The Representation Of The Female Form In Art Essay Example For Students

The Representation Of The Female Form In Art Essay Since humankind advanced ladies have been revered, loved, loved and appreciated while all the while have been criticized, censured, denounced, manhandled, insulted, assaulted and killed as can be seen through the historical backdrop of craftsmanship. How ladies are depicted in craftsmanship educates much regarding the status and jobs of ladies in the public arena and where men needed them. Since ancient occasions lady have been depicted in craftsmanship, giving an impression of the recognition the craftsman and the way of life they lived in, had of ladies. The most punctual etchings and figures emphatically relate around a certain something. The female as the existence supplier, richness and labor. Despite the fact that there is the feeling that during circumstances such as the present ladies were viewed as simply spouses and moms keeping the house (cavern? ) clean. Some would contend ladies were not depicted as anything short of equivalent in workmanship. The idea of ripeness and labor was significant and raised ladies to a degree of extraordinary otherworldly significance and force among crude society. Jenny Saville is a cutting edge non-literal craftsman who through her work brings up issues identifying with universes impression of sexual orientations, concentrating on the obscuring of the lines of sex in ladies; in the outlooks of the changing recognitions men have of ladies just as the observation ladies have of them selves in a where the intensity of ladies is just later. She states shes looking to make the feeling of the possibility of a gliding sex that isn't fixed where sex doesnt characterize who class a subject falls into. This is her disputable painting of a transvestite with a womanly figure, bosom however male privates. She says this piece is expected to cause uncertainty on all levels. Is it a lady who resembles a man or a man who resembles a lady or both or not one or the other? The work of art is from a low heavenly attendant evidently to force a manly control while she lays femininely unprotected on the floor. Modern craftsmanship, for example, Damien Hursts The Virgin Mother The Virgin Mother has layers evacuated on one side to uncover the hatchling and the womans skull, muscles and tissue. Some may contend that the picture of the infant and the mother like this is an actual existence insisting and delightful delineation of the female as the most unique supplier of life. An incredible position, seeing pregnancy and labor not as simply the job of ladies in a world made for men nearly and tyrant position, this is substantiated by the size of the sculpture which stands tall above yard 35 ft noticeable all around giving the impression of intensity and predominance. The significance of ladies and the job they play in humankind. In spite of the fact that it has likewise been contended that Hursts dismemberment of the body, the organs uncovered, the belly the bosoms and the structure of the body noticeable practically like the natural development of a child machine. Removing the exceptional, amazing position that richness and labor can be viewed as having and summoning musings of ladies simply as plants in the continuation of the species. Kali Goddess of enduring Kali is the brutal type of the awesome mother. A long way from a lifeless thing of tentativeness and shortcoming. She typifies power, savagery savage ruthlessness and control over all men and is portayed like this through all hindu imaginative depictions Active and aloof contention There is a contention that ladies have consistently been delineated in workmanship as inactive while men are depicted as dynamic. A naked Venus like the ones of Botticelli and works of art by Titian are epitomes of strict standards. Be that as it may, in the two cases ladies are likewise erotic, inactive trimmings proposed for the male look. This is especially so on account of the Titian painting, which not just gives a substitute crowd in the figure of a pervy artist performer yet in addition models its Venus on a sixteenth century escort lady, prostitute. The most clear case of this is the leaning back nudes, for example, the one of the left. .u27d99f25625a015b0cb3e9cbadb649d6 , .u27d99f25625a015b0cb3e9cbadb649d6 .postImageUrl , .u27d99f25625a015b0cb3e9cbadb649d6 .focused content zone { min-stature: 80px; position: relative; } .u27d99f25625a015b0cb3e9cbadb649d6 , .u27d99f25625a015b0cb3e9cbadb649d6:hover , .u27d99f25625a015b0cb3e9cbadb649d6:visited , .u27d99f25625a015b0cb3e9cbadb649d6:active { border:0!important; } .u27d99f25625a015b0cb3e9cbadb649d6 .clearfix:after { content: ; show: table; clear: both; } .u27d99f25625a015b0cb3e9cbadb649d6 { show: square; change: foundation shading 250ms; webkit-progress: foundation shading 250ms; width: 100%; mistiness: 1; progress: obscurity 250ms; webkit-progress: murkiness 250ms; foundation shading: #95A5A6; } .u27d99f25625a015b0cb3e9cbadb649d6:active , .u27d99f25625a015b0cb3e9cbadb649d6:hover { haziness: 1; change: darkness 250ms; webkit-progress: murkiness 250ms; foundation shading: #2C3E50; } .u27d99f25625a015b0cb3e9cbadb649d6 .focused content zone { width: 100%; position: relative; } .u27d99f25625a015b0cb3e9cbadb649d6 .ctaText { outskirt base: 0 strong #fff; shading: #2980B9; text dimension: 16px; textual style weight: striking; edge: 0; cushioning: 0; text-enrichment: underline; } .u27d99f25625a015b0cb3e9cbadb649d6 .postTitle { shading: #FFFFFF; text dimension: 16px; textual style weight: 600; edge: 0; cushioning: 0; width: 100%; } .u27d99f25625a015b0cb3e9cbadb649d6 .ctaButton { foundation shading: #7F8C8D!important; shading: #2980B9; fringe: none; outskirt span: 3px; box-shadow: none; text dimension: 14px; textual style weight: intense; line-tallness: 26px; moz-fringe range: 3px; text-adjust: focus; text-embellishment: none; text-shadow: none; width: 80px; min-stature: 80px; foundation: url(https://artscolumbia.org/wp-content/modules/intelly-related-posts/resources/pictures/straightforward arrow.png)no-rehash; position: supreme; right: 0; top: 0; } .u27d99f25625a015b0cb3e9cbadb649d6:hover .ctaButton { foundation shading: #34495E!important; } .u27d99f25625a0 15b0cb3e9cbadb649d6 .focused content { show: table; tallness: 80px; cushioning left: 18px; top: 0; } .u27d99f25625a015b0cb3e9cbadb649d6-content { show: table-cell; edge: 0; cushioning: 0; cushioning right: 108px; position: relative; vertical-adjust: center; width: 100%; } .u27d99f25625a015b0cb3e9cbadb649d6:after { content: ; show: square; clear: both; } READ: Parts of Speech Essay PaperAlthough not painted for sexual want or sensual incitement, and while she is portrayed as a goddess she is dozing lifeless. Compositions of this time were painted by men for men. Giorgione has made the female a subject of onlookers, voyeurs into her private world. We should recollect that for most of human civilisation pictures of ladies depicted in craftsmanship, writing and film have been made by and for men. Ladies were regularly thought of as being stupid, just considering excellence and vanity. Valasquez takes the exemplary picture of the leaning back venus seen on the privilege and shows us a Venus with her back to us, appreciating herself in the mirror, and we perceive how Venus has now gotten assimilated in her own vanity. Specialists playing with the equivocalness of conclusion over the portrayal of ladies. Goyas Naked Maja (painted around 1800) introduced a period where the leaning back naked was not a goddess, princess, courtesan or spoiled lady. The Maja is a lady of faulty personality. It is safe to say that she is someones spouse or darling, a working model simply posturing for cash, or something different? The artistic creation was seized in 1808 by request of King Ferdinand VI of Spain , and in 1813, the Inquisition appropriated the composition as a profane work. In any case, Goyas translation of the naked was later trailed by different painters, particularly in France . Ladies depicting ladies. The Polish craftsman Tamara Lempicka is notable for her Art Deco-styled figures of hot, room peered toward ladies layed in frequenting presents. The historical backdrop of the picture of ladies as sensual items in craftsmanship is unending and, for current eyes honed by the basic bits of knowledge of women's activist idea, perpetually tricky. One can just start to attempt to list what number of ways it has been transformed in the possession of ladies Pre-Raphaelite Art. Through inverse pictures of sexuality and excellence, female subjects have been raised while being detained. These ladies are nearly representation for the position and job that the perfect Victorian female was relied upon to take. The primary pervasive portrayal of ladies in the craftsmanship of this period is that of the Holy Virgin. They are the perfect picture of commitment and uprightness. In Rossettis Ecca Ancilla Domini, the craftsman trys to show the strict hugeness of the Virgin mother.

Exploring the Logic of Experimental Design Statistics Project

Investigating the Logic of Experimental Design - Statistics Project Example bjects configuration is their capacity to build up a connection between a needy variable and various elements and the way that the two plans have a similar number of members in every treatment of a trial (Gravetter and Forzano, 2011). Notwithstanding, while every member in an inside subject structure is exposed to all medicines in an examination, every member in a coordinated subjects configuration is just exposed to one treatment. Relationship in inside subjects configuration is done across medicines while connection in coordinated subjects configuration is done across gatherings of members. So also, subjects are estimated in more than one condition in an inside subjects structure while estimations on members in a coordinated subjects configuration happens just in one state of a test (Gravetter and Forzano, 2011). An experiment’s object is to gather information and build up properties of the gathered information towards determination regarding a matter. An exploratory plan achieves its motivation by giving way to deal with directing the trial (Jackson, 2011). One of the benefits of exploratory plan is its serious extent of interior legitimacy because of randomization impact that dispenses with biasness and causality. It likewise has a high â€Å"construct validity,† particularly when the builds can be controlled (Smith and Mackie, 2000, p. 36). The design’s significant impediment is anyway in its low â€Å"construct validity† under moral contemplations (Smith and Mackie, 2000, p. 36). Control alludes to the control of an experiment’s subordinate variable towards a normal perception. Its motivation is to assistant numerous gathering examination between perceptions in trial and controlled set ups (Jackson, 2011). A bewilder alludes to wild factor in an examination. Trial configuration is a case of a structure that can have three frustrates. A portion of the methods of controlling frustrates are â€Å"use of arbitrary sampling,† â€Å"use of comparable control group,† and blinding of

The Youngs modulus of the copper wire Essay Example for Free

The Youngs modulus of the copper wire Essay Along these lines, having done the primer, I believe that my expectations lie on the right lines. It is ideal to utilize a slight wire, in light of the fact that a thick wire would not extend as much for a similar power, however I need to think about security, in light of the fact that the wire snaps and in light of the fact that it is under pressure, it whips back and can cause some harm if the understudy falls in contact with it. In this way, under these conditions, it is important to wear wellbeing goggles. On the off chance that we are utilizing a thick wire, you will find that we will include an enormous burden. On the off chance that the wire snaps, similar perils would occur as referenced above at the same time, the weight dropping to the floor will make harm the toes and so forth, if the weight falls on the foot, so keep a sheltered separation when the additional heap is included. Try not to ADD THE WEIGHTS QUICKLY AS THE WIRE IS SENSITIVE WHEN THERE IS ALREADY A LARGE FORCE APPLIED ON IT. The vernier scale is delicate, so we need to give specific consideration to how much power we apply, in light of the fact that the most extreme expansion, which can be perused, relies upon the size of the scale. Because of the expansion in the normal cross-sectional zone, which influences the augmentation in the wire, we have to build the precision of the readings by taking rehashes, utilizing distinctive wire of a similar width, and again take estimations of the measurement, with utilization of the micrometer. This builds the unwavering quality of the outcomes and thus the Youngs modulus of the copper wire. The vernier scale technique is considerably more precise than the clasp and pulley strategy, which could have been utilized also, however as we are focusing on exactness it is ideal to utilize the vernier scale technique. The test is to be directed under room temperature, in light of the fact that the temperature of the wire whether cold or hot diminishes the precision of the outcomes, the wire extends increasingly under warm conditions on the grounds that the wire is less solid than if it was in cold or even room temperature of 23 oC. I should assess potential mistakes, for example, the zero blunder in gear, and other irregular and efficient mistakes, which can happen. I will attempt to abstain from making the parallax blunders, (the mistake which happens when the eye isn't put legitimately inverse a scale when a perusing is being taken). This can be made on perusing off a ruler. The understanding blunders (the mistake because of the mystery associated with taking a perusing from a scale when perusing lies between the scale divisions, and the zero blunder (the mistake which happens when an estimating instrument doesn't demonstrate zero when it should), which can be conceivable on the vernier scale. On the off chance that the zero mistake occurs, at that point I will change the instrument to understand zero or the mistaken zero perusing ought to be taken and ought to be included or deducted from some other perusing taken. Now and then the meter rules have worn edges thus I will gauge from 10cm rather than 0cm. As the wire is extended, the width of the copper wire diminishes, we get plastic misshapening before it snaps, for instance in the event that we take a gander at a copper pole as an enormous scope to the slim wire you can see from the underneath that the copper bar necked before it broke. This happens in light of the fact that metals like copper, (above) are bendable they can have huge plastic misshapenings without cracking. It happens on the grounds that molecules move, as the plastic distortion in the precious stone structure move, to place of lower pressure. The copper becomes more slender when iotas move away from the focused on part. The pressure at that point increments on the grounds that the cross-sectional territory is currently diminished. This builds the malleable stream thus the metal yields and gets more slender and more slender. When plastic disfigurement begins, iotas will keep on streaming with no expansion in stress. This extending under a consistent burden is called creep. The diminishing of a wire/pole is called necking. There is additionally the issue that the kg masses may not gauge the given worth, there is a little possibility this would be off base, the best way to discover is by gauging the mass utilizing an electronic scale, which is exact to 0. 001g. Book index Material science For You By Keith Johnson Dictionary of Science By C. Stockley Simmone Hewett C. Oxlade Sue Holt J. Weitheim John Miller Physics 1 By David Sang Keith Gibbs Robert Hutchings Science Desk Reference By Patricia barnes-Svarney www. s-cool. co. uk www. allmeasures. com Encarta 2002 AS Physics Assessed Practical (Skill P) Elasticity of a Copper wire By Priyesh Patel 12O 1 Show review just The above see is unformatted content This understudy composed bit of work is one of numerous that can be found in our GCSE Electricity and Magnetism segment.

Opera Music

Tuning in to a drama is one of the most intriguing traditional music exhibitions you could see live. This hour and a half show I seen was played on Tuesday, November 13, 2012 and performed at 8 p. m. The name play was Wozzeck by Alben Burg and performed by the Philharmonic Ocrhestra. At the show the individual who was assume to be the specialist was sick so Kevin Beurdette assumed Tijil Faveyls position. The individuals that went to the show fluctuated, a few people were more seasoned and others were youthful. The sort of class of individuals that appeared at this show was not explicitly observed on the grounds that the greater part of the individuals that showed where dressed formal-casual.This show had no unique event to it however close to the way that it was a required class meeting at the Disney Concert Hall. The drama had a full ensemble. During this drama execution none of the entertainers had ensembles on nor was the stage set up for an acting show. The scenes performed were all up to the on-screen characters; they remembered the play and afterward extemporized their following up on set. The Doctor acted by Burdette needed to truly ad lib his part. Each opportunity he turned out in a scene he conveyed the content with him out on stage.This show was in German and there were surr-titles rather than captions. The crowd giggled during the drama and they were to have a feeling of relationship with play. Since it was a play the crowd possibly hailed when the drama was finished. The play Wozzeck was a play that not wrapped up by Georg Buchner and Alban Berg completed his play. This play is hampered in World War I. It is an anecdote about officer â€Å"Wozzeck† who is enamored with a whore and she is the mother of his child. Wozzeck can't address her issues monetarily, so he partakes in the doctor’s experiment.The tests begin to cause him to daydream and hear thing. On the mean while his significant other is taking part in an extramarital entangle ments with a drum major and plans to be with him. Wozzeck gets dubious of her and afterward specialist and commander entice Wozzeck to take care of. He at that point begins to have insane dreams of her and the drummer. So he goes ahead on murdering her and afterward he himself suffocating on the grounds that he needs to conceal the blade far into the water so nobody could discover it. This terrible play is formed by Esa-Pekka Salonen at the Disney Concert Hall. It is a 3 section play that is approximately an hour and a half long.Salonen has been with the Los Angeles Philharmonic Music Director from 1992 until 2009. The play has a symphony of fifty individuals and off set ensemble which was the UC Berkley chamber tune that played outside so as to set the state of mind of a dream. The characters Marie and Wozzeck had solo’s, during the play each character sang in order of the music the surface of this play is homophonic and polyphonic. Other than about the way that two primary characters had solo’s there was a gathering of youngsters that came out to sing. ZacharyMimis the offspring of Marie had a little solo toward the finish of the play.The rhythm in Wozzeck vacillated as certain scenes where harrowing or some were troubling. During the play dynamic complexity was played in line with the beat. All suddenly the 2 bassoons would play truly quick and uproarious and different occasions play truly moderate. The music in the play was common and not terrified music. The show Wozzeck was an extraordinary presentation; I didn't go in with high expectations simply because what my perspective on a drama was not for it. At whatever point I think about a drama I think about some fat women wearing a Viking cap and looking like fighters.This show was somewhat extraordinary on the grounds that every entertainer had an unmistakable character that was clearly observed. The chief was an insane character, his acting put him as one of my top picks. His collaborating with Wozzeck in light of the fact that he would ridicule Wozzeck for being an insane crackpot and poor. One thing that I saw about the music was that occasionally when a character would sing they would not be in line with music yet then end it in order. The music had concentrated minutes that astonished me with excitement.The play was additionally interesting a result of the word decision utilized so as to ridicule a character. Resulting in these present circumstances drama was another experience I delighted in the presentation I was unable to sit still since I was becoming weary of sitting. The seat that I sat in was perhaps the best seat that I have had there. The sound quality that was created was extraordinary and you could see all of what the characters where doing. In spite of the fact that it was a piece diverting to be gazing toward the surr-contents it was an encounter I won't overlook. I am unquestionably happy I gotten the opportunity to see a show this way.

The Content Review of the Website - As You Sow Article

The Content Review of the Website - As You Sow - Article Example The creator is trustworthy enough given the strategy wherein the data has been ordered and spoken to given additionally this is an enrolled cause. Additionally, this data has been gotten from authentic sources so this loans more prominent validity to it. The data spoke to on this page is just mostly complete as it covers open constrained organizations in enormous part. Notwithstanding, the precision of the data isn't contestable as the creator has included references to his wellspring of data. The creator has introduced the viewpoints of his association on corporate social duty utilizing appropriately refered to authentic sources including reports and gathering procedures. References to the data are inescapable all through the report and the creator has made it a point to reinforce his contentions by introducing references before propelling his contention. The record and the site are both refreshed given the condition of the issues recorded. What's more, the site shows current issues from 2012 in its menu which additionally focuses to the way that the site is routinely refreshed. The present page on corporate social duty tends to the issue from an assortment of points of view. The creator initially characterizes corporate social obligation and afterward relates corporate social duty to manageability. This is trailed by a conversation of socially dependable speculators and corporate social obligation. At last, the creator relates worldwide announcing rules for corporate social obligation and the archive closes with a connection for advisers for corporate social duty reports and assets.

Presenting College Essay Academy, Your Complete Video Guide to the Admissions Essay - College Essay Advisors Admissions Essay Experts

Presenting College Essay Academy, Your Complete Video Guide to the Admissions Essay - College Essay Advisors Admissions Essay Experts Presenting College Essay Academy, Your Complete Video Guide to the Admissions Essay Presenting College Essay Academy, Your Complete Video Guide to the Admissions Essay If you’ve ever spent any time wondering what we get up to over the summer before the Common App comes out, wonder no more! We are very excited to announce the release of our first ever complete video guide to the college admissions essay: College Essay Academy is a process-driven, advice-filled, fully animated webseries that teaches the art of writing the college admissions essay, equipping students with the tools to tackle this assignment with the confidence of a caped superhero and the finesse of a professional keyboard-playing cat. This ten-chapter video series takes you through The Uncommon Essay Approachâ„¢, a step-by-step process for unearthing unconventional ideas, sculpting inventive narratives, and polishing the final draft of your college admissions essays to a high shine. If this sounds good to you, (1) you are very smart and (2) now is a great time to get started! Chapters 1-6 just dropped today and chapters 7-10 will come out on August 1 (along with the Common Application). Tell your friends! About Thea HogarthView all posts by Thea Hogarth »

The Cyanamid test - Free Essay Example

Introduction Interim (a.k.a. interlocutory) prohibitory injunction is a court order that forbids the person it is addressed to do something. It is an equitable remedy and is awarded at the discretion of the court. The famous guidelines for granting the interim injunctions by the court were introduced by Lord Diplock in the case of American Cyanamid Co v Ethicon Ltd[1] (hereinafter the Cyanamid test). The above case concerned the claimant, a US company marketing synthetic surgical sutures, which was finally granted an injunction by the House of Lords to restrain the defendant, an English company, which invented a similar product, from infringing its patent rights. This work aims to analyse the argument that the Cyanamid test is too rigid prompting the courts to create a number of exceptions. The Cyanamid test Lord Diplock introduced the following elements of the Cyanamid test to be satisfied in order for the court to grant interim prohibitory injunction[2]: Serious questions to be tried Firstly, the claimant is required to show to the court that its claim has substance, i.e. that it is à ¢Ã¢â€š ¬Ã…“an issue for which there is some supporting material and the outcome of which is uncertainà ¢Ã¢â€š ¬Ã‚ [3] rather than a frivolous claim[4]. Adequacy of damages If the first element is satisfied, the court will then look into whether the damages awarded to the claimant or to the defendant, if the latter wins, are adequate to do justice (Garden Cottage Foods Ltd Milk Marketing Board[5]). Where damage is hard to quantify or in the case of irreparable harm, the injunction is likely to be granted (Allen v Jambo Holdings Ltd[6]). Balance of convenience If there are any doubts regarding the adequacy of damages, the balance of convenience will be looked at by the court à ¢Ã¢â€š ¬Ã…“balancingà ¢Ã¢â€š ¬Ã‚  all other issues specific to the case. Subsequent treatment of the Cyanamid test The decision in the Cyanamid case caused some turbulence in the subsequent court decision making. However, before proceeding with analysis of the same, it is essential to note that the Cyanamid test comes into a conflict with earlier Beecham Group Ltd Bristol Laboratories Pty Ltd[7], where the court emphasised that for the injunction to be granted, firstly, the claimant must establish à ¢Ã¢â€š ¬Ã…“prima facie caseà ¢Ã¢â€š ¬Ã‚ , i.e. that the claimant is actually entitled to the right he is claiming and, secondly, the proof of the probability of success was required, which is overall a much tougher test to satisfy than the Cyanamid test. Subsequently, the Cyanamid test was closely followed by the courts in a number of cases, such as Alfred Dunhill Ltd v Sunoptics[8], where Browne LJ stated that Lord Diplockà ¢Ã¢â€š ¬Ã¢â€ž ¢s decision was binding and that the Cyanamid test should be followed. The court in Thomas Marshall (Exports) Ltd v Guinle[9] followed the Cyanamid test as well, but nonetheless noted that there are some cases where the needs of the parties and justice dictate a more comprehensive hearing with Beecham style test applied. When analyzing the Lord Diplockà ¢Ã¢â€š ¬Ã¢â€ž ¢s rationale behind the Cyanamid test it appears that he tried to ensure the speedy review of the injunction applications and to prevent the occurrence of unnecessary à ¢Ã¢â€š ¬Ã…“mini-trialsà ¢Ã¢â€š ¬Ã‚  burdening the court system (Series 5 Software Ltd v Clarke[10]). Some commentators argue that he went too far in setting out very precise rules on assessing the strength of partiesà ¢Ã¢â€š ¬Ã¢â€ž ¢ cases, the potential harm to the parties despite alternative legal resorts and availability of undertakings in relation to payments of damages, which was limiting the exercise of the courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s discretion to do justice[11]. In order to ensure the equitable treatment of all cases, courts tended either to side-step the Cyanamid test or create exceptions to it. It was distinguished in Bryanston Finance Ltd v de Vries (No 2)[12] by the Court of Appeal, which decided that the Cyanamid test was inapplicable to injunction application to prevent presentation of winding up petition. Keay in his article[13] provides a number of further examples of exceptions, such as cases where fraud is involved (Alfred Dunhill Ltd v Sunoptics[14]) and those relating to the right to publish an article or the transmission of a television programme where time is of the essence (Cambridge Nutrition Ltd v BBC[15]), mandatory injunctions applications (De Falco v Crawley BC[16]) and employment and industrial disputes (Attorney-General v Punch Ltd[17]). Interestingly, one of the exceptions was introduced by Lord Diplo ck himself in NWL Ltd v Woods[18] where he accepted that the Cyanamid test should not be adhered to if the interim hearing was going to be decisive and final. This is a very important exception as Lord Denning M.R. in Fellowes Son v Fisher[19] mentioned that à ¢Ã¢â€š ¬Ã…“after a decision on an interim injunction application the matter goes no further in 99 out of 100 casesà ¢Ã¢â€š ¬Ã‚  [20]. Besides the exceptions, it appears that the courts in some cases felt that the à ¢Ã¢â€š ¬Ã…“prima facieà ¢Ã¢â€š ¬Ã‚  test worked better and in Fellowes Son v Fisher[21] Browne LJ was particularly concerned that it was not possible to consider the balance of convenience fairly and equitably without taking into account the merits of the case[22]. On another note, Meagher argued that it is doubtful that the damages can actually be adequate in cases where the remedy of injunction is sought[23]. Indeed, the injunction is generally applied for in specific, sometimes extreme, cases to prevent the applicantà ¢Ã¢â€š ¬Ã¢â€ž ¢s potential hardship, undermining of its reputation, loss of its customersà ¢Ã¢â€š ¬Ã¢â€ž ¢ trust or loss of its business relationships and it is hard to imagine how the damages can be adequate if any of the above happens. Again, this should all be left to the courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s discretion in order to allow it to do what is just and equitable. Recent considerations Since the introduction of the Civil Procedure Rules and the ensuing change of approach towards the case management, it is claimed that the Cyanamid test is not as critical as it once was, mainly because the Rules place, among other things, greater emphasis on identifying and resolving issues likely to go to hearing as early as possible[24]. In addition, following the implementation of the Human Rights Act 1998, the court in Cream Holdings Ltd v Chumki Bannerjee The Liverpool Daily Post Echo Ltd[25] held that the Cyanamid test is no longer applicable to injunction a pplication relating to the freedom of expression[26]. Conclusion The Cyanamid test is a good example of the battle happening in the courts on the most equitable methods to be used to decide the interim injunctionà ¢Ã¢â€š ¬Ã¢â€ž ¢s application, which are generally either on the merits of the case (the prima facie case) or on the balance of convenience (the serious question). It was argued that some bits of the Cyanamid test were considered too rigid and limiting the courtà ¢Ã¢â€š ¬Ã¢â€ž ¢s discretion in doing justice. As a result, whilst the Cyanamid test was acknowledged and in some cases followed by the courts, it has been frequently either avoided or subject to various exceptions, altogether with ensuing criticism and academic debate. Following the introduction of the Civil Procedure Rules, the Cyanamid test seem to have lost its edge and the Human Rights Act 1998 disapplied its application to the cases involving freedom of expression. However, at the end of the day, the Cyanamid test should not be treated à ¢Ã¢â€š ¬Ã…“as rules but only as guidelinesà ¢Ã¢â€š ¬Ã‚ [27]. As such, they seek to bring more flexibility rather than limit the discretion given to the court by equity (R v Secretary of State for Transport, ex parte Factortame Ltd[28]). Bibliography Meagher R et al, Equity à ¢Ã¢â€š ¬Ã¢â‚¬Å" Doctrines Remedies, 4th ed., LexisNexis Butterworths, Charswood, 2002 McGhee J, Snellà ¢Ã¢â€š ¬Ã¢â€ž ¢s Equity, 31st ed., Sweet Maxwell, London, 2005 Spry I, The Principles of Equitable Remedies: Specific Performance, Injunctions, Rectification and Equitable Damages, 7th ed., Sweet Maxwell, London, 2007 Cumming G, The Use of English Civil Procedure in order to Enforce European Competition Law, Civil Justice Quarterly, 25, 2006, 99-112 Keay A, Whither American Cyanamid?: Interim Injunctions in the 21st Century, Civil Justice Quarterly, 23, 2004, 133-151 1 Footnotes [1] [1975] AC 396 [2] American Cyanamid Co v Ethicon Ltd [1975] AC 396, at 408, per Lord Diplock [3] Cayne v Global Natural Resources Plc [1984] 1 All ER 225 [4] Meagher R et al, Equity à ¢Ã¢â€š ¬Ã¢â‚¬Å" Doctrines Remedies, 4th ed., LexisNexis Butterworths, Charswood, 2002, p.779 [5] [1984] AC 130 [6] [1980] 1 WLR 1252 [7] (1968) 118 CLR 618 [8] [1979] F.S.R. 337, at 365 [9] [1979] F.S.R. 208 [10] [1996] 1 All E.R. 853 [11] Spry I, The Principles of Equitable Remedies: Specific Performance, Injunctions, Rectification and Equitable Damages, 7th ed., Sweet Maxwell, London, 2007, p.466 [12] [1976] Ch 63 [13] Keay A, Whither American Cyanamid?: Interim Injunctions in the 21st Century, Civil Justice Quarterly, 23, 2004, 133-151, p.139 [14] [1979] F.S.R. 337 at 363 [15] [1990] 3 All E.R. 523 at 534 [16] [1980] 1 Q.B. 460, CA [17] [2003] 1 A.C. 1046 [18] [1979] 1 W.L.R. 1294 at 1306 [19] [1976] Q.B. 122 [20] ibid, at 133 [21] [1976] QB 122 [22] ibid, p.139 [23] Meagher R et al, Equity à ¢Ã¢â€š ¬Ã¢â‚¬Å" Doctrines Remedies, 4th ed., LexisNexis Butterworths, Charswood, 2002, p.780 [24] Keay A, Whither American Cyanamid?: Interim Injunctions in the 21st Century, Civil Justice Quarterly, 23, 2004, 133-151, p.151 [25] [2003] 2 All E.R. 318 [26] This is because s.12 of the Human Rights Act 1998, which incorporated the European Convention on Human Rights into English law, provides that no relief, including injunction, restraining the freedom of expression à ¢Ã¢â€š ¬Ã…“is to be granted so as to restrain the publication before trial unless the court is satisfied that the applicant is likely to establish that publication should be allowedà ¢Ã¢â€š ¬Ã‚ . In these circumstances, the Cyanamid test would be unsuitable (Cumming G, The Use of English Civil Procedure in order to Enforce European Competition Law, Civil Justice Quarterly, 25, 2006, 99-112, p.107 ). [27] Cayne v Global Natural Resourc es plc [1984] 1 All ER 225 at 237 [28] [1991] 1 AC 396