Right okay thank you for doing the average golfer out here at Conway Golf Club in absolute glorious sunshine I'll take my glove off for a second I'm about to hit the ball very very shortly I've been tested here all week and have you ever heard someone from the UK complain it's too hot at 10 o'clock in the morning as well anyway what we're here for well this video is all about the epic flash hybrid let's take the cover off it deserves to be out of its cover in my eyes it's one of the best-looking hybrids that's ever hit the market here's some images see what you think I mean one of the things that appeals to some or not to others is on the crown this sort of this imprinted carbon crown that we've seen on on all of the drivers the epic drivers in recent years I really like the way it looks but what I like about it is its sleekness at address as well this is fairly shallow I think they call away themselves and said it sits between the big birther and the and the apex in terms of their hybrid range and I would say it does in terms of profile as well but for me it's bang on the apex was a little bit too small the big birther a little bit on the bulky side this sits absolutely perfect it shallers off on the back end and whether you like the underneath or not it doesn't really make a great deal of difference because you don't see a great deal of that but anyway it looks superb I've got a four hybrid 21 degrees but it's adjustable it's adjustable two degrees up and perhaps is it two degrees down I'm not 100% sure should know that but the point is it's a quality product it's coming in at a quality premium price what's packed into it as you see from the images that thrown up there I never like to go too much into detail because let's be honest every manufacturer will sell a similar story it's about ball speed and it's about forgiveness how each company achieves that stiffer slightly but ultimately it's all about what happens when you get out here on the golf course that's exactly what we're gonna do now I want to stop talking we're gonna get some real proper feedback from situations that you find yourself out there on the golf course and then we'll come back here and I'll give you my overall assessments of this epic flash hybrid there's so much power in that I mean that's gone it's left a fairway you know you can see that and it's still rolling still rolling still rolling we're a bit downwind so it's an absolute perfect weapon for this type of golf course right now if you can get that ball flight as first strike this thing has literally come out the wrapper you'll see some other balls in a fairway that's a bit 5 iron on this tee as well for a different video on the epic flash but that was unreal in terms of how that felt out the face it's just that's got some power packed into that I'm saying no more because literally let's find another seat position that's a great start thing goes on mild absolute mild I'll eat it out a bit down the right but in terms of picking it up again you'll see if you watch both videos of the flash irons and the hybrid today I've teed off and hit from some similar positions of just its 7 iron in the flash irons again from that position but unreal out picks the ball up again off a very very tight line incredible ball flight we're slightly down breeze and it'd be interesting to see like I said when I switch this round and we're going the opposite way but that's absolutely travel for miles and don't forget this a 21 degree for hybrid right so perfect scenario for a hybrid I think most people one of the main reasons they'll put hybrid in the bag amongst other things is to play it from a little bit of a lie in the roof and this isn't a particularly heavy don't get me wrong we're going to play the you probably just see the 200 yard marker we're into the breeze there's a perfect shot to try and see what I can do at least with this epic flash well if anything that's absolutely flu and I think it's too big it's bulleted out the roof I mean the ball flight was a little bit lower and again perhaps coming out that roof again just kill that ball flight just like I said just didn't pick it up quite as high as they have done on previous shots but we'll go and see where that one's finished up now I've put the camera position where it is because flag was playing probably about 198 I think I added that we probably carried that and don't forget that into the wind that's got to have well we've run out there about 240 it's a powerful hybrid this thing and something you'd have to get used to in terms of that yardage I came out off that face like an absolute bullet to tell you now anyone who plays come my golf will tell you the same holes 16 and 17 are a very very tight finish to your round and in a position like this what I like I don't know about you but I like a bit of a go-to club something that I've got confidence with and I would normally choose something like a three wood I'm like in the mini driver right now or perhaps even a long iron but a hybrid would certainly this is where this epic flash hybrid for me that the carries the distances that I'm achieving I see it as a club that I can play from the tee and a bit of a go-to club maybe let's see how we get on 16 so you want to be idea the left of center well I certainly doing your left of center and it cambers from left to right left you dead right you dead you have a lot of options does it sit beautiful behind the ball the epic hybrid it really does oh wow that's the best strike of it today wow now again it's been difficult in terms of both like we're either into the Sun or against it and I'm afraid you might pick that one up and I'm certainly being the shadow right now I don't even tell from sound but it's absolutely pure out the middle I've got to say I mean I'm loving this right now it's first few shots I'm not swinging the club that great today that was probably the best ball contact I've had club on ball but I have to say on every occasion it's done a job for me we're into the breeze here and again I would suggest that's done a fair bit of travel right as you know most keen on some feedback and what I want to know from you is your game in a hybrid and if you are which one have you got in the bag how'd you find it and where do you use it I suppose as well I mean how reliant are you on a hybrid nowadays because it tends to be for an average golfer it's pretty much a bit of a go-to club I think. I nearly cursed myself by starting a commentary before I hit the ball but I thought I'll just wait and see how this goes and believe me what I was going to say if I find the fairway on 17 this might well go in the bag because this again I mentioned on 16 or 17 is even tighter it's a real card wrecker aim down the left hand side hopefully for a bit of cut it cuts a little bit but it basically stayed down that left hand side again it's got a decent bit of distance on it I would imagine that's again to 20 the interesting thing for me is this 21 degrees that the the hybrid that I've got before it goes up to a six hybrid and I think the six hybrid five and six hybrid if you're struggling with your long irons four five and six in this are gonna be a real big help to you because like I said they've got a lot of power right across the club face some unbelievable distances and for me it's similarities to what I said about the mini one driver in terms of control off the tee if I could go if I've got a go-to club that I can get sort of to 20 out of sure to shaft small head there bit of control over it then it's something that inspires confidence and that's the big deal for me it's that control you've got with these type of clubs but then being able to achieve those kind of distances as well and that's obviously all relative to what we all hit and play but for me that sits banging on if I'm stood on 17 team we've done it on 16 they've found two fairways then that's good enough for me it's just I just look for words on the hybrid because I would keep putting like so many positives towards one club but it literally does do at the minute the only thing I'd say it's hard to abandon with it right so round over I've just got a summarise on this epic flash and I'm gonna make this very very brief indeed it's a beast it's a monster it's a powerhouse of a hybrid I can't say no more than that really very difficult to pick fault go and try it yourself as a simplest thing I could say incredibly fast ball speeds right across the club face and great ball flight ticks every single box price down to you as always right I'm gonna make it that brief it is as simple as that I'm afraid you've seen what happened out there on the course we don't need dry ball data we need nothing more you see what happens you see now it performed I can't do any better than that anyway as ever thank you for watching please subscribe if you do subscribe hit that notifications button if the like button get involved in the comments down below and I'll see you all very soon


We now want to discuss another exciting feature, and that is Google Calendar enables you to learn and track public events that occur throughout the year. Public events that can affect your business, can affect when your business is open or when it is closed, or can affect the promotions and marketing plans that you have scheduled throughout your year. Let's look at how that happens. I have a setting called Holidays in the United States. When I click on it, holidays that occur during the month appear. I have them colored in green. So in February, as you can see, Valentine's Day is on the 14th and President's Day is on the 15th. We both may want to promote President's Day in our business. If we click forward in the month of March, there are two key holidays or moments that occur Easter Sunday, for example, something you may wish to promote in your business. If we click forward, we see that on the 13th of April, another President's Day occurs, this one being Thomas Jefferson. If you are promoting presidential holidays, this gives you a chance to plan accordingly. There are other interesting calendars that you can use as well for this purpose. If you go to other calendars and click on the down arrow on the right, you'll see a setting called Browse, Interesting Calendars. Click on it and a listing occurs for holidays around the world. You can click on previewing any one of the countries or any one of these calendars and you'll see what is going on for them in the month that you choose. If you click forward month to month, you can see what all of the holidays are. I happen to be holidays in Angola. For the month of February, I see Carnival occurs on the 17th. That's a big day. You may want to organize an event around that day. In addition to holidays, as you can see, there are sports that you can follow. Let me close this and now open sports. There are all the major sports, baseball, basketball, etc. You pick the one you want to review. Click on the arrow on the right. I picked baseball and all of the major league teams around the world are there for my review. There are more interesting calendars to look at. As you can see, when you click on it, a list of interesting calendars occur, preview any one of them, and use the information you learn there to engage with your team members, to engage with your customers, your clients, and just enjoy that activity with them. This is an exciting feature of Google Calendar. Enjoy it.


The first and foremost hallmark of a good content strategy is that it has to connect with the audience and engage with the audience in their local and native language. So I think the rise of Indic content consumption holds the key to a good marketing strategy within content. Now within that itself, I think the form which they have been a lot of debate about what should the duration of content especially in the video format or in the audio format. My point of view is that it's not a duration which matters in a good content strategy. It is the content engagement which matters and they're the best form I believe is storytelling. So I think if you can narrate strong good connected stories, it forms the backbone of a good content strategy along with the regional and vernacular dimension to it. I don't think so there's a direct correlation which you can put right now saying if I do content marketing, my overall marketing cost will go down. In initial stages the way industry is right now, in fact the cost could be even higher because you know what is going to happen is like the way I talked some time back is that content marketing is boundary less, there are no political boundaries to it. You're consuming content in a certain language sitting in completely different geography altogether. The life of content asset is much lower than the life of maybe a TV asset as we have known. So the assets get multiplied, the assets durations get shorter and the assets timelines become shorter as well. So initially you'll have to maybe invest in multiple creatives, you'll have to find you going through multiple genres, you'll find yourself experimenting with multiple you know platforms. Hence it's very difficult right now to say whether content marketing immediately can give you a cost saving on the overall marketing plan. What it can definitely do is, it can give you much greater engaged quality if it is done rightly. And I think that's the perspective I would keep it in limited to right now. And as I said as scale and localization both take place the cost will do come down. First of all the biggest change in transition has been the awareness about digital evolution and digital adoption cannot happen without quality content and more specifically regional quality content because that's the way we are as a country. We are a country of multiple regions. So I think that's the first change which has happened in the last four to five years that's a big realization. Second transition which is really happening is that we are clearly realizing that if this is the way it's not a game of language, one language master to multiple language audit. It's a game of multiple language masters and it's a game of faster quicker turn around in content consumption. And I think that's putting a lot of pressure on the ecosystem, that's putting a lot of pressure on the marketing teams to keep pace but I think that's also giving us a much better idea of how to connect and engage with digital audience. No I don't agree with that because the fact is even though digital marketing spends are growing at the fastest rate among all constituents the fact is TV itself is projected to grow at a healthier rate, print strength has not gone down so I guess there will be a space for at least these three mediums definitely I see between TV print and digital. Yes digital will grow bigger especially in the back of regional content but I think traditional marketing will have its own evolution. We are already seeing TV for example is in any case moving on to digital screens. It's evolving in its own way. It's realizing that it needs to keep pace with this new technology updates. We've seen print gone online so I think there will be a place for both traditional marketing and digital which will coexist. I don't think so there's any content marketing possible without evolution of technologies. I think the whole existence of digital today is the kind of technology disruption we're seeing and finally the kind of technology disruption which happen almost every quarter in the world today are changing the way our paradigms have always existed about marketing to consumers even to digital consumers and I think technology will keep on continuing challenging all of us and giving us some multiple and disruptive opportunities to reach out to audience in a very very personalized way.


I really think intersectionality helps us understand our current political dilemmas. And I think it's evolving as a theory. I think it's a relatively new set of ideas, but many of us are winners in some respects and losers in others. Yes, there's some people who are at the bottom of every single hierarchy that's ever been imagined. And there's some who are at the very, very top. And if we look at them, we see that they often, those at the very, very bottom and very, very, very top have very similar characteristics. Those at the top tend to be from rich countries. They tend to be white and they tend to be male and they tend to own capital, right? At the other extreme, the mere image of that. But a lot of us are in between. So we're winners in some respects and we're losers in others. And so that means when we think about how to allocate our time and energy and collective action, we might want to advance the interests of our group, but we belong to many groups. So the strategic dilemma is pretty great. Hello, I'm Jayati Ghosh. I teach economics at the University of Massachusetts at Amherst in the US. And before that, I've been teaching for three and a half decades in Jawaharlal Nehru University in India. Today, I'm really delighted to be able to talk to Nancy Folbre, professor at the University of Massachusetts at Amherst as well, about her new book, The Rise and Decline of Patriarchal Systems, An Intersectional Political Economy. Nancy Folbre is well known to many people as one of the founders, really, of a branch of economics which I hesitate to call feminist economics because I really think it should be called human economics. So Nancy, thank you so much for joining me today. Oh, thank you so much, Jayati. I can't think of anyone I would rather be interviewed by. Oh, wow, I love that, so thank you for that. So Nancy, can you begin by just telling us in this book what exactly, I mean, I'm not going to ask what you're going to try to do because it's huge. I think the canvas you've taken on is enormous. But I think what is really striking is how you have picked on care as this fundamental concept that affects how economies are organized and what patriarchal systems are really all about. So can you tell us a little bit about that? Well, you know, historically, economics is really focused on the production of commodities, on things that are bought and sold in markets. But the economy really depends on human capabilities.  And I think we need to reverse the lens and think about the production of human capabilities as our end goal. Gross domestic product is an input into that rather than seeing workers as an input into the production of things that are bought and sold. And so I define care very much in those terms as involving the creation and the development and also the maintenance of human capabilities. So not just children, but people who are experiencing sickness or disability or the frailty of old age. This is a really central process and we can't just leave it up to nature or leave it up to kind of culture or leave it up to preferences. We have to think about how it's organized because it's organization, like the organization of commodity production involves both cooperation and conflict and collective conflict between men and women, between rich and poor, between citizens of rich countries and poor countries. All of those dimensions of collective conflict have an influence on the allocation of resources to care. You know, that's, it's so fascinating to hear you put it this way in terms of this sort of, you know, dilemma between conflict and cooperation within societies which in turn determines really how care is distributed and who performs the care. But one of the other very fascinating insights I think in your book is really about the nature of care about how it's different from other activities and that the very performance of care somehow reduces if you like the socially bargaining power of those who are doing it. Well, you know, care really requires some identification with and concern for the wellbeing of the person being cared for. And also it's not standardized. It has to be, you know, tailored to responding to the particular needs of an individual person. In fact, you could even think of care as something that's co-produced by the person receiving it and the person giving it.  And if they don't, you're not a successful teacher. If you're a doctor, you need to persuade your patient to be mindful of the ways to promote good health and to follow the best guidance and instruction in that whole process. You know, the challenge of parenting is to persuade children to do things that are good for them, you know, without resorting to threats or completely authoritarian parenting. So it really involves the creation of cooperative attachments between people. And that in itself makes it difficult for people to just, you know, enter and exit freely and go from one relationship to another because you, you know, attachment itself is sticky. And once you become attached to people who need your assistance, it's very hard to threaten to withdraw it. There's that wonderful phrase in your book that basically the caregivers, that you care about those whom you are caring for. And then that in turn, as you say, because it affects your ability to withdraw it, means that you have less bargaining power. Yeah, and I think ordinary people really experience this in a lot of ways. Like sometimes I think we realize that we're likely to become attached to people who need our help. And we kind of preemptively avoid putting ourselves in a situation where we might form that attachment because we know that it will be costly.  You wanna shut that out because you know, if you see it, you'll feel the need to help out. So I think there's this, you know, it's not just that people get attached, it's also that we often have elaborate ways of preventing ourselves from getting attached to people who we think might be too needy. But then there's also this very profound point that essentially empathy, therefore underlies the economic order. That economies use empathy to generate care. Yes, empathy is really required. But in general, I would say also, there's a sense in which a lot of social institutions impose obligations on groups of people to provide this empathy. And it's not as though the natural force of empathy is sufficient to solve the problem. It has to be kind of reinforced and channeled by social institutions. And I think that's one of the reasons that patriarchal systems emerge is that they are systems that basically channel and reinforce the distribution of caring commitments, often basically requiring women to devote much more time and energy to care than men. And that is at the heart in many ways of women's reduced bargaining power. You know, there are these four concepts that economists use all the time, particularly I would say Marxist or socialist economists who use these concepts that you unpack. And I think you brilliantly dissect, which once you look at care from this particular vantage point, production, mode of production, social reproduction, exploitation, I think you really do unpack. Can you explain a little bit, for example, production? How does that change once we incorporate this particular notion? Well, I think it becomes bigger instead of being just about the production of things, it becomes about the production of people. And then not just the production of people, but also the production of the relationships and the institutions that enable people to cooperate with one another. So I guess I think the traditional Marxian emphasis on surplus value and the creation of a surplus, it's just, it's too simple. As though you can just easily distinguish the seed corn from the corn you have to consume from the surplus corn that's left over. In fact, for many years I used to teach Marxian economics using this piles of corn analogy. And the more I taught it, the more I realized it was really too simple to think about surplus in terms of a physical product. I mean, another way to put it is that population growth itself is a kind of surplus. If you are accumulating more, creating more people over time, creating more resources in terms of population and human capital, that too is a form of surplus. And I think that's a real challenge to the way that the word production is traditionally deployed. And then that feeds into the whole mode of production thing, you know, where we tend to think in these rather simplistic, as you've mentioned, movements between, you know, the primitive kinds of things to slavery, to feudalism, to capitalism. Yeah, because that centering of the productive technology became kind of the way to define the stages of history. You know, hunter-gatherers to sedentary agriculture to feudal systems to capitalist systems, et cetera, et cetera. And don't get me wrong. I think productive technologies have a big impact. And I've been very influenced by the theory of historical materialism, which I think really emphasizes kind of an evolutionary dynamic and dialectic by which societies change over time. But instead of thinking about how things are produced, I think we should think more about institutions of collective power. So I'm kind of bringing collective power to the fore and saying, let's look at the social institutions that give some groups power over others. And for instance, the ways in which patriarchal institutions give adult men power over women and children, but also to ask how those institutions are related to class, institutions of class power, and institutions of racial ethnic power, and many, many other forms of collective power. And I think it's the way in which these different structures kind of interact and interlock, and sometimes conflict with one another that's really a key to understanding the historical complexity, as it were. That's kind of central in your understanding of exploitation as well, isn't it? That you're really bringing in the fact of this power, which is sometimes compounded by cultural norms and different kinds of social norms and so on. So how does that differ from the standard sort of Marxian notion of exploitation? Well, the standard Marxian notion of exploitation is the appropriation of surplus value in production. So it's a very production-centric notion. And Marxian theorists have always been, no, not always, but have often been very sympathetic to struggles against inequality based on gender, race, national identity, so forth and so on, but have always sort of relegated them, have always sort of seen them as political or cultural or identity politics or not as economic. But I think if your focus is on collective bargaining power, it's possible to define exploitation as something that emerges when one group has enough collective bargaining power to claim a larger share of the gains from cooperation than they otherwise would have. And that general definition kind of subsumes the traditional Marxian theory of exploitation, which holds that capitalists have the power to extract surplus value because of the way in which they use the state to expropriate common property and common access to the means of production. So it's really kind of a generalization of that principle. So you could see that like a patriarchal law, like denying women property rights, gives men and women still cooperate, but men are able to claim a disproportionate share of the gains from cooperation because they have that institutional bargaining power that comes from laws, from ownership of property and also from cultural norms. You know, I think this actually leads immediately to something that many people ask about intersectionality. It's very clear to me that your concept is a much more profound concept than simply saying, oh, people have different identities and all of that. You're really making a much broader point about the interplay of these economic and social and cultural processes, aren't you? Well, you know, I really think intersectionality helps us understand our current political dilemmas in some really crucial ways. And I think it's evolving as a theory. I think it's a relatively new set of ideas and I guess I like to frame it as an emphasis on the fact that we're all, not all, but many of us are winners in some respects and losers in others. Yes, there's some people who are at the bottom of every single hierarchy that's ever been imagined and there's some who are at the very, very top. And if we look at them, we see that they often, those at the very, very bottom and very, very, very top, have very similar characteristics. Those at the top tend to be from rich countries. They tend to be white and they tend to be male and they tend to own capital, right? At the other extreme, the mere image of that, but a lot of us are in between. So we're winners in some respects and we're losers in others. And so that means when we think about how to allocate our time and energy and collective action, we might wanna advance the interests of our group, but we belong to many groups. So the strategic dilemma is pretty great and if you're advantaged in a significant way among one dimension, you might be very reluctant to challenge another dimension in which you're actually at a disadvantage. I think because people are really afraid of loss, any loss of position is generally more painful than failure to gain something. Intersectionality helps explain why hierarchical systems are so stable because a lot of people in the middle are very reluctant to challenge a structure that might be destabilized in a way that means their net benefits might be reduced. You're right that thinking about it in this way really does transform even how you look at political changes and many of these things. But then I suppose people would ask you what explains the optimism of your title, the decline of patriarchal systems that you also talk about in some of your chapters. I mean, I think that's so important to look at the other side of it. And I think just remember that's the nature of complex systems that they have contradictory effects. And in fact, that was a really key element of the Marxian analysis of capitalism and in many respects, it was a progressive force that developed technological change and that kind of undermined the feudal order. But it also had a downside in terms of its in terms of its exploitative aspects and its sort of vulnerability to crisis, right? So, you know, my take on capitalism is very similar actually to that vision. I would rather than emphasizing sort of the way which capitalism displaced and undermined feudal relations, I would say capitalism tends to destabilize some patriarchal relations. And in fact, patriarchal and feudal institutions often go together. But you know, one of the things that the technological dynamism of capitalism does is it undermines the family as a unit of production. It means that production moves outside the family to the factory, to the firm, capitalist firm. And as a result, it kind of undermines patriarchal control over women and children to the extent that that was based on kind of ownership of property or control over a commons. And so the younger generation begins to gain some independence from parents and women begin to gain some alternatives to marriage and complete specialization in the family division of labor. And that has some very liberating aspects for women, especially women who are less encumbered by reproductive responsibilities and care responsibilities. So I think single white women with access to education living in rich countries have made enormous gains. So there's this intersectional kind of unevenness to the destabilization of patriarchal institutions. But it also has a kind of cultural and normative spillover effect. And I think we're still trying to understand exactly how to what extent capitalist development is undermining some patriarchal institutions and yet reinforcing others. And in particular, I think capitalism tends to reinforce the idea that women are responsible for care and that care does not need to be socialized, publicly supported, publicly recognized or rewarded. So yeah, I may be optimistic in talking about the decline, but I see at least a possibility of it tipping in the downward direction. So you're probably right in the northern kind of context, but in most developing countries, many of us see it going the other way, actually, that you're getting a reinforcement of the worst kinds of patriarchal norms and gains made are often destroyed, not just by political changes, but even by neoliberalism, which forces more and more onto households. Well, I think that's absolutely true. And I think one of the things I try to emphasize in my book is that the form that capitalist development has taken in less developed countries is very, very different. There has not been a big expansion of wage employment. There has not been a big growth in opportunities for independent employment outside the home. There's been a huge ballooning of informal sector employment that is very unstable and very marginalized and not something that really gives those who participate in it very much economic independence or bargaining power. What I would argue is you could see that as kind of a failure of capitalism or an insufficiency of capitalism, that this idea that the capitalist development would be an exerable force for advancing living standards on a global level has really proven pretty false, because we've seen a tremendous concentration of wealth that means that, I don't know, we could call it a global capitalist system, but in a way it's a more complex system where capitalism in rich countries has delivered significant increases in living standards, but elsewhere, not so clear. Which I suppose would link with the kind of global imbalances of economic power and political power and imperialism broadly, which would bring in another kind of intersectionality too. I think, but even in the developing world, I think one of the things that you mentioned in your later chapters, in terms of the importance of coalitions and the importance of looking beyond your own specific thing for larger social movements, is still so important and so necessary. I think that whenever really serious global problems emerge that clearly require cooperation rather than competition, you see the emergence of new coalitions. And I think the COVID-19 pandemic is so transparently a global problem that markets themselves cannot really address, that it's kind of created a basis for new kinds of coalitions. But also, I think climate change is another very important global threat. It really requires cooperation and collaboration on a global level that we have never achieved in the past. And I would like to think that that's going to be a real impetus to rethinking a lot of the institutional arrangements that we've relied on during a period of economic growth where we had the luxury of ignoring effects on our social environment and our physical environment or natural environment. I'm sure all of you realize how fascinating Nancy's book is. If this is just a small flavor of the many, many insights and the rich tapestry that she weaves in this book. So if this hasn't got you interested in reading this book, I don't know what will, but I assure you it's really worth it. Thank you so much, Nancy, for joining us. Toyota, thank you for your optimism on all fronts.


The Russian branch of the SCP Wiki, as well as numerous SCP artists in Eurasian countries, are being extorted by a man named Andre Dukeson using a fraudulent trademark. To make a long story short, Dukeson made an SCP art book. He then registered a trademark for the SCP logo in Russia. As all SCP works are legally required to be released via the Creative Commons 3.0 share-like license, this was, to simply put it, extremely fraudulent. He's issued takedowns of numerous SCP projects on his side of the world, and is now attempting to force his way into an admin role on the Russian branch of the Wiki itself. We as a community cannot stand by. We cannot let this person rest control the Wiki from those who wrote the stories and made it thrive. Click the link to find ways you can help. Later this week, the Wiki staff will be unveiling a link where you can donate to fund a lawsuit against Andre. Please share this anywhere you can. Get a hashtag, stand with SCPRU trending, and donate through the proper channels later this week.


Join me on Instagram beautiful pictures for you guys and give you lots of good information so that you can prepare yourself well for a PA school What's up you guys it's Adonna. I am back with another video for you guys I just wanted to give a quick shout out to all of my subscribers. I really appreciate you guys I love all of the comments that you're leaving me the emails that you're sending me It just helps me a lot to just stay motivated and know that hey I can do this and what I'm doing is worth it. So thank you guys so much for that I did want to talk to you guys today about just work life school balance in a sense Um, I know that prior to PA school. I did let you guys know that hey, I got declined I got rejected from PA schools and I had to take classes over and it was really um, it was really hard It was really hard you guys I was a mom I was a wife and I had to be a student. I worked so it was difficult just trying to balance everything out I took four classes in one month because I wanted to make sure that I could boost my GPA up and That on top of going to school Well going to school on top of actually having to work as well as be a mom and a wife It definitely took a great juggling act But what was beneficial and what I feel like everyone should have is a great support system. My husband was Amazing, he was really great. He helped out a lot and I needed it You know, he stayed with the kids when I was at work or when I had to go to school and I didn't have to worry about that That was one less thing that I needed to worry about all I needed to worry about was getting some good grades So that I can apply to PA school and make sure that I was the best candidate possible going forward for each school that I applied to So definitely make sure that you have a great support system in your life And also make sure that you tell them that you're appreciative of them I need you to know you are awesome That helps out a lot because I know a lot times people are very like giving they support they give you Give give give I'm talking about a whole lot of awesome But then they feel like all you're doing is just taking so make making sure that you're not just taking from them But also giving in return. I'm talking about like incomprehensible awesome So I just wanted you to know that today I also did a lot of like trying to make sure that I was intentional about spending time with my kids like if I came Home and they were asleep. There's you know, I couldn't avoid that But I come home and they're awake like alright I'm gonna get down on the floor and talk to you or you know, if my little ones like hey mommy can play with me Then we're gonna go play Jenga It's not always feasible But you have to make the time because you don't want them to in the future be like alright Well, you know, I was always studying or sleeping or working She didn't have time for me because that's really why I came into this profession So my kids will never have to say that that I didn't have time for them I want to be able to spend time with them as far as school goes school was definitely I think that was like the easiest part of that whole process and getting into praise PA school that whole balancing I did a lot of studying Finding the time to study may have been a little bit difficult But I had to do what I had to do So I would either study late at night or study really early in the morning because I had a teacher who told me I think it was melanin or melatonin. I think it's melatonin That it is diurnal So it goes down as the day goes on and as the night comes on so it helps you retain Information and study so it's better to study in the morning. So that's what I would do I would wake up really early and study. I think it was beneficial. I got good grades So I guess it worked, but I did a lot of different little study mnemonics and songs and tactics and things to try to get myself to remember the information which was beneficial because it helped cut down on That study time. So that was also something that I really hold true to and then work work is always like irritating You're always like, oh man, I gotta go to work, but I would study at work I would do different things that I made like I applied to some schools while I was at work I just you do what you have to do you have to do what you got to do to get into PA school So I mean all within normal limits, okay, like all within like the law and you know good stuff Like but if I had to study at work, I did, you know, if I had to study while I was on the toilet I did if I was going through something in my head while I was taking shower I did that and and that's okay. Do what works best for you But also make sure that you're utilizing your time as much and as best as possible because that's all it's It's there for that moment and then it's gone So definitely utilize their time wisely. So that is the take home for balancing, you know My life prior to PA school and trying to get into PA school I really just utilize my time wisely I did what I had to do if I was studying and brushing my teeth. That's what I did I would I would go to sleep with something on my mind and wake up with it on my mind Like I was dreaming about that class Which is beneficial.  You will make it You will get into PA school or med school or nursing school and P school, whatever it is You're trying to do you will definitely do it if you utilize your time wisely All right, you guys. Thank you guys so much for watching If you do want to hear about what my life is like now in PA school Balancing that life is a whole different dynamic. Just leave a comment below or hit that like button See you guys next


I am Mr. Sarvajne Gandhi, working as assistant professor in Department of Mechanical Engineering from Balchan Institute of Technology, Solapur. In this session, we are going to study regarding steps to construct root locus and plot the root locus using MATLAB. At the end of the session, students will be able to apply the rules to construct root locus and solve the root locus problems and analyze the nature of root locus. So, we have step number 5 where we are going to find breakaway point. So, for finding breakaway point step one is to have the characteristic equation that is 1 plus g of s into h of s. So, in this case, we have 1 plus k divided by s into s plus 5 into s plus 10. So, if we try to simplify, we have 1 plus k into s square plus 5 s into s plus 10. So, if we further try to simplify, we will get 1 plus k divided by s cube plus 15 s square plus 50 s. So, we have characteristic equation as s cube plus 15 s square plus 50 s plus k equal to 0. So, then we have step number 2 where we are going to take the terms with k on one side. So, we are going to have k as minus s cube minus 15 s square minus 50 s. So, in step number 3, we are going to have d k by d s. So, it will be minus 3 s square minus 30 s minus 50 and you are going to equate it to 0. So, you have 3 s square plus 30 s plus 50 equal to 0. So, if you try to find the roots of this, you are going to have s 1 as minus 2.113 and s 2 as minus 7.88. Out of this, which one is to be selected? Minus 2.11 or minus 7.88. So, you need to see these points on the root locus that you have drawn in step number 2. If you see that minus 2.11 is going to lie somewhere over here. So, it is a part of root locus. So, from that we can say that minus 2.11 is a valid breakaway point and 7.8 lies somewhere over here. So, it is not a part of root locus. So, that point is invalid. Other method to check whether this point is valid or invalid is to put the value of s as minus 2.11 in this step number 2, where we have k. So, if we are going to get the value of k as positive, it implies that that is valid breakaway point. If we are getting the k value as negative, that implies that it is invalid breakaway point. So, if we put the value of s as minus 2.11 in this equation, you are going to get positive value of k and it will be 48.112 and that implies that it is a valid breakaway point. This is invalid. Fine. Then we have step number 6, where you are going to have intersection with imaginary axis. So, for that we require the characteristic equation that we have already found that is s cube plus 15s square plus 50s plus k equal to 0. So, from that you are supposed to construct Routh's array. The highest power is 3, then s raised to 2, then we have 1, 15, 50 and k. So, for s raised to 1, you are going to have 750 minus k divided by 15 and for s raised to 0, you are going to have k and you are going to select the element which has the k involved in it. So, that is 750 minus k divided by 15 and you are equating it to 0. So, you are going to get k marginal value as 750. Since k marginal value is positive, so that implies that it is going to have intersection. Correct? It is going to have intersection and for that you need to consider the auxiliary equation which is a row which is present immediately above that element. So, it will be 15s square plus k equal to 0. So, we have auxiliary equation as 15s square plus k equal to 0. We are going to keep the value of k as k marginal and it is equated to 0. So, we have 15s square plus 750 equal to 0. If you try to solve, you are going to have two roots plus or minus 7.07j which is intersection with imaginary axis. Then we have step number 7. So, in this case, we do not have complex conjugate either poles or zeros. So, this step is not applicable for us. Then we have step number 8. So, in this step number 8, we are going to have the plot on graph paper. In step number 8, we are going to draw the final plot on s plane. From the open loop transfer function, we know that the poles are at 0. It is at minus 5 and it is at minus 10 and the root locus is existing between 0 and minus 5 and from minus 10 up to minus infinity. We know the centroid is located at minus 5 and from here, the asymptotes is going to pass with angle of 60, 180 and 300. So, this represents theta 1 which is at 60 degree. This represents theta 2 which is at 180 and this represents theta 3 which is at 300 degrees. Then we came to know that the breakaway point which is a valid breakaway point is at minus 2.11. So, that is breakaway point and we came to know that the K marginal value is 750 and it is going to have the intersection with imaginary axis at plus or minus 7.07 j. So, we are going to draw a root locus which is going to pass through this breakaway point and it is going to have intersection with imaginary axis at plus or minus 7.07 j. So, from here, the root locus is going to start and it is going to cut this imaginary axis at 7.07 j. Similarly, it is going to pass through this breakaway point and have intersection with imaginary axis at minus 7.07 j. So, if you see p minus z, so from that we know three branches are approaching infinity. So, this is the first branch which is approaching infinity, this is the second branch which is approaching infinity and this is the third branch which is approaching infinity. Step number 9, we are going to comment on stability. The K marginal value is 750 that represent the system is marginally stable when K value is less than 750 and greater than zero. So, we say that the system is stable. K value is greater than 750 then we say that the system is unstable. These are my references. Thank you.


Hi friends, I am Pooja and today we will discuss the following question. In a hostel, 60% of the students read Hindi newspaper, 40% read English newspaper and 20% read both Hindi and English newspapers. A student is selected at random. If she reads English newspaper, find the probability that she reads Hindi newspaper. Now the conditional probability of an event E given the occurrence of the event F is given by probability of E given F is equal to probability of E intersection F upon probability of F and her probability of F is not equal to 0. So this is the key idea behind our question. Let us begin with the solution now. Now in the question we have, if she reads English newspaper, find the probability that she reads Hindi newspaper. So let E be the event that she reads Hindi newspaper. Then probability of E is equal to 60 upon 100 because we are given that 60% of the students read Hindi newspaper. And this is equal to 3 upon 5 and let F be the event that she reads English newspaper. Then we have probability of F is equal to 40 upon 100 because we are given that 40% of the students read English newspaper and this is equal to 2 upon 5. Now we are also given that 20% of the students read both Hindi and English newspapers. So probability of E intersection F that is probability that she reads both newspapers is equal to 20 upon 100 and this is equal to 1 upon 5. In the question we have, a student is selected at random. If she reads English newspaper, find the probability that she reads Hindi newspaper. So we have to find probability of E provided F has happened that is we have to find probability of E given F. Now by key idea we know that the conditional probability of an event E given the occurrence of the event F is given by probability of E given F which is equal to probability of E intersection F upon probability of F and here probability of F is not equal to 0. So probability of E given F is equal to probability of E intersection F upon probability of F this is equal to now probability of E intersection F is equal to 1 upon 5 upon probability of F which is equal to 2 upon 5 and this is equal to 1 upon 2. So we have got our answer as 1 upon 2. Hope you have understood the solution. Bye and take care.


Good evening, Lords, ladies, gentlemen, students, all our faculty visitors and friends. I'm Sarah Worthington and I'm delighted to welcome you to the faculty for the 2015 Alun and Overy lecture. This is the fourth in a series that Alun and Overy generously sponsor. The first lecture was in 2012 and marked the launch of the Cambridge Private Law Centre. I think it's a tribute to Alun and Overy that, right from the outset, Mae'n ddechrau'n cyd-dillod yma o ran o'r ymwyonau. Dyma'r lleffordd rydyn ni'n ddechrau'n ddau'r traddiffinol. A ddod o'r Llyfrgell ddau cyd-dillodau fel gweithio'r gweithio'r llefforddau o'r pethau'r llefforddau cyd-dillodau o'r llyfrgellol ddiolchol. Mae'n mynd i'n ddiweddillod yma o'r traddiffinol. Llyfrgell Grafynor'r llefforddau yn ei ddod o'r llefforddau o'r cyd-dillodau a'r llyfrgell. Ac yn rhywbeth arweigio'r ystyried ymddangosikrwyddol yn gyfleoedd y Llywodraeth Llywodraeth yn dod. Mae ydych chi'n amlwg ar gyfer y Llywodraeth yn ysgrifennu oherwydd ar gyfer y Llywodraeth yn ymddangosikrwyddol. Cyfaint y byddai'n gweithio'r ysgolwyr yn golygu darliadau, ac yn y byddai'n gweithio'r ysgrifennu, ac yn yng Nghymbr 2014 rydych chi'n gweithio'r cyfrifiad, ac yn ymddangosod, Rwy'n credu cyfnod y ddweud y ddweud o'r Cyfnodd Gweithgaredd yn cael ei ddweud o'r dragon. Ond nid oedd. Ddiw i'r hyn yn ddiogel, Llyfrgell Newburgh wedi'i ddweud y gweithio ydych chi'n ei ddweud o'r Cyfnodd Gweithgaredd yn cael ei ddweud o'r 7 o 9 o'r tribynol. Mae yna'n gweithio i chi'n ddechrau, ond rydyn ni'n ddweud. Mae'r Gweithgaredd yn cael ei ddweud o'r Cyfnodd Gweithgaredd, oedd ydych chi'n gilydd y traps oed i gydig i'r ysgrifennu, ac rwy'n cael ei peth o'ch ten i ddaw ar y dweud o'r rhaid i'r ddweud o gydig i ddweud o'r ddweud. Rwy'n cael, Lord Grafynor yn naherwydd yn fawr i'r ddweud, ond mae'n traps oed i ddweud. Rwy'n cael, Lord Grafynor, yn ystafell o'r barh raisedeiaid, yn ffwrdd, iddynt y rhaid i'r barh raisedeiaid. Mae wedi eu parhau o'r byd o'r gwahodd cyflogol. Mae'r bod yn ymwybodol sydd wedi cyd-i'r pwblig yn cyd-lifio'r Lord Grabiner a Lord Sumpfyn, Fe, yn Llyfrgell Cyswyddorol, wedi cael ei wneud ar gyfer y top 2 silch yn cyflawn. Mae'r cyd-lifio'r Lord Grabiner i'r prifysgol yn cyd-lifio'r Llyfrgell ac yn cyd-lifio'r Llyfrgell i'r prifysgol. Mae'n rhaid i'r tyfu, gallwch yn cyd-lifio'n cyflawni. Wel Grabner is head of one Essex court chambers, Master of Clare College and before that he was chair of the Governers at the LSE, which is my old home. He sits in the Lords, obviously. He serves on a good number of external boards and has been treasurer of Lincoln's Inn and he still manages a substantial court and arbitration and advisory practice, so he's a man with energy. A oedd ydych chi'n meddwl i'n meddwl i'r cyfleidwch yn gweithio'n ddiddordeb cyfwyr ac yn ymwetd yn Llywodraeth. Roedd y dyma yn y cyflwydoedd yn cyflwydoedd, felly mae'n meddwl i'w cyflwydoedd, ar y llyffydd o gweithio'n bwyd, ac yn y meddwl i'n meddwl i'r cyflwydoedd, ac mae'n meddwl i'n meddwl i'r cyflwydoedd. All y bydd yn ym mhlu, fel y bydd yn ymhlu, gyda y First Class hon sukwyddiad a LLM o'r ddysgu'r LSE. Bydd hynny'n ddysgu hynny'n eu morol. Mae'r gweithio'r gweithio'n gweithio. Felly mae'r gweithio'n golygu i'r spore mimicnol a'r bydd yn ymlaenol o ddim yn ddweud. Mae'r amser yn uch ymddangos i'r gweithi arall. Felly, dwi'n meddwl i'n ddweud, rydyn ni'n ffwrdd mae'n gwneud. Grefanna wedi bod yn dweud ffynu sydd wedi gweithio cyfellol ac yn ymdweud cyflawn. Yn gyfaint gweithio. Gweithio'r iawn, Serah. Mae'r bod yn fwyaf i fi, ac mae'n gweithio'n fwyaf i'ch gwaith gwasanaeth o'r bwysig. Mae'r bwysig i'ch gweithio'r gwaith, ond yn y nghymhwyl. Mae'r bwysig i'ch gweithio'r gwaith gweithio'n gweithio'r gwaith. ..y'r ffordd yn ymwyaf. So, ddodd yn ddweud. Felly, Sarah yn gallu amdano'n ei wneud... ..y'r lechau, rydyn ni'n gwneud yw y ddyn nhw i'r 1970... ..y'r llwyddoedd ychydig i'r llwyddoedd yma... ..y'r 7 ydych chi'n llwyddoedd yma... ..y'r llwyddoedd Sutton a'r Shannon... ..y'r llwyddoedd. Mae'r llwyddoedd yma sy'n llwyddoedd... ..y'r llwyddoedd yma sy'n llwyddoedd... ..y'r llwyddoedd yma sy'n llwyddoedd... ..y'r llwyddoedd yma i am 8 ydych chi. Fy nid oed yn iawn y bwrdd... ..y'n gweld y cwpio ddeiligol yn ychydigol yr effeith... ..y'r llwyddoedd yr ymwyaf.. ..y'r llwyddoedd, ydiol y deiligol... ..y gallwn yn ymddangoson yn y fawr... ..y'r llwyddoedd sy'n dda'r llwyddoedd... ..y'r llwyddoedd yn di'r cael iawn... ..y'r llwyddoedd, yw'r llwyddoedd... ..y'r llwyddoedd yma, ychydig... a was as untidy then as it still is some 45 years later. The same point is made by the Chancellor, Sir Terence Etherton, in a case called Sharmar, which is the most recent decision of the Court of Appeal, decided just a couple of weeks ago. The reason why the law was well summarised in that chapter was that a certain Mr AGP Hughes, Now Lord Hughes was a key member of our research team. The probability is that he actually wrote the chapter. Now when Sarah and I spoke, I also knew that there had recently been a spate of cases at Court of Appeal and Supreme Court level. But apart from Tinsley and Milligan, I hadn't followed the debate in detail. It's true that through the recent judgments a number of important differences between distinguished jurists have emerged. But the quality of the debate and the modern willingness of our leading judges to debate and our leading judges to identify and give expression to what used often to be the unstated major premise of a piece of legal reasoning is a welcome development. I have five headline points and one digression. First, I will deal with the principle emerging differences. The detail was painstakingly summarised and explained by Lord Newburger in his judgment in Getivia and Biltah. Secondly, I think the time has come to resist further incantation of Lord Mansfield's statement of principle in Holman and Johnson. Without disrespect to that great man, that passage raises more questions than it answers. It would be better to ask ourselves what purpose the law in this area should be concerned to achieve and to take full account of the observations of Lord Justice Bingham in his judgment in Sanders and Edwards. I'll be forgiven, I hope, if I just quote a passage from that great judge. Where issues of illegality are raised, the courts have to steer a middle course between two unacceptable positions. On the one hand it is unacceptable that any court of law should aid or lend its authority to a party seeking to pursue or enforce an object or agreement which the law prohibits. On the other hand, it is unacceptable that the court should, on the first indication of unlawfulness, affecting any aspect of a transaction draw up its skirts and refuse all assistance to the plaintiff, no matter how serious his loss nor how disproportionate his loss to the unlawfulness of his conduct. The Supreme Court is uniquely positioned to adopt those wise words, and I will come back to this point. The third headline point is this. We should recognise that Tinsley and Milligan is an unsatisfactory decision. Not in the result, but in the reasoning of the majority. In that case, two single women jointly owned a business running lodging houses. With funds generated by the business, they bought a house and lived in it together. The title to the house was by agreement between them. Vested solely in the name of Ms Tinsley on the understanding that they were the joint beneficial owners of the house. The purpose of the arrangement was to assist in the perpetuation of frauds on the DSS because Ms Milligan, with the connivance of Ms Tinsley, made false benefit claims on the dishonest basis that she paid rent and was not a house owner. The judges regarded Ms Milligan's behaviour as unattractive, but in Lord Goff's words it was of a relatively minor nature. This was no doubt because he was impressed with the fact that she had come clean with the DSS and repaid the money improperly obtained. Ms Milligan succeeded on a technicality. She was able to assert an equitable proprietary interest in the house without the need to rely on the dishonest purpose of the agreement. Now this decision is binding and the Supreme Court should in the next appropriate case be invited to depart from it. We need an illegality rule which is principled so that the result won't turn on the availability or otherwise of a presumption derived from equity. And in this context it's worth comparing Tinsley with the case of Collier. In Collier, in order to defraud his creditors when he thought he was in financial difficulties, the father granted leases of two premises to his daughter. As well as options to acquire the freeholds. In the event the anticipated financial problem evaporated, but the father and daughter fell out. The father sued. It was held there was no withdrawal on his part before the illegal purpose had been performed. Indeed the father had directed his daughter to exercise the options and to take a transfer of the freehold interests. Also there was no resulting trust presumption in favour of the father and his claim accordingly failed. The fourth headline point is this. The endeavor to achieve certainty is a noble one. Especially if it has the effect of producing clarity for the parties at the stage of drafting the contract. But even then it may only have a holy grail quality. Because for example the interpretation in due course adopted by the court may focus on the supposed commercial purpose of the bargain rather than the words used by the parties in their contract. Recent cases including Rainy Sky and Cookmin Bank and Arnold and Britain are a welcome development on that front. In this area of the law certainty is less of a concern. Because when deciding whether or not to make an illegal bargain it is unlikely that the enforceability of the transaction would have figured in the minds of the negotiators. Fifthly and this is really a constitutional point. It is wrong in principle for the courts below the Supreme Court in effect to legislate recommendations of the law commission and to do so in the face of binding decisions of the highest court. That can and should only be done by the Supreme Court or by parliament. This is an unfortunate aspect of the story and I think is at the heart of some of the differences between the judges in the recent cases. Between 1999 and 2010 the law commission recommended legislative reform to give the courts a statutory discretion in relation to the illegality defence. But it eventually concluded in CP 189 and report 320 that the matter should be left to be developed by the common law and I quote the commission in the way we hoped. Close quote. By this expression the commission meant that the defence should be applied flexibly and only allowed where and again I quote. Its application can be firmly justified by the policies that underlie its existence end quote and that the court should consider on the facts of the individual case whether the application of the illegality defence could be so justified. According to the law commission the quotes so called rules end quote developed in the cases were only guidance and the courts and I quote. Bent sorry which the courts bent. It's quite a serious allegation but no doubt absolutely well founded in truth. It said that case law should only be followed sometimes where it and I quote helps end quote. Now for those of us who were raised on Professor Rupert Cross's magnum opus precedent in English law. These views of the law commission reveal a novel approach to starry decisis. In support of its views the law commission relied in particular on some obiter remarks of Lord Hoffman in Grey and Thames trains and Lord Phillips in Stone and Rolls and Moore Stevens. Since then the courts have given conflicting judgments. The Court of Appeal in Parking Eye, Appatex and Patel explicitly and the Supreme Court in Haunga implicitly adopted the law commission approach. That approach was in turn firmly rejected by the Supreme Court in Appatex by Lord Sumption with whom Lords Newburger, Mans and Clark agreed. But with all Tawson in the minority essentially disagreeing with his Supreme Court colleagues. Now by comparison with the trenchant dissenting observations of Justice Scalia in the recent US Supreme Court decision in a case called Obergefell against various state governors. Our own justices are remarkably polite and mild mannered towards each other. The issue in Obergefell was which of the federal court or the state legislature was authorised to decide whether the 14th amendment contained a fundamental right to permit same sex marriage. Amongst the gems were describing the, this is Scalia, Justice Scalia describing the majority opinion as quote, lacking even a thin veneer of law end quote, saying that quote, buried beneath the mummaries and straining to be memorable passages of the opinion is a candid and startling assertion end quote and a footnote no less that quote. The Supreme Court of the United States has descended from the disciplined legal reasoning of John Marshall and Joseph Story to the mystical aphorisms of the fortune cookie end quote. To add insult to injury Justice Scalia drew attention to the fact that the majority opinions had discovered in the 14th amendment a fundamental right which had been quote, overlooked by every person alive at the time of ratification and almost everyone else in the time since. He names all what he calls the lesser legal minds who also miss the point listen to the list. Thomas Cooley, John Marshall Harlem, Oliver Wendell Holmes, learn it hand, Louis Brandeis, William Howard Taft, Benjamin Cardozo, Hugo Black, Felix Frankfurter, Robert Jackson, last but not least, Henry friendly. I could not resist that digression. I will say something about some of the recent cases, but my thesis is that they can be reconciled when divided into two broad categories. First those in which the claimants cause of action is founded on illegality by which I mean where he has to rely on or would benefit from an illegal or immoral act. In such cases the general principle preventing recovery based on Holman and Tinsley still applies. The law commission's recommendations are inconsistent with this proposition. Secondly cases such as parking I and honga where the claim is not founded on an illegal or immoral act but may still be so closely connected with illegality as to be tainted by it. In such cases the law is more flexible and the approach of the law commission is broadly consistent with it. As to the first proposition the reliance rule is rigorously applied but there may be some flexibility where the illegality is trivial. For example if the claimant was unaware of some statutory rule or was ignorant of the facts constituting the breach. The extent of this exception is uncertain. In tort cases the rule will apply where the claimant seeks recovery for loss caused by his own illegal act. Grey and Thames trains is such a case. Having pleaded guilty to a charge of manslaughter the ex-Turpee Khauzar principle prevented Mr Grey from recovering damages for loss of liberty, loss of earnings, damage to his reputation and feelings of remorse and guilt. He was also barred from claiming an indemnity against any claim brought by the dependence of his victim, notwithstanding that his mental state was allegedly caused by Thames negligence in connection with the labric grove train crash. This is because it would have been inconsistent for the civil court to compensate him for the consequences of the sentence imposed upon him by the criminal court. There's also a line of cases which shows that the court will take note of the illegality and bar the claim even though the illegality is not relied on. Beresford and Royal Insurance is famous, the insurance claim in respect of a suicide when suicide was a crime, Alexander and Rason where the contract was intended to be performed illegally either at the outset or subsequently. Cases where the claim is inextricably linked with criminal conduct, for example the claim by a bank robber against the driver of the getaway car for negligent driving. If you saw it in a sitcom you wouldn't believe it. It is exceedingly rare for the court to sustain the illegality defence in a talk case. Cross and Kirby is a homely example where a hunt protester attacked a participant with a baseball bat. The participant rested the bat from the protester and delivered his own blow in response. The protester's claim for assault was held to be so closely connected with or inextricably bound up with his own criminal behaviour that the court could not permit him to recover without appearing to condone that conduct. Perhaps it is no great surprise that the court of appeal should have upheld the God given right of a man on a horse to beat a protester with impunity. The rarity of a successful plea of illegality in a talk case is consistent with the willingness of the court to permit a restitutionary remedy. The talk claim is essentially a restitutionary remedy. I want now to say something about the recent cases. Apotex concerned a claim for damages on a cross undertaking following the discharge of an interim injunction restraining infringement of the claimant's patent. The damages were in respect of a product which, but for the injunction, would have been manufactured in Canada and that's an important point. This would have been a strict liability statutory wrong in Canada because it would have breached a Canadian patent owned by a member of the claimant's group of companies. The court of appeal held the breach would have been an illegal act but Apotex was nevertheless entitled to recover damages based on Canadian manufacture. Lord Justice's Kitchen and Laws agreed with Lord Justice Etherton that the court should adopt the law commission approach and would permit the illegality defence only when it was just and proportionate in the light of various policy considerations. The court decided the illegality principle was engaged but allowed the appeal relying on a variety of factors including the following. Apotex believed the Canadian patent was invalid, the illegality was in the words of Lord Justice Etherton low on the scale of culpability, the sale in the UK would not have been unlawful, the Canadian court had declined to grant an interlocutory injunction restraining local manufacture and Apotex conceded it would give credit for the amount of the manufacturing profit for which it would have been liable in Canadian law. The decision of the court of appeal in Apotex ignores previous binding authority. It treats the law commission proposals as the law and it is inconsistent with Hewison against meridian shipping because the claim was in respect of profits which could only have been earned by what the court of appeal decided would have been an illegal act. In Hewison the appellant claimed loss of earnings calculated on the basis that but for the accident he would have continued to work as a semen crane operator until normal retirement age. The respondents case was that it would be contrary to public policy to award damages on that basis because an essential part of the claim would have involved the claimant continuing to deceive his employers by fraudulently representing that he was not suffering from epilepsy as he had done in the past so the premise of his claim was that he would repeat that fraudulent statement and on that footing claim to be entitled a compensation. Furthermore although the judgement of the court of appeal in Apotex refers to the rejection of the public conscience test and adopts instead a just and a proportionate response in the light of the policy considerations it is difficult to see how if at all the two tests differ in practice. In Parking Eye the lead judgement was given by Sir Robin Jacob with whom Lords Justices Tulson and Laws agreed. Sir Robin took the Law Commission recommendations as his starting point and adopted its view that minor and incidental transgressions even if intended at the outset should not render the contract unenforceable. On the facts he held that Parking Eye did not need to rely on any illegality. The illegality performance was neither an object of the contract nor was it necessary for its performance. It was only minor and would have been corrected if the illegality had been pointed out. Law Justice Tulson's judgement supports the Law Commission test as being broadly consistent with the body of previous unclear authority but the notion that the proportionality test is a different thing from the public conscience test is I think doubtful. It is difficult to imagine anything that would be relevant to the former which would not also come into an assessment of the dictates of the public conscience. I suppose it can be said that the modern terminology has the worthwhile merit of being less pompous. The result reached by the Court of Appeal in Apatex was affirmed by the Supreme Court on the different ground that the illegality rule was not engaged by the infringement of the patent under Canadian law. Civil wrongs unless they involve dishonesty or corruption do not amount to turpitude because they are not contrary to the public law of the state and do not engage the public interest. The majority of the Supreme Court disapproved the Law Commission approach and Law Justice Ethiton's reasoning as being inconsistent with Tinsley. Lord Sumtsham, with whom Lord Newburger, Lord Manson, Lord Clark agreed, was particularly troubled by the Court of Appeals what he calls largely subjective judgement about how badly Apatex had behaved and how much it mattered. When what was in fact required, as he puts it, was, the application of general rules of law and not fact based evaluations of the effect of applying them in each individual case. For Lord Sumtsham, the key question is whether there is turpitude and if so how close is its relationship to the claim. But what is turpitude? Lord Mansfield did not elucidate. Lord Sumtsham in Apatex said it covers criminal and what he calls quasi-criminal acts, which he says engage the public interest in the same way. He cites the example of infringements of competition law and notes the anomalous categories of misconduct such as prostitution. At the same time he says, a run-of-the-mill breach of statutory duty will not amount to turpitude. Does Lord Sumtsham's rule of law then change according to the morals and values of the time? After all, Amnesty International is now campaigning to legalise all consensual sexual activity including prostitution. We have seen enormous changes in attitudes to such matters in my lifetime short as it has been. Prior to 1967 consensual homosexual activity even in private was criminal. Now we have gay marriage. Such questions, even over what is turpitude, allow for wriggle room for the advocates and the judge to find the right answer dressed up as principal. Lord Sumtsham also refers to what he calls a recognised exception to the category of turpitudinous acts for cases of strict liability, generally arising under statute where the claimant was not privy to the facts making his act unlawful. One wonders on what basis this is a recognised exception. The obvious answer is that no judge would want to punish such an innocent party by enforcing the illegality rule. The danger with this sort of analysis is that although dressed up as principal it is in reality simply an example of the court acting to get the right answer. That is not very far from the discretionary approach of the Court of Appeal in Apotex which attracted the opprobrium of the Supreme Court. The next case, Ho'unga, is problematic and has given rise to a good deal of debate in the profession as well as in law faculties everywhere. The facts were simple. The claimant Nigerian was employed as a family help under an employment contract which was unlawful from inception. She had obtained entry into the UK by stating fraudulently that she was a relative of the family. Both parties knew throughout that it was illegal for her to work here and she was a willing participant in the illegality. The employment tribunal rejected her claims for unpaid salary, damages for unfair dismissal and for the statutory tort of dismissal on racially discriminatory grounds because they were all inextricably bound up with her illegal conduct which could not be condoned. The employment appeal tribunal allowed her appeal in relation to the statutory tort on the ground that her illegal employment was not inextricably linked with the physical abuse and forcible eviction to which she had been subjected. The defendant successfully appealed to the Court of Appeal. Lord Justice Reimer said this. In making good her dismissal, discrimination case, she was directly invoking and relying upon the fact that she was here illegally and had been working illegally for the Allans. She was making a direct link between the discriminatory treatment of which she complained and the circumstances in which she came to be and was employed by the Allans. The Supreme Court reversed the Court of Appeal. It made no express reference to the law commission's reports but applied its approach. Lord Wilson with whom Baroness Hale and Lord Carr agreed concluded on the basis of a dictum of Lord Phillips in stone and rolls that the tinsley reliance test could not automatically be applied and thought it appropriate quotes to soften the effect of the reliance test by the need to consider the underlying policy. On the inextricable link test Lord Wilson said this. I would hold the link to be absent. Entry into the illegal contract on 28 January 2007 and its continued operation until 17 July 2008 provided no more than the context in which Mrs Allen then perpetuated the acts of physical, verbal and emotional abuse by which among other things she dismissed her anger from her employment. Although he went on to say the bigger question was whether the inextricable link test was applicable, Lord Wilson did not explicitly answer that question and focused instead on the public policy foundation of the illegality defence. He referred to the well-known dictum of Justice McLaughlin in Haaland Hebert and said that awarding compensation for injured feelings to Ms Hounga did not allow her to profit from her wrongful conduct in entering the contract or to evade a criminal penalty, nor did it encourage others to enter similar illegal contracts. Conversely, to allow the illegality defence would encourage other disreputable employers to discriminate with impunity against their employees. These public policy considerations led Lord Wilson to conclude that there scarcely existed any justification for applying the illegality defence. In essence, this was an example of the approach favoured by the Law Commission. It is, I think, noteworthy, however, that in his enumeration of the policy considerations, Lord Wilson omitted the most obviously applicable one, namely consistency in the law. How could the law prohibit the employment yet reward Ms Hounga with damages for its discriminatory termination? Lord Hughes with Lord Carmouth agreed with Lord Wilson that there was not a sufficiently close connection between the illegality and the statutory tort. This was in contrast with the claims for breach of contract when the contract was prohibited and illegal. The employment merely provided the setting or context for the commission of the tort and to allow recovery for that tort would not amount to the court's condoning what it otherwise condemns. I think the Court of Appeal was right to say that all Ms Hounga's claims, including the one on which ultimately she succeeded, were obviously inextricably bound up with the illegal employment. It is difficult to see on what basis the unfair dismissal was, but the racially discriminatory dismissal was not caused by it. This looks like an example of Lord Sumpson's interesting observation in apotex to the effect that the disordered state of the law is due to the distaste of a court for the consequences of applying their own rules. The law commission would say this is an example of the law being bent in order to achieve a palatable result. Ms Hounga was relying for all her claims on her own unlawful employment. In the later case of Bilter, there is a valiant attempt by Lord Sumpson to support Hounga. At paragraph 102 he says, Ms Hounga did not rely and did not need to rely on the circumstances in which she had entered into the United Kingdom. I don't with respect think that quite hits the point. The circumstances of Ms Hounga's entry into the United Kingdom may have been background, but the illegal contract clearly was not. It was central to any unfair or racially discriminatory dismissal claim. In my view, the real question in Hounga should have been whether on the true construction of the provision which created the statutory tort, the Race Relations Act 1976, section 4-2, it applied to unlawful contracts of employment. That seems to me to be the key question. That question was never addressed either by the Court of Appeal or by the Supreme Court. The section deals with employment discrimination and access to opportunities for promotion and training, as well as dismissal and other forms of detriment. The decision in Hounga implies that a person knowingly in illegal employment can nevertheless make claims across the whole range. For example, but for his race, the terms of the illegal employment would have been improved. That gives you a statutory cause of action. Or he would have been promoted a separate cause of action under the same statutory provision to more senior illegal employment. That cannot with respect be right. Hounga may be a classic example of a hard case making bad law. Now, it certainly does not follow that the decision in Hounga is in conflict with Tinsley. There are different cases. Tinsley decides that the illegality defence depends on a rule of law. It doesn't turn on the supposed equities and it certainly isn't a discretionary power exercisable on the basis of a judicial value judgment or balancing exercise. Cases such as Parking Eye and Hounga are different because the claimant is not obliged to rely on his own illegality and Tinsley is not applicable. In apotex, the claimant relied on the alleged illegality and the Tinsley principle was engaged. In Hounga, the Supreme Court decided the illegality was merely background or context, so the Tinsley principle was not engaged. In Hounga, there was also a competing public policy. For this reason, the singular expression, the illegality defence is misleading and should be avoided. Hounga was followed in best against the chief lamb registrar. There, a squatter was held to be entitled to claim title to a residential property in reliance upon his adverse possession, notwithstanding that his occupation amounted to a criminal offence under the legal aid sentencing of Parliament Act 2012, section 144. The Court of Appeal concluded that in enacting section 144 Parliament did not intend to produce any collateral effect upon the settled law of adverse possession in respect of registered or unregistered land. The next case is Patel, where contrary to the Criminal Justice Act 1993, and I think this is a case which has either been argued or is about to be argued in the Supreme Court, contrary to the Criminal Justice Act 1993, section 52, the claimant paid £620,000 to the defendant under an illegal contract to bet on the movement of shares in Royal Bank of Scotland using inside information. In the event the illicit information was never forthcoming, the contract was frustrated but the defendant refused to repay the money. The Court of Appeal unanimously held in favour of the claimant because the contract was wholly unperformed. The reason why the claimant had withdrawn was held to be irrelevant and it was unnecessary for the claimant to have to show that this had been done voluntarily or that there had been on his part some hand-ringing expression of repentance. This aspect of the decision confirmed the point made some years earlier by Law Justice Millet in tribe and tribe and has sensibly clarified a previously unresolved chestnut. The combined effect of Law Justice Millet in tribe and the decision in Patel means that Bygos and Basted is no longer good law. The Court was, however, divided on the distinct question whether if the judge's decision that the claimant could not withdraw in the events which had happened had been correct, the claim would have been barred because of the need to rely on the illegality. Law Justice's Rhymer and Voss held that it would have been barred because the claimant had relied on the agreement and its frustration in all its gory detail in the pleadings. The point was trenchantly summarised by Law Justice Rhymer. He said the claimant could not have pleaded a case which carefully kept the illegal cat secure in the bank. I'm not sure about the concept of an illegal cat but no matter. Lady Justice Gloucester, the third judge, took the view that it did not matter what had been pleaded. She based herself on Tinsley, Lord Brown Wilkinson, a passage of Lord Brown Wilkinson in that case. She said the test was whether reliance on the illegality of necessity formed part of the claimant's case. In Patel it did not. The claimant merely had to show that he had paid over the money for the purpose of speculating in shares in Royal Bank of Scotland and that this purpose had never been carried out. Lady Justice Gloucester also drew attention to Section 63-2 of the 93 Act to the effect that individual bargains should not be unenforceable from which she inferred that public policy did not require the claim to be infected by the illegality. Now there are two I think meritorious features of the approach adopted by Lady Justice Gloucester which I should highlight. First she applied the necessity test which was authoritatively established in Tinsley. Secondly the answer to this sort of question should not turn on arcane case law about pleadings. This is a public policy issue which should be decided on the actual facts and the applicable principles of law. That analysis does not however sit happily with the fact that the illegality may be raised by the court. For example in a case where it has never been pleaded. In Cross and Kirby you'll remember the Hunt protester case. Lord Justice Beldam said this. I do not believe that there is any general principle that the claimant must either plead, give evidence of or rely on his own illegality for the principle to apply. Such a technical approach is entirely absent from Lord Mansfield's exposition of the principle. And I agree respectfully with Professor Graham Virgo on this point. The current law on the reliance point needs to be clarified. The correct answer should not depend on artifice or formalism. That is the subtleties of the way the case is or might be pleaded. And then I think I should try to summarise where I think we are. If we step back from the respective positions thus far adopted by different judges and ask ourselves the question what has been happening in these cases. The answer is that broadly speaking the courts have reached the right answers. In all these cases they have come to a view on the merits and engineered the appropriate result. Sometimes that has been done in the forthright way adopted by the law commission. The reasoning in such cases has the merit of openness and more transparency than we have ever had before. Hounga is an example. In other cases the courts have adopted a principled rule which has sufficient flexibility to enable it to accommodate the judicial instinct for fairness and justice. With this approach it has and should be possible for the court to decide whether the illegality and the claim are or as the case may be are not inextricably linked so there is a built in safety valve. Ordinarily my personal preference would be in favour of a rigorous and principled rule but for three reasons in this particular context I would not feel so constrained. First our judges are rather good at spotting where the true merits lie and that enables them to get to what I would call the right answer. Secondly as previously mentioned certainty in the law is desirable whether you are advising a client when entering a contract or advising him about his prospects of success when a transaction has broken down. In this context that point does not arise. The parties to an illegal bargain can hardly complain if the court decides for itself what the result should be. In any event it will be an unusual case where there is not one party with clearly more merits than the other. Thirdly litigation lawyers have always cautioned clients rightly in my view that the merits of the case are vitally important in front of most not all judges. Contrary to popular belief judges are human beings. In my experience the merits of a case might even extend to the unsavory appearance of a client and I cannot resist a further short digression. As I have a vivid memory as a pupil attending an application for leave to appeal to the House of Lords. The judicial committee was chaired by Lord Diplock and I think Lord Rosgill was also present a formidable court. Our client apart from being a crook also looked the part. Sam Stamler was my pupil master and he had tried valiantly to dissuade the client from attending in person but he had insisted upon appearing. Stamler was on his feet for no more than a couple of minutes and was told to sit down. His opponent was then given a ten minute blasting and leave was given without the need for the customary withdrawal of counsel. As we walk back to the robing room along the red carpet on the committee floor our opponent congratulated Sam on his extraordinary success. He said he had advised his client that he would not be called on still less that leave to appeal would be granted. He said this was particularly impressive because Sam's physically unattractive client was in court. He said Stamler that's why I told him to sit behind you on your side of the court. True story. History does not relate what happened on the substantive appeal but it doesn't really matter. The other aspect of illegality I want briefly to deal with this evening is the restitution point that is recovery of property transferred under an illegal contract. A variety of policy arguments have been deployed as supposed justifications for denying the remedy of restitution where the claimant has been tainted with illegality. In summary they are consistency that is between the criminal law and private law, sea lord Hughes in Honga that is of course a powerful argument. The other points are less impressive for reasons which I won't address in this lecture. They are deterrents, punishment and the dignity of the court. The arguments are well set out by Professor Virgo in his article the defence of illegality in unjust enrichment. There may be circumstances where one or other of these points will on the facts of the particular case have great sway. Leaving that aside summarising the position shortly the current state of the law appears to be as follows. The first point is that property so transferred is recoverable if for whatever reason the contract is wholly unperformed. Secondly it is established that for this purpose property includes tangible assets, bow makers case, machine tools in that case, real estate as in tinsley and subject to the decision of the Supreme Court in Patel the right to be repaid money. Thirdly property may also be recovered even if the agreement is no longer executory provided the claimant can establish ownership without having to rely on the illegal agreement, sea tinsley and collier, the contrasting presumption cases we looked at earlier on. As I've already suggested the reasoning in these two cases is unsatisfactory and arbitrary. In Patel the claim for return of the 620,000 was not an attempt to get a profit. Still less was it to secure a benefit for Mr Patel from the illegality. Mr Patel wanted his money back. This case strikingly illustrates the subtle way in which there has been a shift in public policy. Lord Mansfield would not have permitted the court process to be used to assist Mr Patel. But provided he is not being rewarded for his improper behaviour, the courts today are, or maybe more sympathetic to the claimant, even if his hands are a little bit grubby. I think this is the point which was anticipated nearly 30 years ago by Lord Justice Bingham. You will recall that learned judges excellent image in his judgment in Saunders and Edwards of the court drawing up its skirts. If in a case like Patel the claimant is barred from recovery it would follow that the defendant would retain a win for and profit from the illegality. This was an acceptable outcome to Lord Mansfield but I think it should not be permitted today. The defendant should not be permitted to retain the claimant's property. Finally, and I know that word always brings relief to the audience, my understanding is that on the restitution point French law is ahead of the game. In France recovery of property is permitted so as to restore the parties to their original positions. The illegal transaction is reversed and is of no effect. On this isolated and resherche point I think we would do well just for once unashamedly to follow the French.


Ladies, most of you have a highly attuned intuition, and yet many of you, it's like your intuition has rose-colored glasses on it. The foolproof way is to, Hillary asks, question, should it be an automatic next if a guy writes on his profile, let's be friends first and see where it goes? That seems like a reasonable path, but he's not ready or serious. You know, I think my dating profile intimated. Something similar. Yeah, let's think about this for a moment. What's the benefit of a friend first? Well, friends first means you feel comfortable with one another. Why don't you think about this? Are some of your best friends the people you feel like you can say anything to? Yeah, I think there's value in developing friendship. I think about my relationship with my sweetheart. We had met, it's a long distance, and folks, you know I'm not a big fan of long distance relationships, but I think ours was unique for a variety of different reasons, and you're more than welcome to ask me about that. First off, we met on a dating site. She lived 1,700 miles away, 1,800 miles away, and there wasn't really any plan to meet, but we're like, okay, we connected, and we began to stay connected, okay? And a little here, a little there, we would talk to one another, and we became Facebook friends. So in the course of one year, we had spent some time getting to know each other non-romantically, and then when we finally did meet, it was as friends. Now there was chemistry, and there was something really special that happened on our first meeting, but we didn't meet in a romantic sense. So I wouldn't discount a person that wrote that. What I would discount is if they just want you, and if they only want you as a friend, or worse, they want you as their therapist. You know, a lot of dating today, people will bond via these devices with people. I call them trauma bonding experiences. You're basically a therapist. By the way, ladies, the online dating world is a cheap way to get therapy for men and women these days.  How many, do you need more new friends in your life? Some of you do, but most of us don't need new friends. We don't have enough time for the existing friends and family we have in our life. So if you're going to invest in that, at least I want to invest in someone who I'd like to at least want to take their clothes off, even if it doesn't happen for the first five days. All right, Christy writes, question. It's my experience, most guys will answer questions with lies in order to say what they think you want to hear. Is there a foolproof way to determine if a guy is lying? You know, where's that book I have? Bum-bum. You know, there's a book called The 101 Lies Men Tell and Women Believe Them. You may want to check that. By the way, there's a link to all the books I recommend in the go to my description, click on Jonathan Books recommend. It's by Dory Heiler. Okay, let's open this up and see some of the lies. Here's one of the lies. I'll call you, I love you. You're the only one. I've never felt this way about anyone else. I've got to work late at the office tonight. That's the best I've sex I've ever had. You've got the most beautiful eyes. You know, I'd say, I've said all seven of these in some way, shape or form. Here's the thing, you wet ladies, most of you have a highly attuned intuition. And yet many of you, it's like your intuition has rose-colored glasses on it. The foolproof way is to trust your intuition. Now, the tricky part is sometimes the ego gets in the way of intuition. So it takes time to dismantle the ego and start leaning into your heart. I don't think I have a copy of it, but I highly recommend the book Return to Love by Marianne Williamson. I highly recommend that to read because that will start dismantling the ego and start helping you shift to your heart. I would definitely recommend that. But ultimately your best bet is your intuition. All right, thank you so much, Christy. Hey, okay, I'm ordering the book. I'm glad to hear that, Winter. Thank you so much.