The Simplex Solution Method Essay Example for Free

The Simplex Solution Method Essay The simplex method is a general mathematical solution technique for solving linear programming problems. In the simplex method, the model is put into the form of a table, and then a number of mathematical steps are performed on the table. These mathematical steps in effect replicate the process in graphical analysis of moving from one extreme point on the solution boundary to another. However, unlike the graphical method, in which we could simply search through all the solution points to find the best one, the simplex method moves from one better solution to another until the best one is found, and then it stops. The manual solution of a linear programming model using the simplex method can be a lengthy and tedious process.Years ago, manual application of the simplex method was the only means for solving a linear programming problem. Now computer solution is certainly preferred. However, knowledge of the simplex method can greatly enhance one’s understanding of linear programming. Computer software programs like QM for Windows or Excel spreadsheets provide solutions to linear programming problems, but they do not convey an in-depth understanding of how those solutions are derived. To a certain extent, graphical analysis provides an understanding of the solution process, and knowledge of the simplex method further expands on that understanding. In fact, computer solutions are usually derived using the simplex method. As a result, much of the terminology and notation used in computer software comes from the simplex method. Thus, for those students of management science who desire a more in-depth knowledge of linear programming, it is beneficial to study the simplex solution method as provided here.

Indian dance Essay Example for Free

Indian dance Essay Kathak is the one of eight forms of Indian classical dances perform by men and women, originated from northern indian, known as kathakars or storytellers. The styles of dance have its unique character from the rhythmic footwork with rhythms that he or she stomps out barefoot on the floor, accented with many bells worn around the ankles ( and from seeing the guest artist I can say there were more than 100 bells around her ankles making lots of noise to go with the beats of the drum), spectacular spins, and also every dance piece has a story behind it. A traditional kathak performance features a solo dancer on a stage, surrounded on all sides by the audience. The repertoire includes amad ,the dramatic entrance of the dancer on stage. Male dancers perform in Persian costume of wide skirts and round caps, while female dancers wear a traditional Indian garment called a sari. Back in the day women are the one who preserved this traditional dance more than the men. Kathak are typically performs by one dancer surrounded by a group of musicians. The solo dancer performs the parts of all the characters in the story. For example the guest artist were going back and forth rapidly from one of her dance piece between two characters. She did it without changing her positions on stage, changes in gestures and facial expressions signal instantly which character they take on at that moment. Before the guest artist started her dance so did a pronom giving thanks to all five elements or also known as the god, space, wind, fire, water and earth. Dance is on the earth, the eyes wherever the eyes are the mind, where the mind there are feelings. The way Antara gave thank to the god were a little different from what we normally did in class, with more steps and she also added some singing and harmony into the rituals. Based on what Antara told us, kathak is a very intimate dance where it is a three ways conversation, between dancers with musicians and dancers with the audience. The tempo for kathak consist of 16 beats. Dancers sometime precise the beats while dancing. With kathak you can play with the rhythms, there is no set rhythms. Kathak consisted of a lot of feet movement and with that the bells around Antara added a more prominent movements. Even though the focused on her foot because of all the bells, we can still see that shes using her upper body. The arms movement were very smooth and elegant, her eyes moved according to her hands gestures. Antara played the Theka which looked and sound like the accordion, along with singing and dancing. The Theka did not stop Antara from doing her incredible spins and keeping the tempo while doing all these things at once. Stomping her foot very fast and loud on the floor seems to be away for her to keep her tempo. Even when she was stomping her foot her hands and head was still doing a lot of movement to help tell the story. During her performance she uses a lot of phrases in Indian and it was hard for me to understand or catch what she was saying. But she later on explained that it is just like how we counts beats in america instead of using numbers, in Indian dance they used the language of the drums. Her right foot always ended in the front to help her keep up with the beat and also so that her body can face the audience and interacted with them. Her dance move was not all fast but it was very precise and very professional. Antara dances very elegant and somehow I can see her personality throw the way she moved the way she carry herself on all the dance pieces. She is a great dancer and a great guest artist for the style, she makes me want to learn more about the style and actually go see her performance in San Francisco.

Education Is Considered As An Investment Economics Essay

Education Is Considered As An Investment Economics Essay Education is considered as an investment in human capital. Human capital can be described as the knowledge, abilities and skills of an individual, acquired through education, training and experience, which help the latter to be more productive and thus improve his potential income earning. Ismael (1998), Becker (1964) and Mincer (1974) have emphasized on the fact that, by investing in human beings, we will gain from some forms of benefits in the future. However, Blankneau and Simpson (2004) find no clear evidence on the link between government spending on education and economic growth. Human capital is one of the most important components of sustainable economic development of a country as illustrated by Lucas (1988) and Romer (1990) in their new growth literature. The expanded neoclassical growth model developed by Mankiw, Romer and Weil (MRW) (1992) and the endogenous growth models developed by Lucas (1988), Romer (1990), Barro (1990) and others have only recently stressed on the importance of human capital in growth theories. Even though human capital incorporates health, experience, skills, education and other social factors, in this paper we will concentrate only on the role of education and its effects on the economic development of Mauritius. One problem that arises is when dealing with the measurement of human capital. In fact, there is no agreed definition of which proxy should be used to represent human capital. Generally, the average number of years of schooling has long been seen as a convenient proxy. For example, Mankiw et al. (1992) use secondary enr ollment as proxy for education and Barro (1998) uses enrollment in different levels of education, i.e. primary, secondary and tertiary, and also enrollment by gender as proxies. In our study we will be using the average number of years of different schooling levels as proxies for education. Petrakis and Stamatakis (2002) have stressed on the fact that each different level of education has different impact on growth. For example, they find that the effect of primary and secondary education on the economic growth of developing countries is more significant than that of tertiary education, and for developed countries it is the opposite that takes place. Since it improves human capital, we could say that education does affect economic growth predominantly, but actually, the impact of education on the economic development is quite ambiguous. There were countless debates over the years by researchers over whether education has a positive, negative or no relationship at all with the economic growth of a country. Barro (1991) finds that education has a positive and significant impact on economic growth. He observes that any rise in enrollment rate, raises GDP too. De Meulmester and Rochet (1995) provide evidence that this relationship may not always be true. Devarajan et al. (1996) find that education has a negative impact on economic growth for some developing countries. They deduce that developing countries are not productive at the margin because these countries do not fairly allocate their public capital expenditure and this explains the opposing relationship between education and economic growth. The purpose of this paper is to dete rmine the impact of education on the economic growth of Mauritius. Empirical Evidence Barro (1991) finds that education and economic growth are highly correlated. He uses enrollment rate as a proxy for education and per capita GDP as a proxy for economic growth. Data are collected across more than 100 countries during the years 1960 to 1990 and Barro finds that each additional year of enrollment increases per capita GDP. Bils and Klenow (2000) also come across similar results in their research. They find that variation in schooling explains approximately one third of the variation in economic growth. Although Bils and Klenow (2000) provide evidence of the positive relationship between education and economic development, they also claim that more growth would result in more education and not the opposite, i.e. a reverse causation effect. Akcabelen (2009) uses the ARDL approach to determine the short-run and long-run effects of different levels of education on Turkeys economic development. Secondary enrollment and tertiary enrollment are used as different proxies for education and this enables us to examine the impact of each level of education on the economic growth. Akcabelen concludes that there is positive correlation between all levels of education and the long-run economic development of Turkey. Loening (2002) uses time-series data from 1951 to 2000 and applies the error-correction methodology to analyze the impact of education on the economic growth of Guatemala. He observes that output per worker increases by 0.16 percent following a 1 percent rise in the average years of schooling. So he agrees on the fact that education does have a positive impact on the overall economic development of the country. Afzal et al. (2010) use time series data from 1970-2009 to analyze the relationship between education, physical capital, inflation, poverty and economic growth in Pakistan. According to their findings, education and physical capital have both a positive and considerable effect on economic growth in the short-run as well as in the long-run. They also find that inflation slows down economic growth in the long-run and poverty has no effect at all on the economic development of Pakistan. Other researchers, such as Kakar et al. (2011), have used time series data for the time span 1980-2009 and apply the Error Correction Model (ECM) and come to the conclusion that education influences Pakistans economic development only in the long-run. They also observe that the quality of education is more important than the quantity of education in achieving economic growth, so the government should increase its investment in education with the aim of enhancing the quality of education further. Since Mauritius is part of Africa, it is also good to see the results of researches conducted in other African countries. Fonkeng and Ntembe (2009) use enrollment and GDP as proxies for education and economic development and they notice that education at higher level, i.e. at tertiary level, is positively correlated with economic growth of Cameroon. Musila and Belassi (2004) use government expenditure on education as proxy for education for the years 1965 to 1999. They apply the cointegration and the ECM methods and find that there is positive correlation between average workers expenditure on education and the economic growth of Uganda. Ndiyo (2007) uses time series data from 1970 to 2000 on real education expenditure, real capital formation and GDP, and employs the VAR technique. Based on the results obtained after computations, Ndiyo (2007) demonstrates that education does not have a positive effect on the economic development of Nigeria. He suggests that this result can be explai ned by various factors such as labor market distortions, redundancy, brain drain, industrial disputes and job discontinuities, and government failure etc. Khorasgani (2008) analyses the impact of higher education on Irans economic development for the period 1959 to 2005. The proxies used for human capital are education attainment and research expenditures. Khorasgani (2008) also uses Cobb-Douglas production function together with the ARDL method to determine the short-run and long-run effects of higher education on the economic growth. The study demonstrates that real output increases by 0.314 percent in the long run and 0.198 percent in the short run following a 1 percent increase in higher education attainment. Hence, higher education has a positive and significant impact on the economic development of Iran.

The End of Work :: Literary Analysis, Jeremy Rifkin

The material and ideological conditions of our society is important to understand our social situation. This essay outlines the material and ideological conditions and how it signifies our social situation. Material condition means production, exchange and the organization of society. Ideological condition means ideas that are common in society. This essay will focus on the following reading: â€Å"The End of Work† by Jeremy Rifkin, â€Å"Where the Wasteland Ends† by Theodore Roszak, â€Å"The Making of Economic Society† by Robert Heilbroner and â€Å"The Tyranny of Work† by James W. Rinehart. The material conditions in our society are very important. The introduction of machines reduced the number workers in the workforce. The commodity was produced mainly by machines with a little help of humans. The technology has developed which lead workplaces look into new ways in reducing cost and efficient products. In the â€Å"Where the Wasteland Ends† by Theodore Roszak it stated that knowledge grows and how tomorrow’s knowledge is enormous. Today’s knowledge would always be the base for tommow’s knowledge. (Roszak,149) Today’s people know more than people in the past. This relates to the â€Å"The End of Work† by Jeremy Rifkin article which states that the people in the past had their own knowledge of producing their own things for their own needs and than these workers had to make the products for other people which than lead to inventing machines to get rid of the workers. This demonstrates the fact that â€Å"the workers† were the old knowledge and the â€Å"machines† are the new knowledge. As technology, in other words â€Å"science† grows new knowledge would develop and this would lead today’s young generation to become smarter than the previous generation. The jobs that are present today in our society is related t o technology and therefore the work people do shows what they are worth. If you have more knowledge on the recent technology you would have a higher value. (Rifkin, 17) In the â€Å"The Making of Economic Society† by Robert Heilbroner it mentions that in order for humans to earn their daily bread they must work. (Heilbroner,1) In our world, the well developed countries depend on other countries to provide them with their daily needs and other products. They do not make their products instead they ship materials in and out the country for their citizens to use. (Heilbroner, 3) Countries like U.

Editorial - Letter to the Editor :: Editorial Newspaper Article Letter

Dear Editor, C. S. explains in his article â€Å"The Daily We,† the experiences that bring closeness in people that share a common identity. An experience that brings the knowledge of this is the recent freshman orientation that happened this past weekend. This brought closeness with all of the incoming students and warmth to be welcomed into the Dayton community. â€Å"The Daily We,† applies to this experience as a tool to understand the past weekend as complete fun. Throughout, the beautiful sunny day of August 28, upperclassmen helped new students put away their belongings. As time went on before even entering my room, I met many new faces and met many new friends. All day the upperclassmen sold t-shirts, lemonade and drinks and other memorabilia in front of the three freshman dorms. Rudy’s Fly Buy, a student store was right in front of Marycrest selling memorabilia. The day was very much complete. By midday I was very much packed into the room. After meeting my roommate, a friend who I met over summer classes, I knew right away this was going to be great year. All day, the experience was fun and exciting. Using the new student’s orientation as an example to â€Å"The Daily We,† I figured that it made the most sense to the closeness of people coming together as one. The first day will remain a memory in my mind. When I was apart of the orientation, the excitement grew, I felt happy, and the impact became a big part of my college experience. The first thoughts that came across my mind when I entered my room was this is my home for the next nine months, I am going to be sharing the bathroom with my whole wing, I am independent, and I am going to not have people telling me, â€Å"You have this due when?† or â€Å"You have to go to class?† This decision is your own. Your parents are not with you. You don’t have your dad or mom looking over your shoulder. Editorial - Letter to the Editor :: Editorial Newspaper Article Letter Dear Editor, C. S. explains in his article â€Å"The Daily We,† the experiences that bring closeness in people that share a common identity. An experience that brings the knowledge of this is the recent freshman orientation that happened this past weekend. This brought closeness with all of the incoming students and warmth to be welcomed into the Dayton community. â€Å"The Daily We,† applies to this experience as a tool to understand the past weekend as complete fun. Throughout, the beautiful sunny day of August 28, upperclassmen helped new students put away their belongings. As time went on before even entering my room, I met many new faces and met many new friends. All day the upperclassmen sold t-shirts, lemonade and drinks and other memorabilia in front of the three freshman dorms. Rudy’s Fly Buy, a student store was right in front of Marycrest selling memorabilia. The day was very much complete. By midday I was very much packed into the room. After meeting my roommate, a friend who I met over summer classes, I knew right away this was going to be great year. All day, the experience was fun and exciting. Using the new student’s orientation as an example to â€Å"The Daily We,† I figured that it made the most sense to the closeness of people coming together as one. The first day will remain a memory in my mind. When I was apart of the orientation, the excitement grew, I felt happy, and the impact became a big part of my college experience. The first thoughts that came across my mind when I entered my room was this is my home for the next nine months, I am going to be sharing the bathroom with my whole wing, I am independent, and I am going to not have people telling me, â€Å"You have this due when?† or â€Å"You have to go to class?† This decision is your own. Your parents are not with you. You don’t have your dad or mom looking over your shoulder.

Free Hamlet Essays: Hamlet Interpreted :: The Tragedy of Hamlet Essays

Hamlet Interpreted It is clear Hamlet can be interpreted from a multitude of perspectives on numerous levels. I cannot quite grasp Mr. Bloom's contention that this is a work of near biblical importance nor can I accept his allusions to Jesus or the Buddha. "Hamlet remains apart; something transcendent about him places him more aptly with the biblical King David, or with even more exalted scriptural figures."(Bloom, 384). My immediate response is that when Mr. Bloom shuffles off this mortal coil, I don't believe Billy Shakespeare will be waiting with a pint of ale. Professor Schechner's enjoyable production increased my appreciation of the value of wardrobe and inflection of voice. Prior to this performance I did not see Polonius as a buffoon (as portrayed by Mr. Shapli), nor the incestuous nature of Ophelia's familial relationships (Ms. Cole's ability to transform from coquette to lunatic was shocking). Doubtless there are near as many interpretations of Hamlet as there are Shakespearean aficionados. My own expertise lies in the political arena. I believe Hamlet could be construed as a treatise on aggressive, imperialist behavior. Throughout the Dramaturgic Analysis of Hamlet Prince of Denmark the indecisiveness of Hamlet is noted. He does not immediately seek vengeance but continually schemes, rants and raves (both in his rational and insane moments). Whether cowardice, caution, or simply indifference dominate his persona is unclear - what is clear is his distaste for his own behavior: "How stand I then, That have a father kill'd, a mother stain'd,...And let all sleep, while to my shame I see The imminent death of twenty thousand men... (sic)." (Shakespeare, 116). The impending doom of the twenty thousand men alludes to a campaign waged by Fortinbas, the Prince of Norway. Though the battleground is said to be of little value, Fortinbas is warring on principles of honor and the subsequent expansion of Norway. An enraged Hamlet mistakenly slays Polonius. Rosencrantz and Guildenstern are sent to their inconsequential deaths only when he is inspired by pirates to save his own life. These murders involved no elaborate schemes but were simply enacted. Yet with all his planning, his opportunities, his justification, why can he not kill Claudius? The portrayal of the pirates as "merciful thieves" (Shakespeare, 124) and the fact that warlike Fortinbras succeeds in Poland and obtains the Kingdom of Denmark by play's end - may be a commentary on decisive, imperialistic behavior.

Criminal Law Intoxication Essay

For hundreds of years, it has been assumed that individuals behave more aggressively while under the influence of alcohol. Alcohol related crimes cost the UK taxpayer  £1.8 billion on average per year . However, society has taken an ambivalent attitude towards intoxication. Alcohol consumption is generally depicted as a puritanical moral barrier used to escape pain and the harsh realities of life. Intoxication can conversely be portrayed as a sign of weakness, impeding human reasoning leading individuals to behave in an unacceptable manner. Does this lack of consistency in society’s opinion reflect the clarity of the law as regards to when intoxication can be a defence? Drunkenness was a crime punishable by imprisonment in the form of stocks or a fine from 1607 to 1828. The law in this area concentrates on whether the accused who committed the prohibited act, has the necessary mens rea due to voluntary or involuntary intoxication. There are two extreme approaches that the law could follow on intoxication; the strict subjective theory emphasizes the defendant lacked the required mens rea and supports the idea of absolute acquittal from liability. The absolutist policy theory highlights the importance of public protection and endorses punishment. This arena consisting of the two aforementioned principles have created a tangled web that leaves numerous questions unanswered. The law has tried to achieve an intermediate compromise, rejecting both theorems in favor of adopting different strategies for each criminal offence. An initial distinction has to be drawn between being drunk and being intoxicated. It was expressed in R v Sheehan and Moore that ‘a drunken intent is nevertheless an intent.’ A drunken individual would not be able to use the defence of intoxication, as he is still capable of forming the necessary mens rea. The case of R v Stubbs stated that intoxication needed to be ‘very extreme’ as it is impossible to form the mens rea due to the effect of copious amounts of alcohol. This essay will investigate the situations when intoxication can be used as a defence, analyzing the decision in R v Majewski and its impact on the specific and basic intent dichotomy. The Law Commission has taken a ‘stripped-down approach’ attempting to codify the main principles of the common law regarding voluntary and involuntary intoxication. There is an opinion that ‘there is much in the Report to commend it’ but others have drawn attention to the production of ‘head scratching provisions’ leading some to question whether intoxication should be called a defence at all. The Scottish Law Commission have recognized the difficulty in reforming the law and have stated ‘intoxication as a complete defence in all circumstances would be extremely serious.’ To what extent is intoxication used as a defence in criminal law and should the legal boundaries be clearer? Voluntary Intoxication Voluntary intoxication is defined in the Butler Committee Report as ‘the intentional taking of drink or a drug knowing that it is capable in sufficient quantity of having an intoxicating effect.’ In reality, the law does not support the stringency of this explanation. The main rationale is that the intoxicant must be able to impair the defendant’s rationality and human reasoning abilities. In the case of R v Hardie, the question of whether valium could be classed as an intoxicant arose. The defence was that the valium was only administered for relaxant purposes and according to Lord Parker, ‘there was no evidence that it was known that the appellant could render a person aggressive.’ Does this mean the court has to decide whether a substance is an intoxicant individually for each case? The Law Commission believes this approach is overall inadequate. The law in England and Wales presumes that intoxication is voluntary unless evidence is produced that allows the court or jury to conclude that it was involuntary. Recent government proposals refrain from attaching a definition to ‘voluntary intoxication,’ preventing the creation of a narrow approach developing. Consequently, voluntary intoxication is not a defence in the law but it can become a mitigating factor and be considered as a â€Å"partial excuse† reducing the echelon of criminal liability. This area has caused serious problems in English criminal law, as it is fraught with ambiguity and uncertainty. How should the law decide the effect voluntary intoxication has on the defendant’s liability? The effect of voluntary intoxication on the mens rea of criminal acts is often comprised of the defendant foreseeing the consequences or intending their occurrence. The strict subjective theory emphasizes that intoxication will always be relevant to the outcome of the case but the absolutist policy theory allows the possibility to escape liability completely. Each theorem supports contrasting trains of thought and makes the options for reform more unenviable and unclear. In an attempt to reach a ‘compromise’ and stabilize the theoretical problems and public policy issues involved, the law has categorized criminal offences into two groups; specific and basic intent offences. Despite the broad scope for divergence, the Law Commission has approved the common law’s implementation of this â€Å"midway course† distinction. Specific and Basic Intent Dichotomy ‘All people have the right to a family, community and working life protected from accidents, violence and other negative consequences of alcohol consumption.’ The essence of the law in England and Wales is not dissimilar to this aim in that intoxication can provide a defence to crimes that are of specific intent, but not to those that are of basic intent. The House of Lords in the leading case of Majewski depicted this approach, which has been dubbed a ‘dichotomy.’ They declared it must be proved in specific offences that the defendant lacked the necessary mens rea at the time of the offence. It is for the prosecution to establish the actual intent of the defendant, taking into account the fact that he was intoxicated. In crimes of basic intent, the actuality that intoxication was self-induced provides the necessary mens rea. The original distinction between crimes of specific and basic intent initially appeared to be clear: the courts did not want a defenda nt to escape liability for his crimes caused during his intoxication. In practice, the distinction is difficult to ascertain and has created incongruity in the law. The courts also desired the dichotomy to be flexible allowing partial defences and mitigation in some cases. Simester argues this similarity is ill founded, as ‘intoxication is a doctrine of inculpation†¦and work in opposite directions.’ Simester’s view regarding the dichotomy is persuasive but I believe clarification is needed before the law can be deemed acceptable. Lord Simon developed another analysis where ‘the prosecution must in general prove that the purpose for the commission of the act extends to the intent expressed or implied in the definition of the crime.’ Another approach put forward was the ‘ulterior intent test,’ which was more widely accepted. This supports the idea that in specific intent crimes, the mens rea extends beyond the actus reus and in basic intent crimes, the mens rea goes no further than the constituents in the actus reus. However, the most prevalent explanation, the â€Å"recklessness test,† which was given by Lord Elwyn-Jones and later approved in the House of Lord’s decision in the case of R v Caldwell. An individual is Caldwell-type reckless if the risk is obvious to an ordinary prudent person who has not given thought to the possibility of there being any such risk, or if the individual has recognized that there is some risk and has nevertheless persisted in his actions. This test states intoxication can only be relevant to crimes that require proof of intention and it is immaterial to crimes that are committed recklessly. Lord Diplock took the objective view that classification of offences into basic or specific intent was irrelevant where â€Å"recklessness† was satisfactory to form the mens rea. However, the distinction between the varying offences is important if the intoxicated person who is charged with an offence of basic intent has thought about a possible risk and wrongly concluded it to be negligible. In this case, there is a lacuna in the â€Å"recklessness test.† The defendant would be acquitted unless convicted under the Majewski ruling on the basis that the actus reus of an offence of basic intent has been committed. Lord Edmund-Davis dissented arguing ‘however grave the crime charged, if recklessness can constitute its mens rea the fact that it was committed in drink can afford no defence.’ Is this too harsh to adhere to the justice proclaimed in the English legal system? The case of R v Heard, the Court of Appeal rejected the recklessness test in favor of the â€Å"purposive intent† and â€Å"ulterior intent† test. The judgment contains vast amounts of ambiguity with the difficulty of ‘fitting an offence into a single pigeon hole.’ The â€Å"recklessness† test was finally confirmed in the 1980 Criminal Law Revision Committee Report and provided an ample explanation for voluntary intoxication. The offence of rape provides a good illustration of the difficulties involved in the â€Å"recklessness† test. The case of R v Fotheringham concerned the rape of a 14-year-old girl by an intoxicated husband who mistakenly underwent sexual intercourse in the belief that the girl was his wife. The offence of rape at that time could be committed recklessly but this has been altered to the principle of ‘reasonable belief.’ The court had to decide whether the defendant had an intention to carry out unlawful sexual intercourse or whether recklessness was sufficient for conviction. Public policy of protection triumphed over the strict subjective theory where intoxication would prevent liability and defined rape as a basic intent offence. The recent case of R v Rowbotham (William) concerning the offences of murder, arson with intent to endanger life and burglary were invalidated where defence expert evidence showed the defendant’s mental abnormalities combined with extreme intoxication had prevented him from forming the specific intent necessary. This case illustrates the dichotomy is still used by courts today despite aspirations for reform. Involuntary Intoxication The courts have taken a moderate approach to defendants who have become intoxicated through no fault of their own. The most common cases of involuntary intoxication involve intoxication that is unknowingly induced by a third party. The main principle is that a defendant will not be held liable for any crimes they carried out while involuntary intoxicated. Their transparency and lack of knowledge shields their ability to form the necessary mens rea. This is not a â€Å"blanket† rule and there are various requirements as to what satisfies the definition of ‘involuntary intoxication.’ Lord Mustill in R v Kingston described the phenomenon as a ‘temporary change in the mentality or personality of the respondent, which lowered his ability to resist temptation so far that his desires overrode his ability to control them.’ He declared the Court of appeal supported the view that protection flows from the ‘general principles’ of the criminal law, b ut what exactly does the term â€Å"general† entail? The first criterion is that the defendant cannot claim they are involuntarily intoxicated if they were misinformed about the description or specific alcohol content. This is illustrated in R v Allen where a man was convicted of indecently assaulting his neighbour even though he had no knowledge of the high alcohol content of the home made wine that he was drank at home having returned from the pub. The second criterion imposed by the courts is that the defendant must have been intoxicated to the point where it would be impossible to form the mens rea to commit the crime. The case of R v Beard created the rationale that there is no remedy if an individual’s inhibitions are lost due to involuntary intoxication. This case was more complex as it involved succession of acts; the defendant whilst intoxicated, raped a 13-year-old girl, placed his hand on her mouth to stop her from screaming, and thus suffocating her resulting in her death. The trial judge at first instance erred in a pplying the test of insanity to a case of intoxication, which did not amount to insanity. Has the ambiguity in this case been eradicated? A recent paradigm of involuntary intoxication can be seen in the Kingston case involving a situation where a 15-year-old boy was drugged and indecently assaulted after the defendant’s drink was spiked. The trial judge directed the jury to convict if they found that the defendant had assaulted the boy pursuant to an intent resulting from the influence of the intoxication. The Court of Appeal upheld the appeal on the basis that it was the defendant’s ‘operative fault.’ Smith has depicted this outcome as ‘surprising, dangerous and contrary to principle.’ The opinion of the House of Lords, who took a narrow view of blame, was Smith’s preferred alternative but others favor the creation of a new common law defence determined by character assessment. Sullivan has described this as comparing the defendant’s â€Å"settled† character with their â€Å"intoxicated† character. If the character is ‘destabilized, he should have an excuse.’ Should the blame not be directed at the 3rd party instead of the defendant though? This method creates a schism between the relevant blame and moral fault. As a consequence, mens rea is being given a more normative meaning negating its cognitive counterpart. However, the Commission is adamant to reject the creation of a new approach and wishes to give statutory effect to the decision in Kingston. They believe that ‘there should be no defence or reduced inhibitions or blurred perception of morality where the defendant’s condition was caused by involuntary intoxication.’ Only time will tell, if the legal reform bodies will cling to their orthodoxy or embrace change. Dutch courage and diseases of the mind To what extent is alcohol-related crime attributable to those with already dysfunctional lives, with a propensity to problematic behaviors, rather than apparently ‘normal’ people engaging in criminal acts when intoxicated? The union of actus reus and mens rea is known as contemporaneity. It is necessary to establish for a conviction to be successful. However, the Dutch courage rule, where the accused gets into a drunken state after deciding to commit a crime, is an exception to this principle. It was decided in Attorney General for Northern Ireland v Gallagher that the accused would be liable for the crime even though they were too drunk to satisfy the required mental element. Lord Denning declared ‘the wickedness of his mind before he got drunk is enough to condemn him.’ Although, it has been recognized that ‘it is almost inconceivable that the case envisaged could ever arise.’ The sale and consumption of alcohol are legal so should we accept t he consequences of diminished responsibility as a cause of criminal activities if perpetrated whilst under the influence? There has been more discussion surrounding the affiliation between alcohol and diseases of the mind. The case of R v Dietschmann concerned a defendant who was intoxicated at the time of the killing that suffered from a mental abnormality due to a recent bereavement. Lord Hutton said ‘drink cannot be taken into account as something which contributed to his mental abnormality.’ The main principle is that drunken defendants are not excluded from pleading diminished responsibility or insanity if they suffer from mental abnormalities. Ashworth believes the task of the jury to decide whether the mental abnormality affected the mens rea is ‘fearsomely difficult.’ Medical experts to some extent aid the task of the jury but the margin for error is significant as the effect of drink and drugs is unique to every individual. It has also been argued that there could potentially be a genetic predisposition to alcoholism but the scope of this is unknown. Tolmie’s conceptualizations of the ‘disease model’ and the ‘habit model’ are eccentric and provide light recovery from psychoanalytic evaluations. I particularly enjoy the fact that she has highlighted the importance of ‘normal human processes†¦and bad choices,’ which are often overlooked. She concentrates on the need for treatment for defendants and does not fall into the trap of defining intoxication as an express defence. The current position of the law in this area is unfair as it deforms other doctrines, supports unprincipled sentencing and punishes some defendants far more than they deserve. Adoption of a generic, doctrinal mitigating excuse of â€Å"partial responsibility† with application to all crimes would solve these problems. This alternative option would function in a similar manner to the ‘not proven’ verdict used in Scotland. In the end, to provide blame and punishment reduction based on fair respon sibility ascription will not support a denial of responsibility. Reform Certain statutes expressly state that a defendant has a defence if they possess particular beliefs. Does this apply where a belief is acquired through intoxication? There is only one type of case where an intoxicated belief can be used as a â€Å"defence.† In the case of Jaggard v Dickinson, the defendant appealed against a conviction of reckless criminal damage to property. The accused, owing to voluntary intoxication, mistakenly but honestly believed that she was damaging the property of a friend and that they would have consented to her doing so. A major anomaly in the law is found when the approach taken in Jaggard is contrasted with that taken in Majewski where the Criminal Justice Act 1967 was not relied upon. Wells has commented that ‘it is difficult to see how†¦the sections perform any different function.’ The area surrounding drunken mistakes is just one theme encircled with uncertainty. There has been much discussion of reform regarding the position of intoxication in the law. The concepts of basic and specific intent are ambiguous, confusing and misleading. The Law Commission has created a proposal to abandon them but the substance of the distinction has been retained. The main question regarding the specific and basic intent dichotomy is the affect it has on the voluntary intoxicated defendant’s liability. The blameworthiness of the defendant is expressed by an evaluation of criminal liability. An enlightened system of criminal justice should respond differently to ‘common criminals’ and voluntary intoxicated defendants. If a man commits mischief when intoxicated, should society take steps in the framework of the criminal law to prevent him? Judicial insistence upon the requirement of mens rea might remove the problem of antisocial drinking but alternatives will not develop if the courts allow these problems to be thrust upon them. The Majewski decision has been criticized as it allows conviction for causing harm where mens rea has not been formed. This is even the case where a defendant is convicted of a basic intent offence instead of a stricter specific intent offence. The House of Lords decision acknowledged the principle of allowing intoxication to be adduced to show that the mens rea for specific intent offences did not exist. They were persuaded by policy objectives to convict of basic intent offences despite the intoxication. This â€Å"midway course† is acceptable on policy grounds but it fails to accord with the basic principles of justice in the criminal law. Is this a clear and logical compromise? The idea to secure conviction for serious offences without satisfying the criteria of mens rea is conjured. This conflicts with the burden of proof, which is placed on the prosecution. This means the fictitious objective â€Å"recklessness† test allows conviction of offences, which require proof of subjective â€Å"recklessness.† The current rationale of the law is that the subjective reckless involved in becoming intoxicated is the moral equivalent of the subjective recklessness usually required for liability. A further criticism is that â€Å"recklessness† relates to the risk of becoming intoxicated and not to the risk of specific harm being caused. As a result, the liability for the harm caused whilst intoxicated goes against the principle of contemporaneity and is constructive, which is contrary to the trend of current law reform. The English law reform bodies have created proposals to replace Majewski with a separate offence of intoxication. This separate offence would remove the possibility of a complete acquittal, which is available in specific intent crimes. A disadvantage to the proposal would be the construction of a â€Å"status† offence with no mens rea involved. This contrasts with previous social policy illustrated in the case of Reniger v Fogossa where a drunken killer was hanged to death to protect human life. However, the Criminal Law Revision Committee rejected the idea of a new offence of intoxication and instead suggested the codification of the law, whilst approving the â€Å"reckless test.† Authors such as Jeremy Horder, who depicted the Law Commission’s efforts as making ‘little effort to discern any deeper principles underlying the common law’, have criticized the Law Commission attempts at clarifying the law. The reform bodies now intend to amend their previous proposals and return ‘to the subject with a stripped down approach.’ Conclusion Why is it taking an unbounded amount of time to evaluate reform of the law on intoxication when 61% of the population perceives alcohol-related violence as worsening? The bare components of the law on intoxication are complex but the added series of exceptions that the Law Commission have proposed to introduce, in my opinion, will undermine the principle of justice in England and Wales. The common law has found a reasonable balance between the subjective and absolutist theories but the ‘midway course’ of specific and basic intent is not satisfactory. The dichotomy requires the courts to evaluate individual criminal acts on their merits putting them into a category of specific or basic intent, which squanders the court’s time and thus, decreases the overall inefficiency of the legal system. Child’s innovative approach involving the correlation with subjective recklessness is an alternative to the recent reform proposals. He declares intoxication will constitute fault only where the burden is replaced by subjective reasonableness and if the defendant would have foreseen the risk if sober. The ‘midway course’ is preserved but in a clear and logical manner without a list of exceptions. However, I disagree with Child’s interpretation of intoxication as the equivalent to recklessness. I believe more research needs to be given to determine the extent of their connection and ultimately decide whether they are analogous or mutually exclusive. Ultimately, liability is ascertained by the intention element but how can this truly be deduced when automatons are intoxicated? Lady Justice Hallett in the recent case of R v Janusz Czajczynsk commented that ‘drinking to excess and taking drugs seems to us to be something of a two edged sword.’ It is tempting to view the defence of intoxication as denying a defendant ‘a valueless opportunity to exculpate himself by pleading his own discreditable conduct in getting drunk.’ However, it is impossible to accurately determine an individual’s thoughts at a precise moment and draw a line where a defendant’s account matches the truth. Simester suggests the intoxication doctrine is reversed to benefit prosecution, becoming constructive liability instead of a defence. I believe there is some accuracy in this initiative but it fails to address the main problem regarding the mental state of the accused. Should there be a common law or statutory defence of intoxication expressly declared? The courts and the Law Commission know the law is not clear and desire to reform the law only after exploring every open avenue. The Law Commission has rightly prioritized consistency, precision and simplicity in their Reports but ‘another round of re-evaluation’ is definitely needed before a firm conclusion can be established. We can only hope that time does run out, allowing the reform debate to finish sooner rather than later.