Credit Card Essay Example | Topics and Well Written Essays - 500 words

Credit Card - Essay Example If the student with a poor credit report is fortunate enough to land their dream job, the weight of the credit report will pull down a portion of their take home pay. They will be saddled with the existing debt, as well as pay higher prices on everything from cars to insurance. Insurance rates are based on a client's risk of filing a claim and the insurance companies adjust the premiums accordingly. A 2004-2005 study by the Texas Department of Insurance found that, "...[I]nsurance loss ratios for people with the worst credit scores are triple those of people with the best scores" (Overview... ). For the poor credit risk this results in higher rates on auto, home, and even life insurance premiums. Yes, even life insurance premiums are affected by a poor credit report because poor credit can damage your health and may result in your death. Endless financial worries and fears of collectors calling can manifest themselves in a myriad of medical problems. Hard to manage credit can cause stress, hormone imbalance, heart disease, high blood pressure, diabetes, and even some forms of cancer (Lawrence). The risk is even greater for young women where financial problems are a leading cause of suicide (Khaitova). Easy credit and the lure of the credit card companies can result in a lifetime of misery when out of control finances result in the loss of a student's dream job. When faced with a second rate job and escalating insurance rates, their health begins to suffer. For some, the cycle of mounting debt can result in death or even suicide.

Literature - Dr Jekyll and Mr Hyde, The Picture of Dorian Gray and The Essay

Literature - Dr Jekyll and Mr Hyde, The Picture of Dorian Gray and The Time Machine - Essay Example In describing the human experience during the fin de seicle era, sociologist Marshall Berman says â€Å"they are moved at once by a will to change – to transform both themselves and their world – and by a terror of disorientation and disintegration, of life falling apart† (Berman, 1982). Through this statement, it is easy to see the conflicting emotions of an individual experiencing the type of rapid change that has characterized society since this period. As the people living during this period became more familiar with the concepts of Sigmund Freud and the hidden recesses of the mind and the ideas of Charles Darwin and the processes of natural selection and evolution, it became a necessity to examine the beliefs and customs of their inner selves. No longer was the world considered stable so the only center of gravity had to be found within, yet the world within was even more threatening. Many of the old values were shifting as factories rose and cities were bui lt. Women were gaining new freedoms and the old aristocracy, with its life of leisure and waste, was slowly falling into disrepute as enterprising and hard-working individuals from the lower classes began to make names for themselves, building up a middle class that valued work above play and based wealth upon monetary measures rather than the size of one’s property holdings. The resulting clash of values also constituted a meeting between the self and the other, as landed gentry struggled to come to grips with the new boldness of the rising middle class. It was during the fin de seicle era in particular that the question of the inner nature of man and his ultimate direction in life were made the focus of scientific study at the same time that the pace and direction of life were thrown into chaos, explaining this period’s fascination with the concept of the monstrous. The novel The Strange Case of Dr. Jekyll and Mr. Hyde, written by Robert Louis Stevenson in 1886, presents the ultimate

New Headway Intermediate Book Evaluation English Language Essay

New Headway Intermediate Book Evaluation English Language Essay The purpose of the second part of this essay is to evaluate New Headway intermediate students book, one of the course books used at many of the foreign language institutes around the world. The evaluation will be based on an external and an internal evaluation of the book. The external evaluation will give us a brief overview of the materials from the outside (also known as factual information) and the internal evaluation will give us a closer and more detailed look at Units 1 and 2. The new headway course book is meant to be suitable for adults undertaking a general English course. It is the third edition, which means that the book is very popular and published many times. Liz and John Soars are the authors of this book. There is a note at the back of the book which states: Liz and John Soares are internationally renowned authors and highly experienced teachers and teacher trainers. This statement indicates that the authors are recognised in an international basis. The publisher is the oxford university press; A widely known publisher which has published thousands of books. There is a website link in the front and in the back of the book which you can access it online. The one link contains exercises you can do online and the other one has different English Books it has published so far. This single course book costs  £22.00, without the supplementary materials. If you want to buy the whole package, you have to buy each material individually. However, the whole package includes: class CDS/cassettes, a workbook (with or without key), the students workbook CD/cassette and a DVD/Video with students activity book. There is also a teachers book in print and locally available. Thus, the student edition will not be difficult to work with. However, if you go online at Amazon, you will see that if you want to buy together the teachers book, the workbook and the class audio cds, costs  £68. It is very expensive for someone who cannot afford it economically and he will be dissuaded from selecting it. In my opinion I would not buy the single book for only  £22 pounds as I would definitely need a workbook for supplementary exercises. However, it is not included in the package and it costs  £12.50. Also the course book does not provide any audio material in the back as man y do. I think that it is essential to provide this extra material in order to use the textbook more successfully in self-time study. The front cover is colourful with nice pictures, but in my opinion it is not very inspiring and attractive for learners. If you would take off the title I will take it as a science or a maths book. When opening the contents page, language is presented and organised into teachable units. The contents page illustrates the general organisation of the material, which is based on topics. Under each unit there is an established topic. Meanwhile, the importance of form is also made obvious by the prominent placement of grammar in the second column. It is now clear that the content is sequenced on the basis of the grammar complexity. It starts from a more simple grammar form and then progress to a more complex grammar form. The contents are divided broadly into language input and skills development. Under language input there is grammar, vocabulary and everyday English. Under skills development there is: reading, speaking, listening and writing. We can now continue to the next stage of the evaluation by performing a more deep investigation into the materials. I am going to examine Unit 1 and 2 in order to perform an effective internal inspection of the materials. Both units start with a presentation of the grammar which will be the focus of the unit and provides an engaging start. Looking the units as a whole all the language skills including grammar, vocabulary, reading, listening and speaking are all covered. Usually after the test your grammar part which engages you into the main focus of the units, there is a text. It is good that the unit starts with this way because it is helping them to remember thing they have done previously but also is going to introduce them of what grammar is going to follow. In unit 1 the grammar is very simple. It starts with auxiliary verbs, naming the tenses, questions and negatives, and short answers. Tenses and auxiliary verbs are integrated into a quiz which they have to complete and then listen to it in order to check their answers. Then there is the grammar spot and then there is a practice section where they have to practice negatives and pronunciation. Then follows some exercises on short answers where they have to notice differences between the two conversations. This is followed again by a grammar spot and then a practice activity based on short answers. It is obvious that it gives more emphasis on grammar. However, then follows an information gap speaking activity. In the next page follows a reading and a speaking activity where the students have to read a passage on the wonders of the modern world and answer some questions based on the text and then discuss some other questions. Further down there is a freer listening and speaking section w hich consists of listening about wonders of the modern world and a discussion based on inventions. Then, follows a vocabulary section with different exercises based on what it is new in a word. This part includes some spelling and pronunciation exercises. Additionally there is a reference to page 159 where you can find all the phonetic symbols. At the end of the vocabulary section there is a writing exercise in page 103 based on correcting mistakes and finally there is the section every day English where students practice social expressions through exercises. Unit 2 starts with a short Test your grammar exercise which is to guide students into the focus of the unit and provide an engaging start. Following this is a picture presentation of different people having fun and here students have to talk about what makes them happy. Then there is a textual representation incorporating pictures and a written text on the theme of what makes people happy, which talks about Sidney fisk and below some comprehension questions focusing on conceptual aspects of the target language. The target language has been embedded in the written text .The object is that learners are given some exercises where they have to opportunity to practice how the present tense is used and why. These rules are reinforced in a grammar spot section under the passage and in the grammar reference in the back of the book where learners can look for help. This is followed by a listening and speaking controlled practice activities, the first two focusing on present tenses. Both of th ese exercises use information and examples from the presentation of grammar. Then students listen and read a conversation which is based on simple or continuous and they have to practice similar conversations with the one they have listened to including different jobs. This is followed by grammar practice activities, where in the first one they have to indicate whether the sentences are correct or not and in the second to complete the sentences with present simple or present continuous. Then, the reading and speaking section is about I am a clown doctor. The unit here includes some pre-reading activities; mainly questions which are said to motivate learners. Then learners have to read the text and answer some questions. Following this is a grammar spot exercise which focuses on present passive. Students have to complete sentences from the text and then if they want they can go and see the rules on how and when to use present passive on the grammar reference part. Some more exercise s follow. The one is related to the text and in the other one you have to format some questions in order to complete the interview. Then there is an activity where students have to discuss some questions in groups. Exercises on vocabulary and listening are in the next page, based on sports. There are pictures of different people doing different sports and a warm-up activity in which learners have to make a list of as many sports and leisure activities they can think of. They can use the pictures for help. When they finish, there is an exercise where they have to match some sports with the verbs do, play or go. Then follows an activity in which they have to complete a chart using activities from the list they have made before. Meanwhile they have the opportunity to use a dictionary to look up any words they need. Then they listen to different people talking about a sport activity they enjoy and take notes. In a freer activity they can ask their partners some questions based on sports . For writing they have to write letters and emails. The unit finishes by everyday English which is based on numbers. They will learn about money, fractions, decimals and percentages, dates and phone numbers. Then they will listen to some conversation and write the numbers they hear. In my opinion it would take me 18-20 hours to teach both units in this course book. New Headway Intermediate is attractively laid out, with glossy pages and plenty use of colour and photographs which inspires the student. The strong visual element is likely to attract students. However, the cover does not really remind you of an English book, but the inside is different. I think that the new headway intermediate book is well organised into units and sub-sections and it is easy to follow. There are headings or labels for each section and exercises and activities are always introduced with clear instructions. The book clearly arranges the contents, and cross references indicate where learners can find further grammatical information, typescripts, pair work activities, irregular verbs, verb patterns and phonetic symbols in the back. Still, it does not include any revision or recycling sections and this is a disadvantage because students will not have the opportunity for self study in order to check the skills they have learnt. I would provide them with some revision ac tivities with every 2 or 3 units so that they will do revisions and refresh their skills. However, I find the way that the materials are sequenced logical, because intermediate learners need to work their grammar. Some people may find this as a limitation but I believe that it is a good for intermediate learners that the content is based on the complexity of grammar. Moreover, there is a varied mix of activities, like grammar, vocabulary, listening, speaking, reading and writing skills, and functional English, but it lacks on pronunciation activities. Even if it provides phonetic symbols in the back of the book it does not include material for pronunciation work, and it is essential for this level of students to practice their pronunciation. The material for vocabulary is adequate in terms of quantity and range It offers a good balance of work on all skills and they are adequately covered .Also, there are some points where there are materials for integrated skills. I think that there are not enough activities associated to the text in each unit. In unit 1 and 2, they have to read the passage and then answer some comprehension questions. There are not exercises or suitable texts that will help students to improve their reading skills (scanning, skimming, intensive reading, and extensive reading). As homework I would give students extra reading exercises to do in order to practice their reading skills. The other skill that lacks in practice in the unit is the listening skill. I believe that again the book does not provide learners the opportunity to expand and practice their listening skills. The exercises provided for listening does not help students to expand their listening skills, and thus I would give them different listening activities to do within a lessons in order to practice their l istening. Grammar, writing and vocabulary are well covered. Speaking activities can equip them for real-life conversations. The topics are motivating for the adult learners and suitable for their language level. It covers a variety of interests and it gives them the opportunity to expand their awareness on some topics and enrich their experiences. Other groups of people are also presented in the topics. On the whole, New Headway Intermediate course book is perceived as a well designed and a well written book which supports English language learning. It is also used in many schools which teach English as a foreign language. It is suitable for learners, and regarding the disadvantages mentioned above they can become overcome through supplementary activities. .

Affirmative Action In The United States :: essays research papers

The writer Mary Anne Warren is focusing on describing the current practices in many organizations today in regards to the implementing a goal vs. a quota system for the purposes of affirmative action. She defines a quota as "Those who use the term "quotas" pejoratively tend to assume that the numerical standards will be set so high or enforced so rigidly that strong reverse discrimination-that is, the deliberate hiring of demonstrably less well qualified candidates-will be necessary to implement them." (Warren, 370). Warren then describes goal as "The term "goal", on the other hand, suggests that this will not be the case, and that good faith efforts to comply with the standards by means short of strong reverse discrimination will be acceptable." (Warren, 370). The critical thing that must be understood when exploring the subject is that the writer is describing how affirmative action is being applied in American organizations today in other words the current reality. However, she fails to speak to us about how the law designs this program to function. This is the critical component that American organizations must be educated to understand. Affirmative action as defined by law is most definitively not based on a quota system. In fact, what is not widely known is that this program can be equally used by all individuals provided that an inequality exists in the group that they belong to as not being reflected in the work force. So what is affirmative action? What is it designed to do? It is not designed to provide an opportunity to an unqualified candidate. It is designed as "a way of compensating individuals or groups for past injustices or for present disadvantages stemming form past injustices" (Warren, 373). It is further designed "as a means about bringing about further future goods-for example, raising the status of downtrodden groups." (Warren, 373). The keyword in these quotes is the word "group". Who are these groups? The law has identified them. Some of the groups identified are: race, religious beliefs, blood trait, gender, disability (whether physical or mental), veteran status, national origin, and the list continues. In no way does this require that you have to hire an unqualified person for a position because they fall into one or more of these groups. What it does mean is that you can not discriminate and exclude a person from getting a job, getting promoted, and other factors, just because they happen to fall into that group.

Crash and Privilege, Power, and Difference

Matthew Miller Paper #1: Privilege, Power, and Difference* and *Crash The Movie Crashis set in Los Angeles and begins when several people are involved in a multi-car accident. From there the movie skips to the day before where we see the lives of several of the characters who were involved in the crash and the racial problems they encounter that day. The moviebegins by showing an Islamic man and his daughter going into a gun shop to by a gun. When the Islamic man speaks in a different language to his daughter the store clerk says to him â€Å"Hey Osama, plan your Jihad on your own time. An argument ensues and the daughter ends up staying in the store and buying the gun, and instead of bullets she accidentally buys blanks asammo, however the clerk does not tell her this. The movie then skips to a couple of young black men who are complaining about the service they received at a restaurant. One of them says it is because of the stereotype that blacks don’t tip very well, and th ensays that he didn’t tip anything because of the poor service. As the two black men are walking down the street they come across a white politician and his wife. When the politician’s wife sees the black men coming towards them she gets closer to her husband. One of the black men noticesthis and points it out. Shortly after they pass each other the young black men steal the white couples’ car at gunpoint. The politician’s wife is really upset about being carjacked and has all of the locks in their house changed. When the locksmith comes and she sees that he is Hispanic she takes her anger out on him. The movie then shows a white LAPD officer who is trying to get medical help for his ailing father. The officeris having problems with a black clerk who won’t give the officers father permission to see another doctor. The white officer takes his frustration out on a black couple during a traffic stop and ends up sexually assaulting the woman. Next the Persian from the beginning of the movie calls the Hispanic locksmith to have him fix the lock at the shop that he owns. The Hispanic locksmith tells the Persian that he changed the lock but it wouldn’t do any good because he needs to replace the door. The Persian gets mad and tells the locksmith to fix the door and the locksmith said that he doesn’t do that, he just fixes locks. The Persian shopkeeper gets really mad about this. Shortly after this,the Persian man’s shop is robbed, and because he didn’t replace the door insurance will not cover the damage. The Persian man is extremely upset about this and blames it on the Mexican Locksmith. The white police officer has another run in with the HMO clerk. The white police officer basically tells the clerk that she only got that job because of affirmative action and that she probably beat out eightmore qualified white men for the job. He also tells her that despite the fact that his father’s janitorial service employed only black men he was forced out of business by affirmative action laws. The movie then goes to the crash where the black lady that was assaulted earlier in the movieis trapped in her car and surrounded by gasoline. It is only a matter of time before the car will explode and the first officer on the scene is the white officer who assaulted her earlier. The black lady initially tells him to go away, but he is very nice to her and ensures her that he is only trying to save her. He pulls her out of the car just before the car explodes. The movie then shows the Hispanic locksmith getting home from work, where he is then approached by the angry Persian shopkeeper, who blames him for his store being robbed and pulls a gun on him. The Hispanic locksmith’s daughter sees the gun pulled on her dad and runs in front of him just before the Persian man pulls the trigger. The shot is fired and everyone thinks the young girl has been shot, but since the Persian man’s daughter accidentally bought blanks in the beginning of themovie the young girl is fine. The movie ends with one of the young black hijackers being shot by the partner of the racist white police officer over some confusion. The first time I saw Crash my initial response was that the movie is incredibly sad. It is upsetting that so many of the racial issues we are faced with today stem from ignorance and fear. Part of me thinks this movie goes a little overboard with the racism issues in the movie because I don’t know if it is likely that so many people’s paths would cross in such a way where so many of them have such deep rooted racism and misunderstanding. It almost seems like the movie takes the racial stereotypes a little too far, but I think that was the point. It shows stereotyping and racism to an extreme and it makes you think that these peoples’ actions are ridiculous. I don’t think most of us are racist to the degree that is shown in the movie, but showing it to such an extreme really makes you aware of how ignorant racism is on any level. While the movie takes these examples to extremes, I do think a lot of the racial issues that occurred in the movie do happen on a regular basis, the movie just ties themtogether in the span of two hours to make a movie. At first I thought this was a little too much, but now I get the point of it. I really think the point of this movie was to raise awareness of the problem because awareness is a major step in the right direction towards solving the problem. One thing that stuck out to me because I’ve heard a lot about it is in the beginning of the movie when the young black men are talking about the poor service they received and that it was because of the stereotype that black people don’t tip very well. I have been dating a server for a few years, and she really isn’t racist at all, but she says this is true. She says she hates it because anytime she is serving a table of black people this stereotypegoes through her head and she hates thinking that but it’s true. I seriously doubt she is a person who would ever give them poor service because of the stereotype but I am sure that in some cases that happens. I think sometimes stereotypes are reinforced because of people’s preconceived thoughts. I am sure there are cases where a table of black people may receive poor service because the server assumes the table will tip poorly and then because the table receives poor service they probably do tip poorly, and the stereotype is reinforced. I thought the movie Crash and the book Privilege, Power, and Differencewere similar in many ways, but also very different in some ways as well. I think both the book and the movie take racial issues to extremes. I think they both do this to raise awareness of the important issues. In the book Johnson states â€Å"People can’t help fearing the unfamiliar—including people of other races† (2006, p. 4), Johnson goes on to say this isn’t necessarily true, but I think the movie tries to highlight this aspect of the problem. In the movie when the politician and his wife are walking down the street, the wife gets closer to her husband when the young black men approach because she is afraid of them. She is a person that has probably not dealt with very many you black men and sheprobably thinks that all young black men are criminals. In the movie she turns out to be right about these two menand is carjacked by them, but real life isn’t really that way. At some points I thought the movie kind of reinforced negative stereotypes like the young black men stealing the white couple’s car after she seemed racist for thinking they would do that. The book talks a lot about white racism and makes it sound as if it is white privilege that is holding back black people. I think the movie does a better job of showing racism from all aspects. The movie makes it seem like all races are racist against races other than their own, while concentrating heavily on the relationship between whites and blacks. In the movie one of the young thieves says that he would never rob a black person, and goes on and on about how white people hold black people down. Another important issue that the movie brought up is affirmative action laws. The white police officer who is dealing with the black HMO clerk brings up the issue in an argument with her. I think obviously the officer is out of line with what he says,however he brings up a pretty good point. The book goes on and on about the advantages of be â€Å"privileged†. When Johnson talks about the â€Å"privileged† he is referring to white men. Johnson says that the privileged have access to better jobs and will usually be hired instead of a black person or a woman. He is completely ignoring the affirmative action laws when he states this. Johnson states that â€Å"watching movies and television the message came across loud and clear that white men are the most important people on the planet† (2006, p. 79). I think the idea of the white man being â€Å"ideal† can be seen in the movie. When the black couple is arguing after the woman is sexually assaulted by the white police officer , the women says to her husband, you didn’t want to do anything because you didn’t want your name to be in the paper and all of your friends to know you really are black. I think she is implying to him that he hangs around with all white directors and acts white like them so that he will be more successful, but in the process has lost his â€Å"blackness†. Overall I thought both the book and the movie do a good job of raising awareness of the many racial issues that we are face with. They both take these racial issues to an extreme to make it clear that they do exist to a large extent. I thought the movie did a better job of giving a realistic portrayal of racism from all sides while the book seemed to be stuck on the concept of â€Å"white racism†. White racism† is certainly not a topic to be ignored and if you want to understand the racial issues we are faced with today it is not a bad place to start. However, the race issue runs much deeper than just white racism and can really be seen in cultures all around the world. I thought that Crash did a really good job of showing racism, and the negative affect it has in our society. Bi bliography Haggis, Paul (2004). Crash.

Land Law – Proprietary Estoppel

Proprietary estoppel protects a person who has a non contractual agreement over land but they have suffered a detriment due to them acting upon a reliance based on an assurance made by the claimant. There has been much discussion in recent case law and academic commentaries as to the elements which make up the nature of proprietary estoppel. Unconscionaibility is a major point for discussion in deciding whether it should be treated as a separate element or if it is linked into the three main elements.This essay will consider and discuss the nature of proprietary estoppel and the two views on unconscionaibility; whether there will always be unconscionaibility if there has been a non-performance of an assurance causing the claimant to suffer a detriment based on the assurance which they relied on or if unconscionaibility should be proven as a separate element in each case.The starting point of proprietary estoppel was in the case of Willmott v Barber (1880) where five criteria were lai d down, which had to be satisfied by a person claiming proprietary estoppel and the courts applied these criteria to a wide range of proprietary estoppel claims.However these criteria were criticised for being too strict leading to the broader approach established in Taylor Fashions Ltd v Liverpool Trustees Co Ltd (1982) where Oliver J stated: ‘whether, in particular individual circumstances, it would be unconscionable for a party to be permitted to deny that which, knowingly or unknowingly, he has allowed or encouraged another to assume to his detriment’. Although the approach became broader there still remained essential elements which must be satisfied for a successful claim.The more modern approach towards proprietary estoppel is based on three main elements, firstly an assurance of land or property being made to the claimant, the claimant relying on the assurance which has been made and finally the claimant suffering a detriment as a consequence of relying on the a ssurance made. The main point for discussion and questioning in proprietary estoppel is the role of unconscionaibility and whether it should be treated as a fourth element which too must be satisfied in order for a claim to be successful or if unconscionaibility is interlinked with the other elements of proprietary estoppel.Proprietary estoppel acts as ‘a sword and a shield’ and can be used in one of two ways. ‘Put positively, the reason why it is possible to use proprietary estoppel to generate a property interest in a favour of a claimant despite the absence of the normal formality rules is because of the need to prevent unconscionable conduct. This is why unconscionaibility is the foundation of estoppel. It is the antidote to the otherwise fatal absence of formality. ’ This is one of the views on unconscionaibility which suggest that unconscionaibility is at the heart of proprietary estoppel rather than a separate element of it.The first element of propr ietary estoppel is encouragement where the claimant’s belief that they would have some rights over land or property has been encouraged by the promisor and this could have been done actively or passively. Active encouragement is seen in common expectation cases where the claimant has been actively persuaded through an express representation as in Inwards v Baker (1965) where a son was actively encouraged to build on his fathers land in the expectation that it would be his in the future.Common expectation cases are dealt with more generously by judges, compared to passive cases, as the promisor has lead the claimant to have a reasonable belief that they would acquire the land therefore leading them to rely upon that assurance causing them to suffer a detriment. It would be seen as unconscionable in a common expectation case for the claimant to have been encouraged to suffer a detriment for the promisor to then go back on their assurance, meaning that unconscionaibility is inst antly a running theme in the elements as it can be seen at the first instance and should therefore not be treated as a separate element.The encouragement could also be passive, for example a land owner standing by watching someone build on their land knowing that somebody is acting under a mistaken belief. The nature of a passive expectation made to the claimant can be distinguished in commercial and domestic cases as was seen in Cobbe v Yeoman’s Row Management Ltd (2008) where the House of Lords established that the expectation of an interest in land should not be vague in a commercial situation.The expectation should be for ‘a certain interest in land’ for proprietary estoppel purposes which was not the expectation held by Cobbe therefore the expectation was held to be too vague. Lord Scott stated ‘Unconscionaibility in my opinion plays a very important part in the doctrine of equitable estoppel, in unifying and confirming, as it were, the other elements. If the other elements appear to be present but the result does not shock the conscience of the court, the analysis needs to be looked at again. This statement shows how case law endorses the unconscionaibility approach as being interlinked with the other elements of proprietary estoppel however if all of the elements are not satisfied there can not be a claim for proprietary estoppel as is the case here. In domestic (family) cases, the nature of the expectation doesn’t have to be so specific as long as there is an interest or right in land that would amount to a significant expectation. The assurance made must be clear enough so that claimant is found to have relied upon.Lord Walker stated in the case of Thorner v Major (2009) â€Å"There is no definition of proprietary estoppel that is both comprehensive and uncontroversial†¦the doctrine is based on three main elements, although they express them in slightly different terms: a representation or assurance made to the c laimant; reliance on it by the claimant; reliance on it by the claimant; and detriment to the claimant in consequence of his (reasonable) reliance† One view on unconscionaibility stated that ‘Once there has been detrimental reliance on an assurance, it is unconscionable to withdraw it’ therefore if it cannot be proven that an assurance existed then it wont be unconscionable for it to be withdrawn showing that unconscionaibility is a running theme within proprietary estoppel rather than a separate element. One difficulty in deciding these kinds of cases is that although an assurance has been made to the claimant in the way of a will, the claimant is also aware that the will could be revoked at any time therefore the question to be asked is whether their reliance based on the assurance was adequate. The second element of proprietary estoppel is reliance where the claimant must have been encouraged to rely on the promisor’s assurance which has caused them to s uffer a detrimental loss by changing their position and there must be a sufficient causal link between this in that the encouragement must have caused the detriment suffered.Reliance can not be treated as an element alone it has to have caused a change in the position of the claimant, if no detriment has been suffered then there can be no claim for proprietary estoppel. There are several ways in which the courts can show how the claimant was influenced to rely on the encouragement; firstly is by clearly showing that there has been a change in position by the claimants positive act, for example the claimant spending money on the land or making property improvements based on the assurance that it will become theirs, causing them to suffer a detriment. Where the claimant has acted in a way different to what he would had the assurance not been made nd relied on this can also show how the encouragement has influenced the reliance causing a detriment as in Jones (AE) v Jones (FW) (1977) w here a son acted on the assurance of property becoming his left his job and house to live with his father, however had the assurance not had been made he would not have done this leading to the detriment that he suffered. There can be a presumption made that the claimant relied on the assurances given to them based on there conduct and in these cases the burden is put onto the other party to prove that the claimant did not rely on the promises made and this is hard to prove as it is a subjective matter based on the claimants state of mind. This was the case in Greasley v Cooke (1980) where the defendant did not have to prove that she relied on assurances as it was presumed from her conduct.The final element of proprietary estoppel is that the person must have suffered a detriment due to the reliance on the assurance which has caused a change in their position. The detriment suffered can be in many forms not just that of financial detriment although it must be substantial in making i t unconscionable for the land owner to withdraw their promise of land to the claimant. Walton v Walton (1994) shows where financial detriment wasn’t the main detriment suffered, the claimant had suffered a personal detriment as he had spent years of his life relying on the assurance made to him that the farm would one day be his, and he couldn’t get those years of his life back. Public policy in formalities of contracts plays a major part in the deciding claims for proprietary estoppel.Section 2 Law of Property (Miscellaneous Previsions) Act 1989 states that (1) A contract for the sale or other disposition of an interest in land can only be made in writing and only by incorporating all the terms which the parties have expressly agreed in one document, or where contracts are exchanged, in each. This act stops informalities in land transfers where a claimant would be expected to sign up a contract but hasn’t done so, as in Cobbe, and this is where they would turn to proprietary estoppel to try and show that the detriment which they have suffered is due to the unconsionability of the removal of the assurance which they had originally relied on. Proprietary estoppel acts as a way around formalities and a form of protection for those who have not followed contractual formalities in the transfer of land.Why should people be able to use proprietary estoppel to make a claim for land where they have followed formalities and drawn up a contract as in Cobbe, it can be seen that it is not unconscionable for the promisor to withdraw as there is no contractual agreement. However in domestic cases where there wouldn’t always be an expectation of a legal contract to be drawn up proprietary estoppel can stop unfair decisions being made due to the lack of formalities where it would be unconscionable for the defendant to suffer a detriment due to an assurance on which they have relied. There are clearly two competing arguments against proprietary esto ppel, the first being that ‘once there has been detrimental reliance on an assurance, it is unconscionable to withdraw it. Indicating that unconscionaibility is a function of the three elements. If unconscionaibility was seen as a separate element then it would be pointless in having formalities as it wouldn’t matter whether it was unconscionable or not as long as the other elements had been satisfied. The second view on unconscionaibility is that of it being a separate fourth element and in some circumstance this can be seen as being successful for example in commercial cases where the first three elements of proprietary estoppel have been established but it would be unconscionable for the claimant to benefit due to the lack of formalities and contractual agreement.Therefore although in some cases unconscionaibility being treated as a separate element is beneficial in some circumstances, it should be treated as function of assurance, reliance and detriment as a withdra wal of the assumption in most cases is unconscionable. Bibliography Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) Martin Dixon â€Å"Proprietary Estoppel and Formalities in Land Law and the Land Registration Act 2002: A Theory of Unconscionaibility† (2003) 2 Modern Studies in Property Law ——————————————– [ 1 ].Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 323 [ 2 ]. Willmott v Barber (1880) 15 Ch. D. 96 [ 3 ]. Taylors Fashions Ltd v Liverpool Victoria Trustees Co. Ltd (1982) QB 133 [ 4 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 328 [ 5 ]. Nigel Gravells, Land Law: Text and materials, (4 th edn. Sweet and Maxwell, London 2010) 589 [ 6 ]. Martin Dixon â€Å"Proprietary Estoppel and Formalities in Land Law and the Land Registration Act 2002: A Theory of Unconscionaibility† (2003) 2 Modern Studies in Property Law, 177 [ 7 ]. Inwards v Baker (1965) 2 QB 29 [ 8 ].Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) 87 [ 9 ]. Cobbe v Yeoman’s Row Management Ltd (2008) 1 WLR 1752 [ 10 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 330 [ 11 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 343 [ 12 ]. Thorner v Major (2009) 1 WLR 776 [ 13 ]. Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) 90 [ 14 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 338 [ 15 ].Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 338 [ 16 ]. Roger Sexton and Barbara Bogosz, Complete Land Law: text, cases and materials, (2nd edn. Oxford University Press 2011) 338 [ 17 ]. Greasley v Cooke (1980) 1 WLR 1306 [ 18 ]. Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) 89 [ 19 ]. Law of Property (Miscellaneous Previsions) Act 1989 (s. 2) (1) [ 20 ]. Diane Chappelle, Land Law, (8th edn. Pearson Longman, London 2008) 89 [ 21 ]. Martin Dixon â€Å"Proprietary Estoppel and Formalities in Land Law and the Land Registration Act 2002: A Theory of Unconscionaibility† (2003) 2 Modern Studies in Property Law, 179