6-sigma Essay Example | Topics and Well Written Essays - 750 words

6-sigma - Essay Example The procedure is normally used in the assembling forms in trying to limit fluctuation of items and upgrade the quality through progress of the business forms. The six-sigma approach uses different quality administration techniques like insights in the advancement of value improvement approaches inside the assembling business. The term stays interchangeable to the assembling terms related with the demonstrating of the assembling procedure through the use of factual procedures. The procedure targets guaranteeing items remains item free, which is fundamental in deciding the viability of the assembling procedure. The sigma level is usually estimated through the level of identify free items. The sigma procedure remembered for the assembling procedure follows an unmistakable succession of exercises planned for accomplishing quantifiable creation targets. Viable accomplishment of the objectives turns into a proportion of the viability accomplished in the usage of the sigma procedure of the executives. The crucial reason for the selection of the six-sigma approach remains the decrease of inconstancy in the items. The inconstancy characterized by the six-sigma approach stays dependent on the event of imperfections upon the items. The quantity of deformities identified upon the items turns into the evaluating component in building up the viability of the creation improvement process (Montgomery and Woodall, p331). This outcomes in the decrease of the deformities to a level that the event of disappointment or imperfections turns out to be practically unimaginable. The procedures used in the improvement of the assembling procedure comprise of five stages that dependent on the activities received by the association. The procedures engaged with the six sigma incorporate the accompanying components Characterize †this can be e characterized as the meaning of the different ascribes which are relied upon to be accomplished through the execution of the six sigma approach. This

Killing Without Emotions Essay Example for Free

Murdering Without Emotions Essay This human instinct of our own makes us think or stops us so as to slaughter without feelings. When people are designed to be sympathetic and merciful not to slaughter, it is difficult to comprehend why there is such a great amount of executing on the planet? How, with sympathy and empathy, can individuals execute? They should abrogate their feelings with more grounded feelings of despise and ideas of direction dependent on their convictions. In the accompanying sections will introduce hardly any models that will demonstrate why and how a few people supersede their feelings with more grounded feelings dependent on their motivation. A typical case of this is of a self destruction aircraft. So how these self destruction planes are shaped or what is the brain research required behind self destruction besieging. . Regularly the self destruction aircraft captured in Pakistan are normally young people and are from a poor foundation. They are generally seized on their approach to class or madraassa (strict school) and afterward indoctrinated. Research and Today’s media uncovers that self destruction aircraft utilizing their religion as a shield legitimizes what they are doing are correct. During indoctrinating they are kept confined and given deluding data on the name of the religion. They are told by the degenerate strict pioneers that executing of the non Muslims are supported by their religion. Notwithstanding this they are likewise informed that perishing for the sake of their religion will gain them the position of a martyred. They are additionally programmed that they will gain a high position in the sky and waterways of milk and nectar and excellent virgins anticipate. (Yusufzai and Jamal). They are extended to significant expense to take care of business. They are guaranteed that their family will live well off life after their activity is finished. Practically 90% of the self destruction aircraft are ordinary people be that as it may, subsequent to knowing the position they can win by kicking the bucket for the sake of their religion, change their feelings to slaughter several guiltless people. From this above model it tends to be inferred that they straightforward defeat their feelings with more grounded feelings of acquiring high position in Heavens by biting the dust for the sake of the religion, making sure about the lives of their family and complying with the sets of God. Another sort of the individuals who supersede their feelings to execute are the warriors. Officers supersede their feelings for specific reasons that they master during the preparation. During the preparation there are informed that they are the defenders of the land. The lives of their families and their comrades rely upon them. In addition, they are prepared with the way that what they are doing is correct and advocated and God is with them. The preparation for the warriors keeps on the changing with time to time. The officers are given finished preparing/rehearsing territory. The fighters are desensitized by making them take shots at human molded paper targets, drill and afterward to moving targets and spring up targets look sort of human shape making their reaction programmed and focused†. (Dwyer). The preparation regions incorporates a wide range of troublesome pathways, underground passages and abrupt appearance of the human molded targets which they have take shots at an d bring them down. They are additionally saluted on their first execute which expands their certainty to abrogate their feelings all the more effectively â€Å"In option to this there are tended to legitimately causing them to accept that they really need to murder. (Robinson). â€Å"Often multiple times the present the foes in way that doesn't feel like a human; for example they will consider their adversaries by those names that even don’t look natural. Names like â€Å"gook† who realizes what is gook? It doesn't seem like a human or an individual. Half of the desensitizing and dehumanizing is made simpler in introducing an individual that doesn't even to our group or kind. Also, saying that God is with us, we are battling for our nation and the individuals and God is glad for us. A great deal of slaughtering is made simpler in this for the warriors introducing these as an explanation. † (Pomerantz) So, with this sort of preparing and exercises of enthusiasm being given to the warriors makes it simpler to supersede to their feelings. In the end I would rehash again that executing without feelings is extremely hard except if you have you don’t conquer your feelings. It takes a great deal of nerve and heart to slaughter without feelings. Works refered to Dwyer, Gwynne. Officers prepared to slaughter and post-horrible psycho-jibber jabber. Thuppahis blog, 29 April 2011. Web. Web. 18 Feb. 2013. Yusufzai, Asfaq, and Amna Nasir Jamal. Young people selected, prepared as self destruction aircraft.  Central online Asia. N. p. , 11 04 2011. Web. 18 Feb 2013. Robinson, Steve. The effect of executing and how to set up the troopers .  Frontline. Cutting edge, 01 Mar 2001. Web. 18 Feb 2013. Pomerantz, Andrew. The effect of murdering and how to set up the fi ghters .  Frontline. Bleeding edge, 01 Mar 2001. Web. 18 Feb 2013.

The Music Of Mozart Essays - The Jilting Of Granny Weatherall

The Music Of Mozart What are the contemplations that experience the brains of the individuals who close to death? These are the issues at the core of A Clean, Well-Lighted Place composed by Ernest Hemmingway and Katherine Porter's The Jilting Of Granny Weatherall. The fundamental focal point of A Clean, Well-Lighted Place is on the torment of mature age endured by a man that we meet in a bistro late one night. Hemingway differentiates light and dim to show the distinction between this man and the youngsters around him, and utilizations his deafness as a picture of his partition from the remainder of the world. Also, in The Jilting Of Granny Weatherall, Porter talks about the second thoughts of an elderly person uncovered by her responses to her being left at the special raised area and her moderate passing sixty years after the fact. Close to the finish of the two stories, the creators show us the urgent vacancy of a real existence close to completed without its reward for all the hard work, and the irr itation of the old eager psyche that can't discover harmony. All through the tales unmistakable pictures of urgency show the lives of the two primary characters at a moment that they have understood the worthlessness of life. In the story, The Jilting of Granny Weatherall, composed by Katherine Porter, Granny Weatherall is a character of profundity. Her name is synomonous with her character. Three fundamental characteristics of her character are her quality, her continuance, and her powerlessness. Her quality isn't so much physical however mental. She lies upon her bed thinking about all that she needs to do. Her little girl Cornelia doesn't verge on dealing with issues just as she does as far as she could tell. What's more, she tell the Doctor Leave a well ladies alone...I'll call you when I need you. She doesn't care for the disparaging position that she ends up in. The way that she has just dodged passing once appears to add to her picture of solidarity. As we follow her psychological ramblings we get understanding to her character as a lady that has persevered through grief just as hardship. She has figured out how to endure the lost of a kid just as being left at the adjust - twice. In any case, when we understand that Death has stayed with Granny Weatherall she is left helpless against an issue that isn't up for conversation. She states likewise that she needs to consume her letters so as not to seem delicate to her youngsters if they should understand them. The whole setting likewise delineates Granny as helpless and needing help. Music

Types of Argumentative Essay Topics

Types of Argumentative Essay TopicsCurrent argumentative essay topics fall into one of two categories, contemporary and historical. Contemporary essay topics are basically centered on the most recent issues of our time. These topics might include issues that pertain to the domestic situation or to the international community as a whole. Historical essays deal with any historical figure or event from the past that relates to the present day situation.Contemporary essay topics usually have to do with social change. However, this is not always the case. In fact, some essay topics might simply deal with current news and happenings in the world today. While some contemporary essay topics are truly biographical, others may take the form of an analysis of some statement made by a current political figure in order to determine whether or not that statement is accurate.Contemporary essay topics might include sports. This includes everything from politics to labor unions to the Olympics. It ca n also include popular television shows and films. Cultural changes may also be included, as might recent trends in fashion, food, music, and the media. One form of contemporary essay topic might include current events such as the current Olympic Games, the recent presidential election, and even the upcoming general elections.Historical essay topics focus on events that occurred in the past. As an example, this could include the overthrow of a foreign government, a new leader's ascension to power, the downfall of a popular president, or any number of political catastrophes. Other historical essay topics may include the rise and fall of a group of scientists who invented the blackboard. They also might include popular inventions or historic events that were fairly recent, such as the invention of the Internet. Historical essay topics might also include events that happened while the author was alive.Recent work is one form of current essay topics. This could include anything from the latest movies to academic research. These topics might also cover current events, such as the status of global warming, the upcoming election, or whether or not the United States is going to be the next country to break out into another war. Recent work, of course, can be difficult to explain in a short essay. In this case, it might be better to give more space to explaining things in greater detail later in the essay.Historical essay topics will include a history of any situation or event that pertains to the present day. Some topics might take place while the writer was alive. These might include aspects of the American Revolution, the Civil War, the overthrow of the American government, the assassination of a president, and other notable events that were happening during the time the essay was written.Some of the best current essay topics are ones that deal with current political figures. The best way to remember these essay topics is to try to anticipate the major political deb ates that will be occurring at the time the essay is written. In addition, it is very important to avoid overdoing things like too much historical detail or too much personal detail.

How Stress Affects The Body Health - 1838 Words

Ever wonder why people get stressed out either if it’s School, Marriage, work, and family? Or some good stress for example is a job promotion, buying a new house, and getting married. Stress can also affect the body health for example it can lead to cancer and cardiovascular disorders. All the stress the person can’t let go will hold on to the person in some form of guilt or regret and they will think about it over and over again and make scenarios in their head. When people are mostly stressed they usually drink alcohol or smoke tobacco to release stress and forget things for a while and enjoy it. That’s when people start getting addicted to alcohol, drugs, and tobacco. There is treatment for that for example to have a strong personal motivation and stop what they’re doing and try new things. One big stress is called PTSD which is called posttraumatic Stress Disorder, it means it’s an anxiety and traumatic experience, an example would be if a per son went to war, and after they came back from the war they can get flash backs and remember the event what happened and can’t stop thinking about it, another example would be a near-death experience where probably someone got in a car accident and almost died and survived the accident and they get flashbacks and have regret of what they should have done. When dealing with stress some symptoms can be being tired, muscle ache, gain or lose weights, and thinking about the problem a lot in the head and can’t concentrate at all. SomeShow MoreRelatedEssay on Coping with Stress at Work1593 Words   |  7 PagesStress at Work There are many jobs in the world and many professionals carrying them out. Every worker has a task to complete and it isn’t always easy. Jobs can demand a lot and specific deadlines of when things need to be done. Some jobs require workers to have more than just one responsibility. Meeting deadlines and being responsible of other tasks can be a bit stressing at times. Stress is not only at home but it is also suffered in jobs, some more than others. Many workers experience job stressRead MoreStress And Health : Can Stress Affect A Person s Health? Essay1567 Words   |  7 Pages Stress and Health Can stress affect a person’s health? It’s a very good question. There have been a lot of studies done on the effects of stress on health. Stress comes in so many forms and can affect people differently. Some short-term types of stresses can actually benefit the immune system while other long-term types of stresses can be detrimental to it. The long-term types of stresses are what will be focused on. Learning how to deal with stress in better ways can help prevent the damageRead MoreStress : How Is It Affecting You739 Words   |  3 PagesMarysa Knudsen Mr. Hisner English 111 8 September 2016 Stress: How is it Affecting You Many of us are familiar with the word stress. And for most of the billions of people who live on earth there is a time or a place that we associate with stress. For you it could be school or a job or a death in the family or certain responsibilities. No matter the cause stress can affect you in two different ways: positively or negatively. Stress begins with the brain releasing the hormone CRH. The CRH tellsRead MoreHow Stress Affects Our Health937 Words   |  4 PagesStress, it is one of the most common topics discussed between friends, family and co-workers. Most of us understand that stress can affect our health. But do you really understand how stress, if left unchecked, but cause issues with your mind and even your body? When you are finished reading this paper, my goal is for you, the reader, to have a better, more clear understanding of how stress affects the body and mind, and how to manage your stress so your can reduce these affects. Read MoreHow Stress Affects Physical Health1288 Words   |  6 PagesHow to relieve stress physically amp; How Stress Affects Physical Health People are increasingly facing more stress since the Human-Being society became developed and complicated, by ignoring the physical influence to our body, Human’s health suffered considerably from stress. Many people was suggested to solve the stress problem by using psychological approaches, however, the research in recent decades has identified a significant awareness gap between the benefits of physical activities and stressRead MoreStress And Its Effect On The Body1322 Words   |  6 PagesStress and its Role in the Body People have very different ideas with respect to their definition of stress. Probably the most common is, â€Å"physical, mental, or emotional strain or tension†. Another popular definition of stress is, â€Å"a condition or feeling experienced when a person perceives that demands exceed the personal and social resources the individual is able to mobilize.† (stress.org). Most use stress as a negative condition that causes people to breakdown and become frustrated. This isRead MoreStress And Stress1465 Words   |  6 PagesStress has a major influence upon one’s health, thinking, behavior, and mood. Stress is commonly mistaken for generally evoking negative associations; however, it is actually part of the human experience that places pressure on people so that they may be able to perform at a higher level achievement. Nonetheless, when stress becomes too much to handle, or becomes chronic, it can affect an individual physically, mentally, behaviorally, and emoti onally. 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It is important have a healthy body, sound emotional state, and solid psychological state to learn and perform at the highest level of capability. The psychological aspect builds upon the emotional, and emotional upon the physical.Read MoreStress And Its Effect On The Body, Mind, And Spirit853 Words   |  4 PagesStress affects everyone at some point. Generally, stress affects an individual in numerous ways including physical manifestations of stress such as pain or illness. The way in which a person responds to stress depends on varying factors, but no two people experience stress in the same way. Treat stress holistically due to its impact on the body, mind, and spirit. A wellness coach is a great asset in learning to cope with stress through modifications in lifestyle and behavior as well as different

Huckleberry Finn American Literature And Culture

Ariella Kerendian English: American Literature and Culture The Boy Who Couldn’t Tell the Truth As kids grow and mature through the different stages of life, they live through experiences which help them create a moral and ethical identity for themselves, based on honorable values. Huckleberry Finn and Tom Sawyer are the first kids depicted in American literature, and through them, Mark Twain develops the concept of kid, by having them participate in comical manipulation and deception. The Adventures of Huckleberry Finn has two principal lies, imaginative lying and deceitful lying. Lying and deceit are central themes Twain uses to develop the blueprint of a child. Tom Sawyer, Huckleberry Finn, and the King and Duke involve themselves in†¦show more content†¦Huck and Tom mastered the definition of youth; savage, fearless, adventure loving, witty, clever, and masters of their environment by means of lying. A lie is described as â€Å"a false statement or action, especially one made with intent to deceit others†, and this definition is brilliantly depicted through Twain’s characters within the novel. Huckleberry and Tom are portrayed as youthful fourteen year olds, while one is characterized as a kid, the other is considered a child, respectively. While they are similar, there are distinguishing difference between a kid and child. Tom Sawyer is the perfect child character. Mark Twain highlights Tom’s character as a perfect depiction of a child; a vivid imagination, as he portrays what he reads in books to his imagination. Being the leader of his gang, Tom was regarded with respect as he mastered a leadership role all kids aspire towards. Tom grew up in a civilized home, where he was to behave properly and politely, yet he was still a free-natured kid that loved risk and adventure. Tom was daring, imaginative, and inventive, and he created an imaginative world of robbery and fun, a world where no one actually got hurt as he explains, â€Å"We played robber†¦we hadn’t robbed nobody, we hadn’t killed any peopl e, but only just pretend† (41). His lies were just plain fun, with no intended harm, but his own amusement, showing thatShow MoreRelatedMark Twain : Seeing America s Flaws1593 Words   |  7 Pagesbook, The Adventures of Huckleberry Finn. Samuel L. Clemens, as a young boy, grew up on the Mississippi and learned the ways of southern society. Clemens grew up to travel the world and write many successful and failed novels, along with many other types of literature. Receiving his education on the Mississippi, Mark Twain wrote The Adventures of Tom Sawyer and The Adventures of Huckleberry Finn which pointed out the flaws of America and became masterpieces in American Literature. Samuel L. ClemensRead MoreEssay on Prejudice and Racism in The Adventures of Huckleberry Finn833 Words   |  4 PagesPrejudice and Racism in The Adventures of Huckleberry Finn      Ã‚   The Adventures of Huckleberry Finn, by Mark Twain, is an excellent example of racism in literature, because it uses language describing African Americans which goes beyond satire.   It treats them as objects and perpetuates stereotypes. It does not expose and deal with racism, as many advocates of its reading claim, but encourages an attitude of superiority that is unnecessary and intolerable. In order to ridRead MoreHuckleberry Finn Persuasive Essay1571 Words   |  7 Pagescontroversial novel; The Adventures of Huckleberry Finn had a great way of capturing moments in time and bringing them to life through the use of meaningful and direct diction. The Adventures of Huckleberry Finn has been a vexed novel for it s a use of the â€Å"N-word†. However, many scholars and associations have devised a â€Å"solution† for this problem such as, completely banning the book, creating sanitized versions, or even replacing the book for another American literature novel. â€Å"What is so wrong about thisRead MoreShould the Adventures of Huckleberry Finn Be Required in Shcool?983 Words   |  4 PagesThe Adventures of Huckleberry Finn be required in school? Mark Twain’s â€Å"The Adventures of Huckleberry Finn† is said to be one of the greatest American novels to ever be written and is what all other pieces of American literature are based off of. The novel has been debated for over an entire century and will continue to be debated for much longer. Never the less, Huckleberry Finn teaches young students and adults the important life lessons. †The Adventures of Huckleberry Finn† by Mark Twain shouldRead MoreRegionalisms Impacts on America, Especially The Adventures of Huckleberry Finn by Mark Twain651 Words   |  3 Pageswith unique settings and accents. In American literature, Regionalism was invented to better convey the aspects of one region in a novel. Regionalisms impact on America can be measured through its popularity in the 1930s, unique writing style, and ongoing influence on writers today (Brooks 1960). According to the Oxford Dictionary, Regionalism refers to Regional quality, character, or distinctiveness; regionality; esp. the expression of this in literature, art, etc.(Oxford Dictionary, 2014) WhileRead MoreAnalysis Of Mark Twain s Works Made A Huge Impact On Readers And Literary Critics1288 Words   |  6 Pages2/26/17 P:2 Outline Mark Twain’s works made a huge impact on readers and literary critics. His writing occurred during both the romantic and realist time eras in American Literature. He has simple, seemingly artless narrators and an understated style leads readers to arrive at the social commentary of his narratives on their own. Mark Twain’s writing influenced society because he created a new perspective on life with the views pointed out in his books. The distinctive trait of Twain s was hisRead MoreHuckleberry Finn Too Offensive For School?880 Words   |  4 PagesHuckleberry Finn too Offensive for School? A widely debated topic concerning, Mark Twain’s classic Huckleberry Finn centers on its content which may or may not be too offensive to be allowed on public school reading lists. The NAACP and concerned parents want Huckleberry Finn â€Å"removed from mandatory reading lists, for the books damaging effects on African-American students† (Hentoff 98). The book did not get removed; in â€Å"1998 Judge Reinhardt wrote: ‘an important part of education is thinking criticallyRead MoreAmerican Experience in Huck Finn1737 Words   |  7 Pagesâ€Å"All modern American Literature comes from one book by Mark Twain called Huckleberry Finn..† claimed Ernest Hemingway, a American author and journalist. This quote represents the idea and perception of Huckleberry Finn as a defining moment in American Literature, a time when a new culture was being formed west of the Atlantic that had many different subjects and characteristics than that of the literature in Europe. Wh at makes The Adventures of Huckleberry Finn so original and such a representationRead MoreThe Adventures of Huckleberry Finn by Mark Twain870 Words   |  3 PagesThe Adventures of Huckleberry Finn,† by Mark Twain, is considered to be one of the greatest American works of art. The novel was published in 1885 and was â€Å"one book from which all modern American literature† came (Ernest Hemingway). The novel was so powerful because it introduced new ideas into book such as the vernacular language and strong expression of racism. As being one of the greatest American novels, it was one of the most controversial. This novel has faced banishment from schools andRead MoreHuckleberry Finn Should Not Be Banned1404 Words   |  6 PagesWhy The Adventures of Huckleberry Finn Should Not Be Banned â€Å"Banning books gives us silence when we need speech. It closes our ears when we need to listen. It makes us blind when we need sight,† Stephen Chbosky. Books open up people’s minds to new ideas and allow people to the world in a new light. Banning books only makes one want to read those books more- to learn and poder over the controversial issues. One controversially banned novel is the The Adventures of Huckleberry Finn. This book while still

Case Study on Commercial Law

Question: Mark, Peter and Mary were out on a Saturday night celebrating the successful formation of a new business venture. They went to a special restaurant up in the hills, Hilltop Point, to mark this occasion. After a great night of eating and drinking, they decided to continue their party at Watchout Point, a scenic hilltop spot with a spectacular view of the city. On their way, they stopped at a bottle shop to buy 2 bottles of premium French champagne. When they reached Watchout Point, they parked the car at the car park which was located at the top of the cliff. There was a 2 meter fence to prevent people from going beyond that point as it was not far away from the cliff edge. There were no warning signs but the cliff was very visible. Anyone can very clearly see the cliffs. In fact, the cliff was part of this beautiful scenery which attracted visitors. At first, the trio sat in the car and chatted and drank champagne. As the night progressed Peter, who had too much to drink, got out of the car and dared the others to climb over the fence and walk to the edge of the cliff. While the others were reluctant, Peter climbed over the fence and walked to the edge of the cliff. He lost his balance and fell off the cliff and broke his leg. Peter wishes to sue the Willow Council who is responsible for Watchout Point. What must Peter do to establish a breach of duty by Willow Council? Is Peter likely to succeed in establishing such a breach? Give reasons for your answer. The champagne bottle that the trio purchased had a very special kind of cap. Instead of the usual cork held in place by wire, it had a metal cap and a cork stopper. Mark opened the cap and tried to pour the champagne into a glass. When nothing came out he shook the bottle a little. The cork stopper suddenly ejected and hit Marks nose. He sustained a blood nose and was in pain for 3 weeks. There wasnt any warning anywhere in the bottle about this kind of cap. This sort of cap is very common in France and used by most French wineries. Mark wishes to sue the wine company. Will he succeed? What must he establish? Answer: Issue: The issue that is present in this can be described as being related with the reliability of Willow Council towards John as he suffered injuries after falling off from the edge of the Watchout Point, where they were celebrating their new business venture. As a result, it needs to be decided if Willow Council can be held liable under the law of negligence. Similarly, it also needs to be considered if reasonable steps have not been taken by the Willow Council which could have prevented the people from filing off. Therefore the question is if there is a duty of care on part of the Willow Council towards John. At the same time, another issue is also present in this case which deals with the liability of champagne manufacturer. In this case, the cork stopper hit Mark as he was trying to open the bottle because the bottle had somewhat different type of a cap. Rule: Duty of Care: According to the rule of law that can be applied in the present case, for the purpose of deciding the issue related with Willow Council's liability towards John, it needs to be seen if a duty of care is owed by the Council and if such duty has been breached. At the same time, the law requires that the injuries suffered by John should be the result of such breach of duty and at the same time, the injuries should be the reasonable result of the action or inaction on part of the Council. Generally in this type of cases, the doctrine of duty of care is used to claim compensation. According to the doctrine of duty of care, a party is considered as being liable towards the other party for tort of negligence. In this regard, Lord Atkins provided the neighborhood principle in the famous case of Donoghue v Stevenson. In this case, it was stated by the court that reasonable care needs to be taken by a party and avoid the acts or omissions if it is likely that the neighbor of the party may suffer injury as a result of such acts or omissions (Keenan, 2007). In such cases, an effort is made by the court to consider if reasonable proximity is present between the parties. In the same way, the court is also required to consider it the damage that has been suffered by the other party as a result of the act or omission could have been reasonably foreseen. At the same time, the court also has to consider if such a risk was foreseeable by any other reasonable person under similar circumstances. In the same way, it also needs to be seen if it would be reasonable for the court to impose a duty of care on the defendant in a particular case. The duty of care is a concept that has been discussed in detail by the court in Blyth v Birmingham Waterworks Co.In this case, the court stated that it is required that negligence on the part of the defendant should be decided by using the standard of reasonable person. Therefore it means that the defendant cannot be considered as negligent if all reasonable precautions have been taken by the defendant and as a result, the conduct of the defendant is in accordance with the standard of care that would have been followed under similar circumstances by any reasonable person. Test Used to Decide Duty of Care Caparo Industries v Dickman is also a significant case in which the court has provided the tests that can be used to decide the duty of care of the defendant. This test provides that in order to see if the defendant owes a duty of care or not, it needs to be seen if the loss or the injury suffered by the claimant could have been the result of defendant's conduct which was reasonably foreseeable. In the same way, it also needs to be considered if there is a relationship of sufficient proximity present between the parties or in other words, the parties can be considered as neighbors. Another requirement that was mentioned by the court in this case is to see if it will be just and fair to impose liability on the defendant, keeping in mind the circumstances of a particular case. In this regard, the law provides that generally it can be said that a party does not owe a duty of care towards the other party if it had taken reasonable steps with a view to prevent or reduce the harm that the other party may suffer by such conduct. On the other hand, even if a dangerous situation has been created by a person blamelessly, according to the duty of care, such person should take steps be reviewed to ensure that loss or injury is not caused to other persons. An example in this regard can be given of a person who has left his car on the road and has also put the lights of the car off. According to the duty of care present on part of such person, even if there was light on the road, the person owes a duty towards the other persons and drivers present on the road. As a result, if in this case, a car collides with the stationary car, it is possible that the person who has left the car on the road can also be held liable jointly. In this regard, the law also provides that i n case of certain circumstances, it is also possible that a person can be liable for the breach of duty of care in case of pure omissions also (Sappideen et al., 2009). In this regard, the law provides that in case there is a previous relationship present between the parties, a person can be considered as liable for the breach of duty of care. In the same way, such a relationship may also be imposed by a statute. Liability of Manufacturer Regarding the second issue that is present in this case, in Donoghue v Stevenson the Court has stated that tort of negligence has to be considered as an individual tort. The law provides that the plaintiff can take civil action if he or she has suffered loss or injury as a result of the negligence on part of the defendant. However before the decision given by the court in Donoghue v Stevenson, the plaintiff had to establish the presence of a contractual agreement for the purpose of establishing negligence. However in this case, the plaintiff had not purchased the drink and as a result, the contractual relationship was not present between the plaintiff and the defendant. However the court held that the manufacturer of the drink was liable under the thought of negligence. In this way, the law provides that the manufacturers have a duty of care towards the ultimate consumers also. The neighborhood principle that has been provided by Lord Atkins in this case requires that a neighbor can be a person who can be affected directly by the act or omission of the other party. As a result, the other party has to take reasonable care with a view to avoid the acts and omissions that can reasonably be considered as likely to cause injury to the neighbor. Application In the present case, two bottles of champagne were consumed by Peter, Mark and Mary in order to celebrate their new business venture. However, after drinking champagne, Peter got out of the car and also asked others to go towards the edge of the cliff. However, Mark and Mary did not follow him but Peter lost balance and fell from the edge. As a result, he broke his leg. In this case, a two meter high fence has been erected by the Willow Council so that the people can be prevented from going near the edge. But in this regard, it also needs to be noted that the council has not raised any warning signs at this point despite the fact that a large number of people came to the place in order to see its scenic beauty and this fact was well within the knowledge of the Council. On the other hand, so far as the liability of champagne manufacturer is concerned, the law requires that the duty to warn the consumers should be reasonably discharged by the manufacturers. In the present case, the ultimate consumers should have been informed that the bottle contains a special type of a cap and injury may be suffered by a person if the cap is not properly opened. In this regard it needs to be noted that in the present case, there was no warning on the champagne bottle regarding the cap. As a result, while trying to open the bottle, Mark suffered an injury when he was hit by the cork stopper. Conclusion Therefore in the present case it can be said that Willow Council has discharged its duty of care towards Peter and as a result, the Council cannot be considered as liable. The reason is that all the reasonable precautions have been taken by the Council as the Council was well aware that the place was visited by a large number of people due to its scenic beauty. Regarding the second issue that is present in this case, dealing with the liability of champagne manufacturer, it can be said that the manufacturer has breached its duty of care because there was no warning on the bottle regarding the fact that it contained a special type of a cap and if it is not handled properly, a person may suffer injuries. Therefore, Mark can succeed in his action against the wine company. References Keenan (2007) Smith Keenan's English Law (15th edn), Pearson Longman Sappideen, Vines, Grant Watson, 2009, Torts: Commentary and Materials, Lawbook Co, 10th ed, pp. 374-5 Blyth v Birmingham Waterworks Co (1856) 11 Ex 781 Caparo Industries Plc v. Dickman (1990) 2 AC 605 Donoghue v Stevenson (1932) AC 562 Greatlakes Shire Council v. Dederer Anor [2006] NSWCA 101 Wyong Shire Council V. Shirt [1980] HCA 12; 146 CLR 40