "Nordic popular rising in Norway," with a central committee of 31 and Quisling as its "fører" – a one-man executive committee – though Quisling seemed to have had no particular attachment to the term. The first meeting of the league took place on 17 March 1931, stating the purpose of the movement was to "eliminate the imported and depraved communist insurgency."


title: Vidkun Quisling

text: Quisling left "Nordisk folkereisning i Norge" in May 1931 to serve as defence minister in the Agrarian government of Peder Kolstad, despite being neither an Agrarian nor a friend of Kolstad. He had been suggested to Kolstad for the post by Thorvald Aadahl, editor of the Agrarian newspaper "Nationen," who was in turn influenced by Prytz. The appointment came as a surprise to many in the Parliament of Norway. Quisling's first action in the post was to deal with the aftermath of the Battle of Menstad, an "extremely bitter" labour dispute, by sending in troops. After narrowly avoiding criticism by the left wing over his handling of the dispute, and the revelation of his earlier "militia" plans, Quisling turned his attention to the perceived threat posed by communists. He created a list of the Revolutionary Trade Union Opposition leadership, who had been the alleged agitators at Menstad; a number of them were eventually charged with subversion and violence against the police. Quisling's policies also resulted in the establishment of a permanent militia called the "Leidang" which, unlike the body he had previously planned, was to be counter-revolutionary. Despite the ready availability of junior officers in the reserve following defence cuts, only seven units were established in 1934, and funding restrictions meant that the enterprise included less than a thousand men before it faded away. Sometime during the period 1930–33, Quisling's first wife, Asja, received notice of the annulment of her marriage to him.


title: Vidkun Quisling

text: In mid-1932 "Nordisk folkereisning i Norge" was forced to confirm that even though Quisling remained in the cabinet, he would not become a member of the party. They further stated that the party programme had no basis in fascism of any kind, including the National Socialism model. This did not dampen criticism of Quisling, who remained constantly in the headlines, although he was gradually earning a reputation as a disciplined and efficient administrator. After he was attacked in his office by a knife-wielding assailant who threw ground pepper in his face on 2 February 1932, some newspapers, instead of focusing on the attack itself, suggested that the assailant had been the jealous husband of one of Quisling's cleaners; others, especially those aligned with the Labour Party, posited that the whole thing had been staged. In November 1932, Labour politician Johan Nygaardsvold put this theory to Parliament, prompting suggestions that charges of slander be brought against him. No charges were brought, and the identity of the assailant has never been confirmed. Quisling later indicated it was an attempt to steal military papers recently left by Swedish Lieutenant Colonel Wilhelm Kleen. The so-called "pepper affair" served to polarise opinion about Quisling, and government fears grew concerning reasonably open Soviet elements in Norway who had been active in promoting industrial unrest.


title: Vidkun Quisling

text: Following Kolstad's death in March 1932, Quisling retained his post as defence minister in the second Agrarian government under Jens Hundseid for political reasons, though they remained in bitter opposition throughout. Just as he had been under Kolstad, Quisling was involved in many of the spats that characterised Hundseid's government. On 8 April that year, Quisling had a chance to defend himself over the pepper affair in Parliament, but instead used the opportunity to attack the Labour and Communist parties, claiming that named members were criminals and "enemies of our fatherland and our people." Support for Quisling from right-wing elements in Norwegian society rocketed overnight, and 153 distinguished signatories called for Quisling's claims to be investigated. In the coming months, tens of thousands of Norwegians followed suit and Quisling's summer was full of speeches to packed political rallies. In Parliament, however, Quisling's speech was viewed as political suicide; not only was his evidence weak, but questions were raised as to why the information had not been handed over much sooner if the revolutionary threat were so serious.


title: Vidkun Quisling

text: Over the course of 1932 and into 1933, Prytz's influence over "Nordisk folkereisning i Norge" weakened and lawyer Johan Bernhard Hjort assumed the leadership role. Hjort was keen to work with Quisling because of his new-found popularity, and they devised a new programme of right-wing policies including proscription of revolutionary parties including those funded by foreign bodies such as Comintern, the suspension of the voting rights for people in receipt of social welfare, agricultural debt relief, and an audit of public finances. In 1932, during the Kullmann Affair, Quisling turned on the prime minister for questioning his hard-line stance over pacifist agitator Captain Olaf Kullmann. In a memorandum laying out his proposals for economic and social reform distributed to the entire cabinet, Quisling called for the prime minister to stand down. As the government began to collapse, Quisling's personal popularity reached new heights; he was referred to as "man of the year," and there were expectations of forthcoming electoral success.


title: Vidkun Quisling

text: Despite the new programme, some of Quisling's circle still favoured a cabinet coup. He later said he had even considered the use of force to overthrow the government but, in late February, it was the Liberal Party that brought them down. With the assistance of Hjort and Prytz, "Nordisk folkereisning i Norge" quickly became a political party, "Nasjonal Samling," or NS, literally "National Unity," ready to contest the forthcoming October election. Quisling was mildly disappointed and would have preferred to head a national movement, not just one of seven political parties. "Nasjonal Samling" soon afterwards announced it would support candidates from other parties if they supported its key aim of "establishing a strong and stable national government independent of ordinary party politics." Although not an overnight success in the already crowded political spectrum, the party slowly gained support. With its Nazi-inspired belief in the central authority of a strong "Führer", as well as its powerful propaganda elements, it gained support from many among the Oslo upper classes, and began to give the impression that "big money" lay behind it.


title: Vidkun Quisling

text: Increased support also materialised when the "Bygdefolkets Krisehjelp," the Norwegian Farmers' Aid Association, sought financial aid from "Nasjonal Samling," who in turn gained political influence and a useful existing network of well-trained party officers. Quisling's party never managed a grand anti-socialist coalition, however, in part because of competition from the Conservative Party for right-wing votes. Though Quisling remained unable to demonstrate any skill as an orator, his reputation for scandal nonetheless ensured that the electorate were aware of "Nasjonal Samling's" existence. As a result, the party showed only moderate success in the October elections, with 27,850 votes—approximately two per cent of the national vote, and about three and a half per cent of the vote in constituencies where it fielded candidates. This made it the fifth largest party in Norway, out-polling the Communists but not the Conservative, Labour, Liberal or Agrarian parties, and failing to secure a single seat in Parliament.


title: Vidkun Quisling

text: After the underwhelming election results, Quisling's attitude to negotiation and compromise hardened. A final attempt to form a coalition of the right in March 1934 came to nothing, and from late 1933, Quisling's "Nasjonal Samling" began to carve out its own form of national socialism. With no leader in Parliament, however, the party struggled to introduce the constitutional reform bill needed to achieve its lofty ambitions. When Quisling tried to introduce the bill directly, it was swiftly rejected, and the party went into decline. In the summer of 1935, headlines quoted Quisling telling opponents that "heads [would] roll" as soon as he achieved power. The threat irreparably damaged the image of his party, and over the following few months several high-ranking members resigned, including Kai Fjell and Quisling's brother Jørgen.


title: Vidkun Quisling

text: Quisling began to familiarise himself with the international fascist movement, attending the 1934 Montreux Fascist conference in December. For his party, the association with Italian fascism could not have come at a worse time, so soon after headlines of illegal Italian incursions into Abyssinia. On his return trip from Montreux, he met Nazi ideologue and foreign policy theorist Alfred Rosenberg, and though he preferred to see his own policies as a synthesis of Italian fascism and German Nazism, by the time of the 1936 elections, Quisling had in part become the "Norwegian Hitler" that his opponents had long accused him of being. Part of this was due to his hardening anti-Semitic stance, associating Judaism with Marxism, liberalism and, increasingly, anything else he found objectionable, and part as a result of "Nasjonal Samling's" growing similarity to the German Nazi Party. Despite receiving an unexpected boost when the Norwegian government acceded to Soviet demands to arrest Leon Trotsky, the party's election campaign never gained momentum. Although Quisling sincerely believed he had the support of around 100,000 voters, and declared to his party that they would win an absolute minimum of ten seats, "Nasjonal Samling" managed to poll just 26,577, fewer than in 1933 when they had fielded candidates in only half the districts. Under this pressure, the party split in two, with Hjort leading the breakaway group; although fewer than fifty members left immediately, many more drifted away during 1937.


title: Vidkun Quisling

text: Dwindling party membership created many problems for Quisling, especially financial ones. For years he had been in financial difficulties and reliant on his inheritance, while increasing numbers of his paintings were found to be copies when he tried to sell them. Vidkun and his brother Arne sold one Frans Hals painting for just four thousand dollars, believing it to be a copy and not the fifty-thousand-dollar artwork they had once thought it to be, only to see it reclassified as an original and revalued at a hundred thousand dollars. In the difficult circumstances of the Great Depression, even originals did not raise as much as Quisling had hoped. His disillusionment with Norwegian society was furthered by news of the planned constitutional reform of 1938, which would extend the parliamentary term from three to four years with immediate effect, a move Quisling bitterly opposed.


title: Vidkun Quisling

text: In 1939, Quisling turned his attention towards Norway's preparations for the anticipated European war, which he believed involved a drastic increase in the country's defence spending to guarantee its neutrality. Meanwhile, Quisling presented lectures entitled "The Jewish problem in Norway" and supported Adolf Hitler in what appeared to be growing future conflict. Despite condemning "Kristallnacht," he sent the German leader a fiftieth-birthday greeting thanking him for "saving Europe from Bolshevism and Jewish domination". Quisling also contended that should an Anglo-Russian alliance make neutrality impossible, Norway would have "to go with Germany." Invited to the country in the summer of 1939, he began a tour of a number of German and Danish cities. He was received particularly well in Germany, which promised funds to boost "Nasjonal Samling's" standing in Norway, and hence spread pro-Nazi sentiment. When war broke out on 1 September 1939, Quisling felt vindicated by both the event and the immediate superiority displayed by the German army. He remained outwardly confident that, despite its size, his party would soon become the centre of political attention.


title: Vidkun Quisling

text: For the next nine months, Quisling continued to lead a party that was at best peripheral to Norwegian politics. He was nonetheless active, and in October 1939 he worked with Prytz on an ultimately unsuccessful plan for peace between Britain, France and Germany and their eventual participation in a new economic union. Quisling also mused on how Germany ought to go on the offensive against its ally the Soviet Union, and on 9 December travelled to Germany to present his multi-faceted plans. After impressing German officials, he won an audience with Hitler himself, scheduled for 14 December, whereupon he received firm advice from his contacts that the most useful thing he could do would be to ask for Hitler's help with a pro-German coup in Norway, that would let the Germans use Norway as a naval base. Thereafter, Norway would maintain official neutrality as long as possible, and finally the country would fall under German rather than British control. It is not clear how much Quisling himself understood about the strategic implications of such a move, and he instead relied on his future Minister of Domestic Affairs, Albert Hagelin, who was fluent in German, to put the relevant arguments to German officials in Berlin during pre-meeting talks, even though Hagelin was prone to damaging exaggeration at times. Quisling and his German contacts almost certainly went away with different views as to whether they had agreed upon the necessity of a German invasion.


title: Vidkun Quisling

text: On 14 December 1939, Quisling met Hitler. The German leader promised to respond to any British invasion of Norway (Plan R 4), perhaps pre-emptively, with a German counter-invasion, but found Quisling's plans for both a Norwegian coup and an Anglo-German peace unduly optimistic. Nonetheless, Quisling would still receive funds to bolster "Nasjonal Samling." The two men met again four days later, and afterwards Quisling wrote a memorandum that explicitly told Hitler that he did not consider himself a National Socialist. As German machinations continued, Quisling was intentionally kept in the dark. He was also incapacitated by a severe bout of illness, probably nephritis in both kidneys, for which he refused hospitalisation. Though he returned to work on 13 March 1940, he remained ill for several weeks. In the meantime, the Altmark incident complicated Norway's efforts to maintain its neutrality. Hitler himself remained in two minds over whether an occupation of Norway should require an invitation from the Norwegian government. Finally, Quisling received his summons on 31 March, and reluctantly travelled to Copenhagen to meet with Nazi intelligence officers who asked him for information on Norwegian defences and defence protocols. He returned to Norway on 6 April and, on 8 April, the British Operation Wilfred commenced, bringing Norway into the war. With Allied forces in Norway, Quisling expected a characteristically swift German response.


title: Vidkun Quisling

text: In the early hours of 9 April 1940, Germany invaded Norway by air and sea, as "Operation "Weserübung"", or "Operation Weser Exercise", intending to capture King Haakon VII and the government of Prime Minister Johan Nygaardsvold. However, alert to the possibility of invasion, Conservative President of the Parliament C. J. Hambro arranged for their evacuation to Hamar in the east of the country. The "Blücher," a German cruiser which carried most of the personnel intended to take over Norway's administration, was sunk by cannon fire and torpedoes from Oscarsborg Fortress in the Oslofjord. The Germans had expected the government to surrender and to have its replacement ready; neither happened, although the invasion itself continued. After hours of discussion, Quisling and his German counterparts decided that an immediate coup was necessary, though this was not the preferred option of either Germany's ambassador Curt Bräuer or the German Foreign Ministry.


title: Vidkun Quisling

text: In the afternoon, Quisling was told by German liaison Hans-Wilhelm Scheidt that should he set up a government, it would have Hitler's personal approval. Quisling drew up a list of ministers and, although it had merely relocated some to Elverum, accused the legitimate government of having "fled".


title: Vidkun Quisling

text: Meanwhile, the Germans occupied Oslo and at 17:30 Norwegian radio ceased broadcasting at the request of the occupying forces. With German support, at approximately 19:30, Quisling entered the NRK studios in Oslo and proclaimed the formation of a new government with himself as Prime Minister. He also revoked an earlier order to mobilise against the German invasion. He still lacked legitimacy. Two orders—the first to his friend Colonel Hans Sommerfeldt Hiorth, the commanding officer of the army regiment at Elverum, to arrest the government, and the second to Kristian Welhaven, Oslo's chief of police—were both ignored. At 22:00, Quisling resumed broadcasting, repeating his earlier message and reading out a list of new ministers. Hitler lent his support as promised, and recognised the new Norwegian government under Quisling within 24 hours. Norwegian batteries were still firing on the German invasion force, and at 03:00 on 10 April, Quisling acceded to a German request to halt the resistance of the Bolærne fortress. As a result of actions such as these, it was claimed at the time that Quisling's seizure of power in a puppet government had been part of the German plan all along.


title: Vidkun Quisling

text: Quisling now reached the high-water mark of his political power. On 10 April, Bräuer travelled to Elverum where the legitimate Nygaardsvold government now sat. On Hitler's orders, he demanded that King Haakon appoint Quisling head of a new government, thereby securing a peaceful transition of power. Haakon rejected this demand. He went further in a meeting with his cabinet, letting it be known that he would sooner abdicate than appoint any government headed by Quisling. Hearing this, the government unanimously voted to support the king's stance, and urged the people to continue their resistance. With his popular support gone, Quisling ceased to be of use to Hitler. Germany retracted its support for his rival government, preferring instead to build up its own independent governing commission. In this way, Quisling was manoeuvred out of power by Bräuer and a coalition of his former allies, including Hjort, who now saw him as a liability. Even his political allies, including Prytz, deserted him.


title: Vidkun Quisling

text: In return, Hitler wrote to Quisling thanking him for his efforts and guaranteeing him some sort of position in the new government. The transfer of power on these terms was duly enacted on 15 April, with Hitler still confident the Administrative Council would receive the backing of the king. Quisling's domestic and international reputation both hit new lows, casting him as both a traitor and a failure.


title: Vidkun Quisling

text: Once the king had declared the German commission unlawful, it became clear that he would never be won over. An impatient Hitler appointed a German, Josef Terboven, as the new Norwegian "Reichskommissar," or Governor-General, on 24 April, reporting directly to him. Despite Hitler's assurances, Terboven wanted to make sure that there would be no room in the government for the "Nasjonal Samling" nor its leader Quisling, with whom he did not get along. Terboven eventually accepted a certain "Nasjonal Samling" presence in the government during June, but remained unconvinced about Quisling. As a result, on 25 June, Terboven forced Quisling to step down as leader of the "Nasjonal Samling" and take a temporary leave of absence in Germany. Quisling remained there until 20 August, while Rosenberg and Admiral Erich Raeder, whom he had met on his earlier visit to Berlin, negotiated on his behalf. In the end, Quisling returned "in triumph," having won Hitler over in a meeting on 16 August. The "Reichskommissar" would now have to accommodate Quisling as leader of the government, then allow him to rebuild the "Nasjonal Samling" and bring more of his men into the cabinet. Terboven complied and addressed the Norwegian people in a radio broadcast in which he asserted that the "Nasjonal Samling" would be the only political party allowed.


title: Vidkun Quisling

text: As a result, by the end of 1940 the monarchy had been suspended, although the Parliament of Norway and a body resembling a cabinet remained. The "Nasjonal Samling," the only pro-German party, would be cultivated, but Terboven's "Reichskommissariat" would keep power in the meantime. Quisling would serve as acting prime minister and ten of the thirteen "cabinet" ministers were to come from his party. He set out on a programme of wiping out "the destructive principles of the French Revolution," including pluralism and parliamentary rule. This reached into local politics, whereby mayors who switched their allegiance to the "Nasjonal Samling" were rewarded with much greater powers. Investments were made in heavily censored cultural programmes, though the press remained theoretically free. To bolster the survival chances of the Nordic genotype, contraception was severely restricted. Quisling's party experienced a rise in membership to a little over 30,000, but despite his optimism it was never to pass the 40,000 mark.


title: Vidkun Quisling

text: On 5 December 1940, Quisling flew to Berlin to negotiate the future of Norway's independence. By the time he returned on 13 December, he had agreed to raise volunteers to fight with the German "Schutzstaffel" (SS). In January, SS head Heinrich Himmler travelled to Norway to oversee preparations. Quisling clearly believed that if Norway supported Nazi Germany on the battlefield, there would be no reason for Germany to annex it. To this end, he opposed plans to have a German SS brigade loyal only to Hitler installed in Norway. In the process, he also toughened his attitude to the country harbouring the exiled king, the United Kingdom, which he no longer saw as a Nordic ally. Finally, Quisling aligned Norwegian policy on Jews with that of Germany, giving a speech in Frankfurt on 26 March 1941 in which he argued for compulsory exile, but warned against extermination.


title: Vidkun Quisling

text: In May, Quisling was shattered by the death of his mother Anna, as the two had been particularly close. At the same time, the political crisis over Norwegian independence deepened, with Quisling threatening Terboven with his resignation over the issue of finance. In the end, the Reichskommissar agreed to compromise on the issue, but Quisling had to concede on the SS issue: A brigade was formed, but as a branch of the "Nasjonal Samling."


title: Vidkun Quisling

text: Meanwhile, the government line hardened, with Communist Party leaders arrested and trade unionists intimidated. On 10 September 1941, Viggo Hansteen and Rolf Wickstrøm were executed and many more imprisoned following the milk strike in Oslo. Hansteen's execution was later seen as a watershed moment, dividing the occupation into its more innocent and more deadly phases. The same year "Statspolitiet" ("the State Police"), abolished in 1937, was reestablished to assist the Gestapo in Norway, and radio sets were confiscated across the country. Though these were all Terboven's decisions, Quisling agreed with them and went on to denounce the government-in-exile as "traitors." As a result of the toughened stance, an informal "ice front" emerged, with "Nasjonal Samling" supporters ostracised from society. Quisling remained convinced this was an anti-German sentiment that would fade away once Berlin had handed power over to "Nasjonal Samling." However, the only concessions he won in 1941 were having the heads of ministries promoted to official ministers of the government and independence for the party secretariat.


title: Vidkun Quisling

text: In January 1942, Terboven announced the German administration would be wound down. Soon afterwards he told Quisling that Hitler had approved the transfer of power, scheduled for 30 January. Quisling remained doubtful it would happen, since Germany and Norway were in the midst of complex peace negotiations that could not be completed until peace had been reached on the Eastern Front, while Terboven insisted that the "Reichskommissariat" would remain in power until such peace came about. Quisling could nevertheless be reasonably confident that his position within the party and with Berlin was unassailable, even if he was unpopular within Norway, something of which he was well aware.


title: Vidkun Quisling

text: After a brief postponement, an announcement was made on 1 February 1942, detailing how the cabinet had elected Quisling to the post of Minister-President of the national government. The appointment was accompanied by a banquet, rallying, and other celebrations by the "Nasjonal Samling" members. In his first speech, Quisling committed the government to closer ties with Germany. The only change to the Constitution was the reinstatement of the ban on Jewish entry into Norway, which had been abolished in 1851.


title: Vidkun Quisling

text: His new position gave Quisling a security of tenure he had not previously enjoyed, although the "Reichskommissariat" remained outside his control. A month later, in February 1942, Quisling made his first state visit to Berlin. It was a productive trip, in which all key issues of Norwegian independence were discussed—but Joseph Goebbels in particular remained unconvinced of Quisling's credentials, noting that it was "unlikely" he would "... ever make a great statesman."


title: Vidkun Quisling

text: Back at home, Quisling was now less concerned about "Nasjonal Samling's" membership and even wanted action to clean up the membership list, including purging it of drunkards. On 12 March 1942, Norway officially became a one-party state. In time, criticism of, and resistance to, the party was criminalised, though Quisling expressed regret for having to take this step, hoping that every Norwegian would freely come around to accept his government.


title: Vidkun Quisling

text: This optimism was short-lived. In the course of the summer of 1942, Quisling lost any ability he might have had to sway public opinion by attempting to force children into the "Nasjonal Samlings Ungdomsfylking" youth organisation, which was modelled on the Hitler Youth. This move prompted a mass resignation of teachers from their professional body and churchmen from their posts, along with large-scale civil unrest. His attempted indictment of Bishop Eivind Berggrav proved similarly controversial, even amongst his German allies. Quisling now toughened his stance, telling Norwegians that they would have the new regime forced upon them "whether they like it or not." On 1 May 1942, the German High Command noted that "organised resistance to Quisling has started" and Norway's peace talks with Germany stalled as a result. On 11 August 1942, Hitler postponed any further peace negotiations until the war ended. Quisling was admonished and learned that Norway would not get the independence he so greatly yearned for. As an added insult, for the first time he was forbidden to write letters directly to Hitler.


title: Vidkun Quisling

text: Quisling had earlier pushed for a corporate alternative to the Parliament of Norway, the "Storting," which he called a "Riksting." It would comprise two chambers, the "Næringsting" (Economic Chamber) and "Kulturting" (Cultural Chamber). Now, in advance of "Nasjonal Samling's" eighth and last national convention on 25 September 1942 and becoming increasingly distrustful of professional bodies, he changed his mind. The "Riksting" became an advisory body while the "Førerting," or Leader Council, and parliamentary chambers were now to be independent bodies subordinate to their respective ministries.


title: Vidkun Quisling

text: After the convention, support for "Nasjonal Samling," and Quisling personally, ebbed away. Increased factionalism and personal losses, including the accidental death of fellow politician Gulbrand Lunde, were compounded by heavy-handed German tactics, such as the shooting of ten well-known residents of Trøndelag and its environs in October 1942. In addition, the "lex Eilifsen" "ex-post facto" law of August 1943, which led to the first death sentence passed by the regime, was widely seen as a blatant violation of the Constitution and a sign of Norway's increasing role in the Final Solution, would destroy everything the convention had achieved in terms of boosting party morale.


title: Vidkun Quisling

text: With government abatement and Quisling's personal engagement, Jews were registered in a German initiative of January 1942. On 26 October 1942, German forces, with help from the Norwegian police, arrested 300 registered male Jews in Norway and sent them to concentration camps, most in Berg and manned by "Hirden," the paramilitary wing of "Nasjonal Samling." Most controversially, the Jews' property was confiscated by the state.


title: Vidkun Quisling

text: On 26 November, the detainees were deported, along with their families. Although this was an entirely German initiative—Quisling himself was left unaware of it, although government assistance was provided—Quisling led the Norwegian public to believe that the first deportation of Jews, to camps in Nazi-German occupied Poland, was his idea. A further 250 were deported in February 1943, and it remains unclear what the party's official position was on the eventual fate of the 759 Norwegian deportees. There is evidence to suggest that Quisling honestly believed the official line throughout 1943 and 1944 that they were awaiting repatriation to a new Jewish homeland in Madagascar.


title: Vidkun Quisling

text: At the same time, Quisling believed that the only way he could win back Hitler's respect would be to raise volunteers for the now-faltering German war effort, and he committed Norway wholeheartedly to German plans to wage total war. For him at least, after the German defeat at Stalingrad in February 1943, Norway now had a part to play in keeping the German empire strong. In April 1943, Quisling delivered a scathing speech attacking Germany's refusal to outline its plans for post-war Europe. When he put this to Hitler in person, the Nazi leader remained unmoved despite Norway's contributions to the war effort. Quisling felt betrayed over this postponement of Norwegian freedom, an attitude that waned only when Hitler eventually committed to a free post-war Norway in September 1943.


title: Vidkun Quisling

text: Quisling tired during the final years of the war. In 1942 he passed 231 laws, 166 in 1943, and 139 in 1944. Social policy was the one area that still received significant attention. By that autumn, Quisling and Mussert in the Netherlands could be satisfied they had at least survived. In 1944, the weight problems Quisling had been having during the preceding two years also eased.


title: Vidkun Quisling

text: Despite the increasingly dire military outlook in 1943 and 1944, "Nasjonal Samling's" position at the head of the government, albeit with its ambiguous relationship to the "Reichskommissariat," remained unassailable. Nevertheless, the Germans exerted increasing control over law and order in Norway. Following the deportation of the Jews, Germany deported Norwegian officers and finally attempted to deport students from the University of Oslo. Even Hitler was incensed by the scale of the arrests. Quisling became entangled in a similar debacle in early 1944 when he forced compulsory military service on elements of the "Hirden," causing a number of members to resign to avoid being drafted.


title: Vidkun Quisling

text: On 20 January 1945, Quisling made what would be his final trip to visit Hitler. He promised Norwegian support in the final phase of the war if Germany agreed to a peace deal that would remove Norway's affairs from German intervention. This proposal grew out of a fear that as German forces retreated southwards through Norway, the occupation government would have to struggle to keep control in northern Norway. To the horror of the Quisling regime, the Nazis instead decided on a scorched earth policy in northern Norway, going so far as to shoot Norwegian civilians who refused to evacuate the region. The period was also marked by increasing civilian casualties from Allied air raids, and mounting resistance to the government within occupied Norway. The meeting with the German leader proved unsuccessful and upon being asked to sign the execution order of thousands of Norwegian "saboteurs," Quisling refused, an act of defiance that so enraged Terboven, acting on Hitler's orders, that he stormed out of the negotiations. On recounting the events of the trip to a friend, Quisling broke down in tears, convinced the Nazi refusal to sign a peace agreement would seal his reputation as a traitor.


title: Vidkun Quisling

text: Quisling spent the last months of the war trying to prevent Norwegian deaths in the showdown that was developing between German and Allied forces in Norway. The regime worked for the safe repatriation of Norwegians held in German prisoner-of-war camps. Privately, Quisling had long accepted that National Socialism would be defeated. Hitler's suicide on 30 April 1945 left him free to pursue publicly his chosen end-game, a naïve offer of a transition to a power-sharing government with the government-in-exile.


title: Vidkun Quisling

text: On 7 May, Quisling ordered police not to offer armed resistance to the Allied advance except in self-defence or against overt members of the Norwegian resistance movement. The same day, Germany announced it would surrender unconditionally, making Quisling's position untenable. A realist, Quisling met military leaders of the resistance on the following day to discuss how he would be arrested. Quisling declared whilst he did not want to be treated as a common criminal, he did not want preferential treatment compared to his "Nasjonal Samling" colleagues. He argued he could have kept his forces fighting until the end, but had chosen not to so as to avoid turning "Norway into a battlefield." Instead, he tried to ensure a peaceful transition. In return, the resistance offered full trials for all accused "Nasjonal Samling" members after the war, and its leadership agreed he could be incarcerated in a house rather than a prison complex.


title: Vidkun Quisling

text: The civil leadership of the resistance, represented by lawyer Sven Arntzen, demanded Quisling be treated like any other murder suspect and, on 9 May 1945, Quisling and his ministers turned themselves in to police. Quisling was transferred to Cell 12 in Møllergata 19, the main police station in Oslo. The cell was equipped with a tiny table, a basin, and a hole in the wall for a toilet bucket.


title: Vidkun Quisling

text: After ten weeks being constantly watched to prevent suicide attempts in police custody, he was transferred to Akershus Fortress and awaited trial as part of the legal purge. He soon started working on his case with Henrik Bergh, a lawyer with a good track record but largely unsympathetic, at least initially, to Quisling's plight. Bergh did, however, believe Quisling's testimony that he tried to act in the best interests of Norway and decided to use this as a starting point for the defence.


title: Vidkun Quisling

text: Initially, Quisling's charges related to the coup, including his revocation of the mobilisation order, to his time as "Nasjonal Samling" leader and to his actions as Minister President, such as assisting the enemy and illegally attempting to alter the constitution. Finally, he was accused of Gunnar Eilifsen's murder. Whilst not contesting the key facts, he denied all charges on the grounds that he had always worked for a free and prosperous Norway, and submitted a sixty-page response. On 11 July 1945, a further indictment was brought, adding a raft of new charges, including more murders, theft, embezzlement and, most worrying of all for Quisling, the charge of conspiring with Hitler over the invasion and occupation of Norway.


title: Vidkun Quisling

text: The trial opened on 20 August 1945. Quisling's defence rested on downplaying his unity with Germany and stressing that he had fought for total independence, something that seemed completely contrary to the recollections of many Norwegians. From that point on, wrote biographer Dahl, Quisling had to tread a "fine line between truth and falsehood," and emerged from it "an elusive and often pitiful figure." He misrepresented the truth on several occasions and the truthful majority of his statements won him few advocates in the country at large, where he remained almost universally despised.


title: Vidkun Quisling

text: In the later days of the trial, Quisling's health suffered, largely as a result of the number of medical tests to which he was subjected, and his defence faltered. The prosecution's final speech placed responsibility for the Final Solution being carried out in Norway at the feet of Quisling, using the testimony of German officials. The prosecutor Annæus Schjødt called for the death penalty, using laws introduced by the government-in-exile in October 1941 and January 1942.


title: Vidkun Quisling

text: Speeches by both Bergh and Quisling himself could not change the outcome. When the verdict was announced on 10 September 1945, Quisling was convicted on all but a handful of minor charges and sentenced to death.


title: Vidkun Quisling

text: An October appeal to the Supreme Court was rejected. The court process was judged to be "a model of fairness" in a commentary by author Maynard Cohen. After giving testimony in a number of other trials of "Nasjonal Samling" members, Quisling was executed by firing squad at Akershus Fortress at 02:40 on 24 October 1945. His last words before being shot were, "I'm convicted unfairly and I die innocent." After his death his body was cremated, leaving the ashes to be interred in Fyresdal.


title: Vidkun Quisling

text: His wife Maria lived in Oslo until her death in 1980. They had no children. Upon her death, she donated all their Russian antiques to a charitable fund that still operated in Oslo as of August 2017. For most of his later political career, Quisling lived in a mansion on Bygdøy in Oslo that he called "Gimle," after the place in Norse mythology where survivors of the great battle of Ragnarök were to live. The house, later renamed Villa Grande, in time became a Holocaust museum. The "Nasjonal Samling" movement was wiped out as a political force in Norway and Quisling has become one of the most written-about Norwegians of all time. The word "quisling" became a synonym for "traitor." The term was coined by the British newspaper "The Times" in its lead of 15 April 1940, titled "Quislings everywhere." The noun survived, and for a while during and after World War II, the back-formed verb "to quisle" was used. One who was "quisling" was in the act of committing treason.


title: Vidkun Quisling

text: To his supporters, Quisling was regarded as a conscientious administrator of the highest order, knowledgeable and with an eye for detail. He was believed to care deeply about his people and maintained high moral standards throughout. To his opponents, Quisling was unstable and undisciplined, abrupt, even threatening. Quite possibly he was both, at ease among friends and under pressure when confronted with his political opponents, and generally shy and retiring with both. During formal dinners he often said nothing at all except for the occasional cascade of dramatic rhetoric. Indeed, he did not react well to pressure and would often let slip over-dramatic sentiments when put on the spot. Normally open to criticism, he was prone to assuming larger groups were conspiratorial.


title: Vidkun Quisling

text: Post-war interpretations of Quisling's character are similarly mixed. After the war, collaborationist behaviour was popularly viewed as a result of mental deficiency, leaving the personality of the clearly more intelligent Quisling an "enigma." He was instead seen as weak, paranoid, intellectually sterile and power-hungry: ultimately "muddled rather than thoroughly corrupted."


title: Vidkun Quisling

text: As quoted by Dahl, psychiatrist Professor Gabriel Langfeldt stated Quisling's ultimate philosophical goals "fitted the classic description of the paranoid megalomaniac more exactly than any other case [he had] ever encountered."


title: Vidkun Quisling

text: During his time in office, Quisling arose early, often having completed several hours of work before arriving at the office between 9:30 and 10:00. He liked to intervene in virtually all government matters, reading all letters addressed to him or his chancellery personally and marking a surprising number for action. Quisling was independent minded, made several key decisions on the spot and, unlike his German counterpart, he liked to follow procedure to ensure that government remained "a dignified and civilised" affair throughout. He took a personal interest in the administration of Fyresdal, where he was born.


title: Vidkun Quisling

text: He rejected German racial supremacy and instead saw the Norwegian race as the progenitor of Northern Europe, tracing his own family tree in his spare time. Party members did not receive preferential treatment, though Quisling did not himself share in the wartime hardships of his fellow Norwegians. Nevertheless, many gifts went unused and he did not live extravagantly.


title: Vidkun Quisling

text: Quisling was interested in science, eastern religions and metaphysics, eventually building up a library that included the works of Spinoza, Kant, Hegel and Schopenhauer. He kept up with developments in the realm of quantum physics, but did not keep up with more current philosophical ideas. He blended philosophy and science into what he called Universism, or Universalism, which was a unified explanation of everything. His original writings stretched to a claimed two thousand pages. He rejected the basic teachings of orthodox Christianity and established a new theory of life, which he called "Universism", a term borrowed from a textbook which Jan Jakob Maria de Groot had written on Chinese philosophy. De Groot's book argued that Taoism, Confucianism and Buddhism were all part of a world religion that De Groot called Universism. Quisling described how his philosophy "... followed from the universal theory of relativity, of which the specific and general theories of relativity are special instances."


title: Vidkun Quisling

text: His "magnum opus" was divided into four parts: an introduction, a description of mankind's apparent progression from individual to increasing complex consciousnesses, a section on his tenets of morality and law, and a final section on science, art, politics, history, race and religion. The conclusion was to be titled "The World's Organic Classification and Organisation", but the work remained unfinished. Generally, Quisling worked on it infrequently during his time in politics. The biographer Hans Fredrik Dahl describes this as "fortunate" since Quisling would "never have won recognition" as a philosopher.


title: Vidkun Quisling

text: During his trial and particularly after being sentenced, Quisling became interested once more in Universism. He saw the events of the war as part of the move towards the establishment of God's kingdom on earth and justified his actions in those terms. During the first week of October, he wrote a fifty-page document titled "Universistic Aphorisms", which represented "... an almost ecstatic revelation of truth and the light to come, which bore the mark of nothing less than a prophet." The document was also notable for its attack on the materialism of Nazism. In addition, he simultaneously worked on a sermon, "Eternal Justice", which reiterated his key beliefs, including reincarnation.


title: Sandalwood

text: Sandalwood is a class of woods from trees in the genus "Santalum". The woods are heavy, yellow, and fine-grained, and, unlike many other aromatic woods, they retain their fragrance for decades. Sandalwood oil is extracted from the woods for use. Sandalwood is often cited as one of the most expensive woods in the world. Both the wood and the oil produce a distinctive fragrance that has been highly valued for centuries. Consequently, some species of these slow-growing trees have suffered over-harvesting in the past.


title: Sandalwood

text: The nomenclature and the taxonomy of the genus are derived from this species' historical and widespread use. Etymologically it is ultimately derived from Sanskrit चन्दनं "Chandana" ("čandana"), meaning "wood for burning incense" and related to "candrah", "shining, glowing" and the Latin "candere", to shine or glow. It arrived in English via Late Greek, Medieval Latin and Old French in the 14th or 15th century. The sandalwood is indigenous to the tropical belt of the peninsular India, Malay Archipelago and northern Australia The main distribution is in the drier tropical regions of India and the Indonesian islands of Timor and Sumba.


title: Sandalwood

text: Sandalwoods are medium-sized hemiparasitic trees, and part of the same botanical family as European mistletoe. Sandalwood is indigenous to the tropical belt of the peninsular India, Malay Archipelago and northern Australia. The main distribution is in the drier tropical regions of India and the Indonesian islands of Timor and Sumba. It spread to other regions through Incense trade route by the vast Indian and Arab mercantile networks and the Chinese maritime trade routes until the sixteenth century CE. The sandalwood of peninsular India and Malay Archipelago as the primary trading center of that time, supported most consumption of sandalwood in East Asia and West Asia during Incense trade route. before the commercialization of sandalwood plantation ("Santalum spicatum") in Australia and China. Although the sandalwood album ("Santalum album") is still considered have the best and original quality in terms of religion and alternative medicine. Australian sandalwood ("Santalum spicatum") is marketed as the notable members of this group today by merchants because of its stable sources; others in the genus also have fragrant wood. These are found in India, Nepal, Bangladesh, Pakistan, Sri Lanka, Australia, Indonesia, Hawaii, and other Pacific Islands,


title: Sandalwood

text: Various unrelated plants with scented wood and also referred to as sandalwood, but not in the true sandalwood genus:


title: Sandalwood

text: Producing commercially valuable sandalwood with high levels of fragrance oils requires Indian sandalwood ("S. album") trees to be a minimum of 15 years old – the yield, quality and volume are still to be clearly understood. Yield of oil tends to vary depending on the age and location of the tree; usually, the older trees yield the highest oil content and quality. Australia is the largest producer of "S. album", with the majority grown around Kununurra, in the far north of the state by Quintis (formerly Tropical Forestry Services), which in 2017 controlled around 80 per cent of the world's supply of Indian sandalwood, and Santanol. India used to be the world's biggest producer, but it has been overtaken by Australia in the 21st century. Over-exploitation is partly to blame for the decline.


title: Sandalwood

text: Australian sandalwood ("S. spicatum") is grown in commercial plantations throughout the wheatbelt of Western Australia, where it has been an important part of the economy since colonial times. WA has the largest plantation resource in the world.


title: Sandalwood

text: Sandalwood is expensive compared to other types of woods, so to maximize profit, sandalwood is harvested by removing the entire tree instead of sawing it down at the trunk close to ground level. This way wood from the stump and root, which possesses high levels of sandalwood oil, can also be processed and sold.


title: Sandalwood

text: Australian sandalwood is mostly harvested and sold in log form, graded for heartwood content. The species is unique in that the white sapwood does not require removal before distilling the oil. The logs are either processed to distill the essential oil, or made into powders for making incense. Indian sandalwood, used mainly for oil extraction, does require removal of the sapwood prior to distillation. , Australian Sandalwood oil sells for around per , while Indian Sandalwood oil, due to its higher alpha santalol content, is priced at about per kg.


title: Sandalwood

text: Sandalwood is often cited as one of the most expensive woods in the world, along with African blackwood, pink ivory, agarwood and ebony.


title: Sandalwood

text: Sandalwood oil has a distinctive soft, warm, smooth, creamy, and milky precious-wood scent. Its quality and scent profile is greatly influenced by the age of the tree, location and the skill of the distiller. It imparts a long-lasting, woody base to perfumes from the oriental, woody, "fougère", and "chypre" families, as well as a fixative to floral and citrus fragrances. When used in smaller proportions in a perfume, it acts as a fixative, enhancing the longevity of other, more volatile, materials in the composite. Sandalwood is also a key ingredient in the "floriental" (floral-ambery) fragrance family – when combined with white florals such as jasmine, ylang ylang, gardenia, plumeria, orange blossom, tuberose, etc.


title: Sandalwood

text: Sandalwood oil in India is widely used in the cosmetic industry. The main source of true sandalwood, "S. album", is a protected species, and demand for it cannot be met. Many species of plants are traded as "sandalwood". The genus "Santalum" has more than 19 species. Traders often accept oil from closely related species, as well as from unrelated plants such as West Indian sandalwood ("Amyris balsamifera") in the family Rutaceae or bastard sandalwood ("Myoporum sandwicense", Myoporaceae). However, most woods from these alternative sources lose their aroma within a few months or years.


title: Sandalwood

text: Isobornyl cyclohexanol is a synthetic fragrance chemical produced as an alternative to the natural product.


title: Sandalwood

text: Sandalwood's main components are the two isomers of santalol (about 75%). It is used in aromatherapy and to prepare soaps.


title: Sandalwood

text: Sandalwood lends itself well to carving and has thus, traditionally, been a wood of choice for idols and sculptures of Hindu Gods.


title: Sandalwood

text: Due to its low fluorescence and optimal refractive index, sandalwood oil is often employed as an immersion oil within ultraviolet and fluorescence microscopy.


title: Sandalwood

text: Aboriginal Australians eat the seed kernels, nuts, and fruit of local sandalwoods, such as the quandong ("S. acuminatum").


title: Sandalwood

text: Early Europeans in Australia used quandong in cooking damper by infusing it with its leaves, and in making jams, pies, and chutneys from the fruit. In Scandinavia, pulverised bark from red sandalwood ("Pterocarpus soyauxii") is used - with other tropical spices - when marinating anchovies and some types of pickled herring such as "matjes", sprat, and certain types of traditional "spegesild", inducing a reddish colour and slightly perfumed flavour.


title: Sandalwood

text: Present-day chefs have begun experimenting in using the nut as a substitute for macadamia nuts or a bush food substitute for almonds, hazelnuts, and others in Southeast Asian-styled cuisine. The oil is also used as a flavour component in different food items, including candy, ice cream, baked food, puddings, alcoholic and nonalcoholic beverages, and gelatin. The flavouring is used at levels below 10 ppm, the highest possible level for use in food products being 90 ppm.


title: Sandalwood

text: Oil is extracted from Sandalwood through distillation. Many different methods are used, including steam distillation, water distillation, CO extraction, and solvent extractions. Steam distillation is the most common method used by sandalwood companies. It occurs in a four-step process, incorporating boiling, steaming, condensation, and separation. Water is heated to high temperatures () and is then passed through the wood. The oil is very tightly bound within the cellular structure of the wood, but can be released by the high heat of the steam. The mixture of steam and oil is then cooled and separated so that the essential oil can be collected. This process is much longer than any other essential oil's distillation, taking 14 to 36 hours to complete, but generally produces much higher quality oil. Water, or hydro, distillation is the more traditional method of sandalwood extraction which involves soaking the wood in water and then boiling it until the oil is released. This method is not used as much anymore because of the high costs and time associated with heating large quantities of water.


title: Sandalwood

text: Sandalwood is very sacred in the Hindu Ayurveda and is known in Sanskrit as "chandana." The wood is used for worshipping the deities, and it is said that goddess Lakshmi lives in the sandalwood tree; therefore, it is also known as "Srigandha". The wood of the tree is made into a paste by grinding sandalwood against stone slab, and this paste is integral to rituals and ceremonies, to make religious utensils, to decorate the icons of the deities, and to calm the mind during meditation and prayer. It is also distributed to devotees, who apply it to their foreheads or necks and chests. Sandalwood paste is used for most pujas both in temples and home altars performed in private households.


title: Sandalwood

text: The paste is prepared by grinding wood by hand against granite slabs shaped for this purpose. With the gradual addition of water, a thick paste forms (called "kalabham" "കളഭം" in Malayalam language and "gandha" ಗಂಧ in Kannada) and is mixed with saffron or other such pigments to make "chandanam". "Chandanam", further mixed with herbs, perfumes, pigments, and some other compounds, results in "javadhu". "Kalabham, chandanam," and "javadhu" are dried and used as "kalabham" powder, "chandanam" powder, and "javadhu" powder, respectively. "Chandanam" powder is very popular in India and is also used in Nepal. In Tirupati after religious tonsure, sandalwood paste is applied to protect the skin. In Hinduism and Ayurveda, sandalwood is thought to bring one closer to the divine. Thus, it is one of the most used holy elements in Hindu and Vedic societies.


title: Sandalwood

text: Sandalwood use is an integral part of daily practices of Jainism. Sandalwood paste mixed with saffron is used to worship "tirthankar" Jain deities. Sandalwood powder is showered as blessings by Jain monks and nuns ("sadhus" and "sadhvis") to their disciples and followers. Sandalwood garlands are used to dress the body during Jain cremation ceremonies. During the festival of Mahamastakabhisheka that is held once in every 12 years, the statue of Gommateshwara is then bathed and anointed with libations such as milk, sugarcane juice, and saffron paste, and sprinkled with powders of sandalwood, turmeric, and vermilion.


title: Sandalwood

text: Sandalwood is mentioned in various "suttas" of the Pāli Canon. In some Buddhist traditions, sandalwood is considered to be of the "padma" (lotus) group and attributed to Amitabha Buddha. Sandalwood scent is believed by some to transform one's desires and maintain a person's alertness while in meditation. It is also one of the most popular scents used when offering incense to the Buddha and the guru.


title: Sandalwood

text: In "sufi" tradition, sandalwood paste is applied on the "sufi"’s grave by the disciples as a mark of devotion. The tradition is borrowed from indian rituals and is practiced particularly among the Indian Subcontinent disciples. In the Tamil culture irrespective of religious identity, sandalwood paste or powder is applied to the graves of sufis as a mark of devotion and respect.


title: Sandalwood

text: In East Asia, sandalwood (檀木), is the most commonly used incense material by the Chinese, Korean and Japanese in worship and various ceremonies. However, some sects of Taoists, following the Ming Dynasty Taoist Manual, do not use lakawood but sandalwood (as well as benzoin resin, frankincense, foreign produced) incense, in worship. In Korean Shamanism, sandalwood is considered the Tree of Life. It was trasmitted to China, the Korean Peninsula, and Japan during the eastward expansion of Buddhism.


title: Sandalwood

text: Zoroastrians offer sandalwood twigs to the "afarganyu," the urn in which the fire is kept at the fire temple (called "agiyari" in Gujarati and "dar-e mehr" in Persian), to keep the fire burning during religious ceremonies. After the firekeeping priests complete the ceremony, attendees are allowed to come up to the "afarganyu" and place their own pieces of sandalwood into the fire. Fire has been a sacred symbol in the Zoroastrian religion since ancient times and it is considered very important to keep the fires in the temples constantly burning. Because of its high sensitivity to fire, sandalwood works very well for this. Also, the wood has been accepted by the Yasna and Yashts as an appropriate fuel for the fire. It is offered to all of the three grades of fire in the fire temple, including the Atash Dadgahs. Sandalwood is not offered to the "divo", a smaller lamp that is kept in the homes of Zoroastrians. Often, money is offered to the "mobad" (for religious expenditures) along with the sandalwood. Sandalwood is called "sukhad" in the Zoroastrian community. The sandalwood in the fire temple is often more expensive to buy than at a Zoroastrian store. It is often a source of income for the fire temple.


title: Jang Ki-yong

text: Jang Ki-yong (; born August 7, 1992) is a South Korean actor and model. Initially beginning a career in the modelling industry, Jang debuted as an actor through a guest appearance on "It's Okay, That's Love" (2014), followed by roles in various television series. He was cast in "Come and Hug Me" (2018), his first-ever lead role and rose to prominence through "" (2019). Jang is also known for his roles in "Confession Couple" (2017), "My Mister" (2018), "Born Again" (2020), "My Roommate Is a Gumiho" (2021), and "Now, We Are Breaking Up" (2021-22).


title: Jang Ki-yong

text: As an established model, Jang earned several awards including the "Fashion Model Award" at the 2014 Asia Model Awards and "Best Dressed Model" at the 2015 Korea's Best Dresser Swan Awards. His transition to acting earned him the accolades "Best New Actor (TV)" at the 2019 Baeksang Arts Awards, the "Excellence Award" at the 2018 MBC Drama Awards and more. Jang is also known for endorsements with brands such as Estée Lauder, Lancôme, and Nivea Men.


title: Jang Ki-yong

text: Jang Ki-yong was born on August 7, 1992, in Ulsan, South Korea. Alongside his parents and older brother, Jang resided in Ulsan. Growing up, Jang had developed an interest for fashion and photography. During his third year at , Jang deliberated on possible future career prospects for college and skills he acquired over the years. He saw a runway video from a fashion show starring Lee Soo-hyuk on the internet which piqued his interest. His enjoyment for magazines and pictorials grew, and eventually wanted to become a model. Despite his ambitions for fashion and modelling, due to familial expectations, he prepared for the college entrance exam during the second semester of high school. After revealing his dream career to his parents, they were initially reluctant and disapproved of his career choice. Eventually he convinced them to let him follow his dream, to which his father stated: "If you really like it and can do well, do it".


title: Jang Ki-yong

text: To pursue his dream, Jang went to Seoul. Describing himself as a "country guy", he often fantasied about the metropolitan city and viewing the King Sejeong bronze statue in Gwanghwamun right before his own eyes. Subsequently, after passing the college entrance exam, Jang enrolled in the musical acting department at Yong In University in Seoul. Still determined to pursue his dream, 19-year-old Jang visited South Korean modelling agency, KPlus (now YGKPlus) in the hopes of joining their company. However, he was not immediately selected. He returned a year later and was given an opportunity to take a pictorial. Following approval from the company's staff, Jang was signed as their newest recruit.


title: Jang Ki-yong

text: At 20 years of age, Jang began his modelling career through the 2012 S/S General Idea Collection Show during Seoul Fashion Week. According to Jang, modelling slowly reversed his timid and introverted personality from childhood. Despite recalling his first year slow-paced, his credits in fashion shows at the time included Kolon and Caruso, and runway show credits included Loriet and Unbounded Avenue . He was also selected as one of twelve promising rookie models by the "Korea Model Association". In 2013, his presence in the music videos "The Red Shoes" and "Friday" by IU brought him public popularity. He went on to win the Fashion Model Award at the 2014 Asian Model Award ceremony in January 2014.


title: Jang Ki-yong

text: Jang was met with an opportunity without the requirement of an audition by the director of "It's Okay, That's Love" (2014) to appear with label-mate Lee Sung-kyung. His role created a buzz within South Korea despite having no lines and was dubbed the "One Second Cameo". Later that year, taking acting more seriously, Jang auditioned for "The Greatest Marriage" (2014). While many other actors auditioned for the role, Jang was selected as he matched the role and its image more in comparison to the others. He was also cast in the drama "Schoolgirl Detectives" (2014).


title: Jang Ki-yong

text: Jang's acting portfolio extended with his supporting roles in television series' "This is My Love" (2015), "Beautiful Mind" (2016) and "The Liar and His Lover" (2017) alongside web-dramas "We Broke Up" (2015) and "Love for a Thousand More" (2016), both co-productions of YG Entertainment and starred Kang Seung-yoon. In 2016, he challenged himself with hip hop after being featured as a contestant in the second installation of "Tribe of Hip Hop". His performance to "Doom Dada" by T.O.P of Big Bang garnered attention due to its fast-paced tempo and flow while its execution was praised despite his occupation as a model. Jang finished as a finalist among the top 10.


title: Jang Ki-yong

text: In 2017, he gained popularity with his supporting character in "Confession Couple" (2017) as Jang Na-ra's college senior. Jang cited the drama as a turning point in his acting career as he soon received many offers to appear in commercials and television shows. He felt its effects more when people in their 40s and 50s approached and recognized him. With Yang Se-jong and Woo Do-hwan, Jang was dubbed "Most Popular Actors Born in 1992" and "Rising Super Rookies" by media outlets in South Korea. After its airing, he received numerous casting offers for various dramas including "My Mister" (2018). Jang chose to cast in "My Mister" for its director and writers as well as the character. After it aired, Jang gained further recognition with his role as a cold-hearted loan shark. His performance earned him the Best New Actor award at the 6th APAN Star Awards and nominations at The Seoul Awards, marking his first as an actor.


title: Jang Ki-yong

text: In 2018, Jang was cast alongside Jin Ki Joo in his first leading role in the melodrama "Come and Hug Me", taking on the role of a detective who has a fated relationship with his childhood friend. His performance in the drama earned him the Best New Actor award in television at the Baeksang Arts Awards.


title: Jang Ki-yong

text: In 2019, Jang was cast in OCN's action drama "Kill It", playing a veterinarian by day and heartless killer at night. The same year, he was cast in the romance drama "" as a CEO and genius composer. Jang made his big screen debut in the crime action film "Bad Guys", based on the OCN drama of the same name, which premiered in September 2019.


title: Jang Ki-yong

text: In 2020, Jang was cast in the mystery romance drama "Born Again" alongside Lee Soo-hyuk and Jin Se-yeon.


title: Jang Ki-yong

text: In 2021, Jang starred in the Netflix original romantic comedy film "Sweet & Sour" alongside Chae Soo-bin and Krystal Jung. Jang later joined the tvN drama "My Roommate Is a Gumiho", which is the first iQiyi original production drama alongside Lee Hye-ri, Kang Han-na, Kim Do-wan and Bae In-hyuk. Jang's last project before his mandatory enlistment was the SBS television series "Now, We Are Breaking Up" with Song Hye-kyo, Choi Hee-seo and Kim Joo-hun, all of which was pre-filmed before his departure in August ahead of its airing in November.


title: Jang Ki-yong

text: In 2022, Jang participated in the Korean republic's musical "Blue Helmet: Meissa's Song", which was Jang's first musical performance, during military service.


title: Jang Ki-yong

text: On July 26, 2021, it was reported that Jang was scheduled to enlist in the mandatory military service on August 23, 2021.


title: Jang Ki-yong

text: Throughout several occasions, Jang has viewed veteran model turned actor and label-mate Cha Seung-won as a role model in both the fields of modelling and acting since debut. Having transitioned from modelling to acting himself, Jang stated: "I want to be faithful to my main job, movies and dramas, and be able to stand on the runway like Cha Seung-won during the fashion show seasons." He also wishes to break the prejudice of "models can't act", just as Cha has done. Jang also briefly cited South Korean veteran actor, Ha Jung-woo as a role model following his appearance on SBS' Healing Camp. Seeing Ha recall his experience prompted Jang to wish to become an actor like him in 10 or 15 years time. Among actors overseas, Jang revealed the late Australian actor, Heath Ledger, as an influence for his diverse range in roles for acting.


title: Jang Ki-yong

text: As a model, his influence extended to model turned actor, Nam Joo-hyuk, to pursue a modelling career. His boost in confidence to wear braces also came through the encouragement of Jang, having also worn braces himself.


title: Jang Ki-yong

text: In September 2012, "Cass Light Beer" from South Korean brewery, Oriental Brewery (OB) chose Jang alongside labelmate and winner of the third installment of Korea's Next Top Model, model Sora Choi, as their endorsement models and muse. Since then, he became advertising models for brands including Guess Korea, TBJ, Jill By Jillstuart, Philips, and .


title: Jang Ki-yong

text: In March 2019, Natuur, an ice cream franchise under Lotteria chose Jang as a model for their products, a first after 7 years following their rebranding. A representative revealed Jang is highly popular among women in their 20s and 30s, which is also their largest customer demographic, thus believing he would be the perfect pick. Various events and fansignings were also taken place. An announcement in May through Sprite Korea confirmed Jang as their newest face and model for both their brand and their Summer 2019 "Dive in Sprite" Campaign along with singer Chungha. Perfect World Entertainment 3D adventure and fantasy MMORPG "Perfect World" announced on October 1, Jang was selected as a promotional model alongside veteran singer Kim Jong-kook and label-mate Rosé. He depicts the appearance of the Elyos Prince, an archer through a promotional video.


title: Jang Ki-yong

text: On August 31, 2020 Estée Lauder cosmetics skin care brand "Lab Series" Korea named Jang as its new face for the brand. A representative revealed through the selection process, they believed his image who constantly challenges himself with diverse roles while also pursuing an active lifestyle fits well with the innovative concept they wish to portray.


title: Contract

text: A contract is a legally enforceable agreement between two or more parties that creates, defines, and governs mutual rights and obligations between them. A contract typically involves the transfer of goods, services, money, or a promise to transfer any of those at a future date. In the event of a breach of contract, the injured party may seek judicial remedies such as damages or rescission. Contract law, the field of the law of obligations concerned with contracts, is based on the principle that agreements must be honoured.


title: Contract

text: Contract law, like other areas of private law, varies between jurisdictions. The various systems of contract law can broadly be split between common law jurisdictions, civil law jurisdictions, and mixed law jurisdictions which combine elements of both common and civil law. Common law jurisdictions typically require contracts to include consideration in order to be valid, whereas civil and most mixed law jurisdictions solely require a meeting of the minds between the parties.


title: Contract

text: Within the overarching category of civil law jurisdictions, there are several distinct varieties of contract law with their own distinct criteria: the German tradition is characterised by the unique doctrine of abstraction, systems based on the Napoleonic Code are characterised by their systematic distinction between different types of contracts, and Roman-Dutch law is largely based on the writings of renaissance-era Dutch jurists and case law applying general principles of Roman law prior to the Netherlands' adoption of the Napoleonic Code. The UNIDROIT Principles of International Commercial Contracts, published in 2016, aim to provide a general harmonised framework for international contracts, independent of the divergences between national laws, as well as a statement of common contractual principles for arbitrators and judges to apply where national laws are lacking. Notably, the Principles reject the doctrine of consideration, arguing that elimination of the doctrine "bring[s] about greater certainty and reduce litigation" in international trade. The Principles also rejected the abstraction principle on the grounds that it and similar doctrines are "not easily compatible with modern business perceptions and practice".


title: Contract

text: Contract law can be contrasted with tort law (also referred to in some jurisdictions as the law of delicts), the other major area of the law of obligations. While tort law generally deals with private duties and obligations that exist by operation of law, and provide remedies for civil wrongs committed between individuals not in a pre-existing legal relationship, contract law provides for the creation and enforcement of duties and obligations through a prior agreement between parties. The emergence of quasi-contracts, quasi-torts, and quasi-delicts renders the boundary between tort and contract law somewhat uncertain.


title: Contract

text: Contracts are widely used in commercial law, and for the most part form the legal foundation for transactions across the world. Common examples include contracts for the sale of services and goods, construction contracts, contracts of carriage, software licenses, employment contracts, insurance policies, sales or leases of land, among others. A contractual term is a "provision forming part of a contract". Each term gives rise to a contractual obligation, breach of which can give rise to litigation. Not all terms are stated expressly, and terms carry different legal weight depending on how central they are to the objectives of the contract.


title: Contract

text: Obligations created by contracts can generally be transferred, subject to requirements imposed by law. Laws regarding the modification of contracts or the assignment of rights under a contract are broadly similar across jurisdictions. In most jurisdictions, a contract may be modified by a subsequent contract or agreement between the parties to modify the terms governing their obligations to each other. This is reflected in Article 3.1.2 of the Principles of International Commercial Contracts, which states that "a contract is concluded, modified or terminated by the mere agreement of the parties, without any further requirement". Assignments are typically subject to statutory restrictions, particularly with regard to the consent of the other party to the contract.


title: Contract

text: Contract theory is a large body of legal theory that addresses normative and conceptual questions in contract law. One of the most important questions asked in contract theory is why contracts are enforced. One prominent answer to this question focuses on the economic benefits of enforcing bargains. Another approach, associated with Charles Fried in his book "Contract as Promise", maintains that the general purpose of contract law is to enforce promises"." Other approaches to contract theory are found in the writings of legal realists and critical legal studies theorists, which have propounded Marxist and feminist interpretations of contract. Attempts at understanding the overaching purpose and nature of contract as a phenomenon have been made, notably relational contract theory. Additionally, certain academic conceptions of contracts focus on questions of transaction cost and 'efficient breach' theory.


title: Contract

text: Another important dimension of the theoretical debate in contract is its place within, and relationship to a wider law of obligations. Obligations have traditionally been divided into contracts, which are voluntarily undertaken and owed to a specific person or persons, and obligations in tort which are based on the wrongful infliction of harm to certain protected interests, primarily imposed by the law, and typically owed to a wider class of persons. Research in business and management has also paid attention to the influence of contracts on relationship development and performance.


title: Contract

text: Private international law is rooted in the principle that every jurisdiction has its own distinct contract law shaped by differences in public policy, judicial tradition, and the practices of local businesses. Consequently, while all systems of contract law serve the same overarching purpose of enabling the creation of legally enforceable obligations, they may contain significant differences. Accordingly, many contracts contain a choice of law clause and a forum selection clause to determine the jurisdiction whose system of contract law will govern the contract and the court or other forum in which disputes will be resolved, respectively. Failing express agreement on such matters in the contract itself, countries have rules to determine the law governing the contract and the jurisdiction for disputes. For example, European Union Member States apply Article 4 of the Rome I Regulation to decide the law governing the contract, and the Brussels I Regulation to decide jurisdiction.


title: Contract

text: Contracts have existed since antiquity, forming the basis of trade since the dawn of commerce and sedentism during the Neolithic Revolution. A notable early modern development in contract law was the emergence of the hawala system in the Indian subcontinent and the Arab world, under which a series of contractual relationships formed the basis of an informal value transfer system spanning the Silk Road. In the Indian subcontinent, the hawala system gave rise to the hundi, a transferrable contract entitling its holder in due course to obtain money from its issuer or an agent thereof, giving rise to the principle underlying contemporary negotiable instruments.


title: Contract

text: The hawala system also influenced the development of agency in common law and in civil laws. In Roman law, agents could not act on behalf of other individuals in the formation of binding contracts. On the other hand, Islamic law accepted agency as permissible in not only contract law but in the law of obligations generally, an approach that has since become mainstream in common law, mixed law, and most civil law jurisdictions. Analogously, the transfer of debt, which was not accepted under Roman law, became widely practiced in medieval European commerce, owing largely to trade with the Muslim world during the Middle Ages.


title: Contract

text: Since the nineteenth century, two distinct traditions of contract law emerged. Jurisdictions that were previously British colonies generally adopted English common law. Other jurisdictions largely adopted the civil law tradition, either inheriting a civil law legal system at independence or adopting civil and commercial codes based on German or French law. While jurisdictions such as Japan, South Korea, and the Republic of China modelled their contract law after the German pandectist tradition, the Arab world largely modelled its legal framework after the Napoleonic Code. While the Netherlands adopted a legal system based on the Napoleonic Code in the early 19th century, Dutch colonies retained the precedent-based Roman-Dutch law. British colonies in Southern Africa adopted Roman-Dutch principles in areas of private law via reception statutes adopting South African law, retaining Roman-Dutch law for most matters of private law while applying English common law principles in most matters of public law. Saint Lucia, Mauritius, Seychelles, and the Canadian province of Quebec are mixed law jurisdictions which primarily adhere to French legal tradition with regard to contract law and other principles of private law.


title: Contract

text: Over the course of the nineteenth and twentieth century, the majority of jurisdictions in the Middle East and East Asia adopted civil law legal frameworks based on the Napoleonic, German, or Swiss model. The Napoleonic Code shapes contract law across much of the Middle East, while contract law in Japan, South Korea, and the Republic of China is rooted in the German pandectist tradition. In 1926, Turkey replaced its Ottoman-era mixture of Islamic and secular laws with a secular civil code modelled after that of Switzerland, with its contract and commercial law modelled after the Swiss Code of Obligations, which was in turn influenced by German and French legal traditions. Following the Meiji Restoration, Japan adopted a series of legal codes modelled primarily after German law, adopting its commercial code in 1899. The Japanese adaptation of German civil law was spread to the Korean Peninsula and China as a result of Japanese occupation and influence, and continues to form the basis of the legal system in South Korea and the Republic of China. In 1949, Abd El-Razzak El-Sanhuri and Edouard Lambert drafted the Egyptian Civil Code, modelled after the Napoleonic Code but containing provisions designed to fit Arab and Islamic society. The Egyptian Civil Code was subsequently used as a model for the majority of Arab states.


title: Contract

text: In the 20th century, the growth of export trade led to countries adopting international conventions, such as the Hague-Visby Rules and the UN Convention on Contracts for the International Sale of Goods, bringing the various legal traditions closer together. In the early 20th century, the United States underwent the "Lochner era", in which the Supreme Court of the United States struck down economic regulations on the basis of freedom of contract and the Due Process Clause. These decisions were eventually overturned, and the Supreme Court established a deference to legislative statutes and regulations that restrict freedom of contract. The need to prevent discrimination and unfair business practices has placed additional restrictions on the freedom of contract. For example, the Civil Rights Act of 1964 restricted private racial discrimination against African-Americans. The US Constitution contains a Contract Clause, but this has been interpreted as only restricting the retroactive impairment of contracts. In the late twentieth and early twenty-first century, consumer protection legislation, such as Singapore's Consumer Protection (Fair Trading) Act 2003, progressively imposed limits upon the freedom of contract in order to prevent businesses from exploiting consumers.


title: Contract

text: In 1993, Harvey McGregor, a British barrister and academic, produced a "Contract Code" under the auspices of the English and Scottish Law Commissions, which was a proposal to both unify and codify the contract laws of England and Scotland. This document was offered as a possible "Contract Code for Europe", but tensions between English and German jurists meant that this proposal has so far come to naught. In spite of the European Union being an economic community with a range of trade rules, there continues to be no overarching "EU Law of Contract".


title: Contract

text: In 2021, Mainland China adopted the Civil Code of the People's Republic of China, which codifies its contract law in book three. While generally classified as a civil law jurisdiction, contract law in Mainland China has been influenced by a number of sources, including traditional Chinese views toward the role of law, the PRC's socialist background, the Japanese/German-based law of the Republic of China on Taiwan, and the English-based common law used in Hong Kong. Consequently, contract law in the Chinese mainland functions as a de facto mixed system. The 2021 civil code provides for the regulation of nominate contracts in a manner similar to that of jurisdictions such as Japan, Germany, France, and Québec.


title: Contract

text: The rules governing contracts vary between jurisdictions. In the majority of English-speaking countries, the rules are derived from English contract law which emerged as a result of precedents established by various courts in England over the centuries. Meanwhile, civil law jurisdictions generally derive their contract law from Roman law, although there are differences between German contract law, legal systems inspired by the Napoleonic Code or the Civil Code of Lower Canada (e.g. Québec and Saint Lucia), and jurisdictions following Roman-Dutch law (e.g. Indonesia and Suriname) or a mixture of Roman-Dutch law and English common law (e.g. South Africa and neighbouring countries).


title: Contract

text: In common law jurisdictions, the formation of a contract generally requires an offer, acceptance, consideration, and mutual intent to be bound. The concept of contract law as a distinct area of law in common law jurisdictions originated with the now-defunct writ of assumpsit, which was originally a tort action based on reliance. Although verbal contracts are generally binding in most common law jurisdictions, some types of contracts may require formalities such as being in writing or by deed.


title: Contract

text: A contract cannot be formed without assent of the two parties to be bound by its terms. Normally this is by written signature (which may include an electronic signature), but the assent may also be oral or by conduct. Assent may be given by an agent for a party.


title: Contract

text: Remedies for breach of contract include damages (monetary compensation for loss) and, for serious breaches only, cancellation. Specific performance and injunction may also be available if damages are insufficient.


title: Contract

text: In order for a legally enforceable contract to be formed, the parties must reach mutual assent (also called a meeting of the minds). This is typically reached through an offer and an acceptance which does not vary the offer's terms, which is known as the "mirror image rule". An offer is defined as a promise that is dependent on a certain act, promise, or forbearance given in exchange for the initial promise An acceptance is simply the assent of the other contracting party or parties to the terms stipulated in the contract. As an offer states the offeror's willingness to be bound to the terms proposed therein, a purported acceptance that varies the terms of an offer is not an acceptance but a counteroffer and hence a rejection of the original offer. The principle of offer and acceptance has been codified under the Indian Contract Act, 1872.


title: Contract

text: In determining if a meeting of the minds has occurred, the intention of contracting parties is interpreted objectively from the perspective of a reasonable person. The "objective" approach towards contractual intent was first used in the English case of "Smith v Hughes" in 1871. Where an offer specifies a particular mode of acceptance, only acceptance communicated via that method will be valid.


title: Contract

text: Contracts may be bilateral or unilateral. A bilateral contract is an agreement in which each of the parties to the contract makes a promise or set of promises to each other. For example, in a contract for the sale of a home, the buyer promises to pay the seller $200,000 in exchange for the seller's promise to deliver title to the property. Bilateral contracts commonly take place in the daily flow of commercial transactions. Less common are unilateral contracts, in which one party makes a promise, but the other side does not promise anything. In these cases, those accepting the offer are not required to communicate their acceptance to the offeror. In a reward contract, for example, a person who has lost a dog could promise a reward if the dog is found, through publication or orally. The payment could be additionally conditioned on the dog being returned alive. Those who learn of the reward are not required to search for the dog, but if someone finds the dog and delivers it, the promisor is required to pay. On the other hand, advertisements which promise bargains are generally regarded not as offers for unilateral contracts but merely "invitations to treat". Some have criticised the categorisation of contracts into bilateral and unilateral ones. For example, the High Court of Australia stated that the term unilateral contract is "unscientific and misleading".


title: Contract

text: In certain circumstances, an implied contract may be created. A contract is implied in fact if the circumstances imply that parties have reached an agreement even though they have not done so expressly. For example, if a patient refuses to pay after being examined by a doctor, the patient has breached a contract implied in fact. A contract which is implied in law is sometimes called a quasi-contract. Such contracts are means for courts to remedy situations in which one party would be unjustly enriched were he or she not required to compensate the other. Quantum meruit claims are an example.


title: Contract

text: Where something is advertised in a newspaper or on a poster, the advertisement will not normally constitute an offer but will instead be an invitation to treat, an indication that one or both parties are prepared to negotiate a deal. An exception arises if the advertisement makes a unilateral promise, such as the offer of a reward, as in the case of "Carlill v Carbolic Smoke Ball Co", decided in nineteenth-century England. The company, a pharmaceutical manufacturer, advertised a smoke ball that would, if sniffed "three times daily for two weeks", prevent users from catching the flu. If it failed to do so, the company promised to pay the user £100, adding that they had "deposited £1,000 in the Alliance Bank to show [their] sincerity in the matter". When the company was sued for the money, they argued the advert should not have been taken as a serious, legally binding offer but a puff. The Court of Appeal held that it would appear to a reasonable man that Carbolic had made a serious offer and determined that the reward was a contractual promise.


title: Contract

text: As decided in the case of Pharmaceutical Society of Great Britain v Boots Cash Cashiers, an offer that is made in response to an invitation to treat, without any negotiation or explicit modification of terms, is presumed to incorporate the terms of the invitation to treat.


title: Contract

text: In contract law, consideration refers to something of value which is given in exchange for the fulfilment of a promise. In "Dunlop v. Selfridge", Lord Dunedin described consideration "the price for which the promise of the other is bought". Consideration can take multiple forms and includes both benefits to the promisor and detriments to the promisee. Forbearance to act, for example, can constitute valid consideration, but only if a legal right is surrendered in the process. Common law jurisdictions require consideration for a simple contract to be binding, but allow contracts by deed to not require consideration. Similarly, under the Uniform Commercial Code, firm offers in most American jurisdictions are valid without consideration if signed by the offeror.


title: Contract

text: Consideration must be lawful for a contract to be binding. Applicable rules in determining if consideration is lawful exist both in case law and in the codes of some common law jurisdictions. The general principles of valid consideration in the common law tradition are that:


title: Contract

text: The insufficiency of past consideration is related to the "pre-existing duty rule". For example, in the early English case of "Eastwood v. Kenyon" [1840], the guardian of a young girl took out a loan to educate her. After she was married, her husband promised to pay the debt but the loan was determined to be past consideration. In the early English case of "Stilk v. Myrick" [1809], a captain promised to divide the wages of two deserters among the remaining crew if they agreed to sail home short-handed; however, this promise was found unenforceable as the crew were already contracted to sail the ship. The pre-existing duty rule also extends to general legal duties; for example, a promise to refrain from committing a tort or crime is not sufficient.


title: Contract

text: Some jurisdictions have modified the English principle or adopted new ones. For example, in the Indian Contract Act, 1872, past consideration constitutes valid consideration, and that consideration may be from any person even if not the promisee. The Indian Contract Act also codifies examples of when consideration is invalid, for example when it involves marriage or the provision of a public office.


title: Contract

text: The primary criticism of the doctrine of consideration is that it is purely a formality that merely serves to complicate commerce and create legal uncertainty by opening up otherwise simple contracts to scrutiny as to whether the consideration purportedly tendered satisfies the requirements of the law.


title: Contract

text: While the purpose of the doctrine was ostensibly to protect parties seeking to void oppressive contracts, this is currently accomplished through the use of a sophisticated variety of defences available to the party seeking to void a contract. In practice, the doctrine of consideration has resulted in a phenomenon similar to that of Ḥiyal in Islamic contracts, whereby parties to a contract use technicalities to satisfy requirements while in fact circumventing them in practice. Typically, this is in the form of "peppercorn" consideration, i.e. consideration that is negligible but still satisfies the requirements of law.


title: Contract

text: The doctrine of consideration has been expressly rejected by the UNIDROIT Principles of International Commercial Contracts on the grounds that it yields uncertainty and unnecessary litigation, thereby hindering international trade. Similarly, the United Nations Convention on Contracts for the International Sale of Goods does not require consideration for a contract to be valid, thereby excluding the doctrine with regard to contracts covered by the convention even in common law jurisdictions where it would otherwise apply. The continued existence of the doctrine in common law jurisdictions is controversial. Scots lawyer Harvey McGregor's "Contract Code", a Law Commission-sponsored proposal to both unite and codify English and Scots Law, proposed the abolition of consideration. Some commentators have suggested for consideration to be replaced by estoppel as a basis for contracts.


title: Contract

text: A contract is often evidenced in writing or by deed. The general rule is that a person who signs a contractual document will be bound by the terms in that document. This rule is referred to as the rule in "L'Estrange v Graucob" or the "signature rule". This rule was approved by the High Court of Australia in "Toll(FGCT) Pty Ltd v Alphapharm Pty Ltd". The rule typically binds a signatory to a contract regardless of whether they have actually read it, provided the document is contractual in nature. However, defences such as duress or unconscionability may enable the signer to avoid the obligation. Further, reasonable notice of a contract's terms must be given to the other party prior to their entry into the contract.


title: Contract

text: Written contracts have typically been preferred in common law legal systems. In 1677 England passed the Statute of Frauds which influenced similar statute of frauds laws in the United States and other countries such as Australia. In general, the Uniform Commercial Code as adopted in the United States requires a written contract for tangible product sales in excess of $500, and for real estate contracts to be written. If the contract is not required by law to be written, an oral contract is generally valid and legally binding. The United Kingdom has since replaced the original Statute of Frauds, but written contracts are still required for various circumstances such as land (through the Law of Property Act 1925).


title: Contract

text: Nonetheless, a valid contract may generally be made orally or even by conduct. An oral contract may also be called a parol contract or a verbal contract, with "verbal" meaning "spoken" rather than "in words", an established usage in British English with regards to contracts and agreements, and common although somewhat deprecated as "loose" in American English. An unwritten, unspoken contract, also known as "a contract implied by the acts of the parties", which can be legally implied either from the facts or as required in law. Implied-in-fact contracts are real contracts under which parties receive the "benefit of the bargain". However, contracts implied in law are also known as quasi-contracts, and the remedy is quantum meruit, the fair market value of goods or services rendered.


title: Contract

text: In commercial agreements it is presumed that parties intend to be legally bound unless the parties expressly state the opposite. For example, in "Rose & Frank Co v JR Crompton & Bros Ltd", an agreement between two business parties was not enforced because an "honour clause" in the document stated "this is not a commercial or legal agreement, but is only a statement of the intention of the parties". In contrast, domestic and social agreements such as those between children and parents are typically unenforceable on the basis of public policy. For example, in the English case "Balfour v. Balfour" a husband agreed to give his wife £30 a month while he was away from home, but the court refused to enforce the agreement when the husband stopped paying. In contrast, in "Merritt v Merritt" the court enforced an agreement between an estranged couple because the circumstances suggested their agreement was intended to have legal consequences.


title: Contract

text: If the terms of a contract are so uncertain or incomplete as to elude reasonable interpretation, the parties cannot have reached an agreement in the eyes of the law. An agreement to agree does not constitute a contract, and an inability to agree on key issues, which may include such things as price or safety, may cause an entire contract to fail. However, a court will attempt to give effect to commercial contracts where possible, by construing a reasonable construction of the contract. In New South Wales, even if there is uncertainty or incompleteness in a contract, the contract may still be binding on the parties if there is a sufficiently certain and complete clause requiring the parties to undergo arbitration, negotiation or mediation.