How should we structure domain names and URLs so that they are easy for search engines and users alike?

How should we structure domain names and URLs so that they are easy for search engines and users alike?

Zurich, the Lovely City of Switzerland

The city is beautiful and picturesque, but it is tough for people who want to travel on a budget. Zurich is basically a business city and the largest number of travelers here are business professionals. Zurich is the banking center of Europe and the world. There are many places where one might stay, but it is a little hard to find a discount hotel. The majority of hotels are located in the center of the city or in the downtown area, but there are few discount hotels and hostel beds in the suburbs which can be a little affordable. Most of the city center hotels are high end four or five stars luxury hotels which can cost you $200 to more than $1,100. One to three stars hotels range in between $60 to $350. But the good news is, almost all hotels are known for their no-compromise on service policy.

Food is also not cheap in the heart of Switzerland. Sit in restaurants can sometimes charge outrageous amounts, but luckily there are hundreds of street vendors and stalls selling traditional food items. Transportation in the city is also affordable because the government encourages people to use it. In summer, free cycles are provided to people for riding.

What to do: If you are going to Zurich on business, you can visit some of the best museums in Europe here. Kunthaus, Swiss National Museum and Museum Buehrle offer some of the best collections of art and Swiss history. The whole city itself is like a museum which is mostly enjoyed during summers.

When to go: There is no hotel season in Zurich because of the business nature of the city. Summer is usually the peak season when the hotel booking fares are at the highest. Prices tend to be a bit lower the rest of the year. If you want to enjoy Zurich, regardless of the hotel booking fares, then it is recommended to visit in summer.

Know All About Luxury Hotels

Something which gives us pleasure rather than sumptuous, great easy, expensive or necessity. These are all main points of luxurious. In past we’ve tried to help for you in all resorts and hotels however there is no standard definition to assist what is luxury or not?  Experience of luxury is very simple and good. Luxury hotel booking experience is like complete package of desires and needs.  It means total serenity. Luxury is defined by superior quality with elements of exclusivity and uniqueness.

If you are on visit then must try for extraordinary style offered by luxury hotels.  Such hotels are building with lagoon stylish pools. Featuring; resorts, luxury look, sophisticated traveler. Emphasizing grey volcanic stone and natural wood, their resort has style, local charm and comfort. The suits and rooms are decorated in style, lux bedding and modern conveniences. Select from the intimate garden view.  Succumb and relax to get all amenities and pleasures for rooms. You can enjoy the amazing activities. For trainers, health conscious staff with yoga classes, fitness center is also arranged in its premises.

Pack the sun-screen in your stylish bag and hit it for day to sun or sit nearest to the pool. If rejuvenation and relaxation is required in day time then reserve it for treatment where natural therapies help in restoring their senses. No doubt, if quit calm and seclusion are required in your stay then you have to visit their place. This garden has 2 pools and is suitable for wind.

All over the world, thousands of visitors selects luxury hotels. It is considered best for business travelers and tourists. Their services are considered momentum of hospitality.

Their main services includes Express Check In & Out, Guided rooms checking, Fruit and wine breakfast, lux brand amenities, free room service, exclusive lounge, coffee machine, packing and unpacking etc.

Luxury hotel is also known as world class hotel. It is recommended for business executive, Media celebrities, high ranking Politian’s and wealthy clients. They offer high scale lounges and restaurants with private dining facilities. Guest rooms are heated, oversized and plush towels for bath, shampoo, soap, shower caps etc. Housekeeping services are offered twice in day. These hotels give neat, safe and comfortable rooms.  Nowadays investors are converting their hotels into luxurious style.

Families can enjoy their free time with space for love, privacy and easiness.  They give resorts, spa, restaurants and lodges.  These hotels are changed all over the world. The major quality is their atmosphere. People believe it most important factor. Their staff knows the requirements and needs of their guests in advance and serves accordingly. I can assure you that you’ll feel happy after staying here.

Sell Your Car At WeBuyCarsToday

There are so many fake cars dealing websites in the market that it’s hard for a person to trust anyone, especially online. Such companies take your vehicle and never pay you a penny, even if they will pay you for your used vehicle, it would not be the correct value of your vehicle. Some car dealing companies will offer you the price for your vehicle even less than the market price. Is this thought not letting you sleep at night? Do not worry, as we assure you the best deals in the town at WeBuyCarsToday.

 However, there are few techniques of how to sell used cars, you have to be extra observant and smart in picking an online website or an automobile dealer. Who have gained a reputation of trustworthy dealer among the customers in the past four years of working period? At WeBuyCarsToday, they assure good service and quick response to their customers.

WeBuyCarsToday was established in 2010, since that time, they are providing friendly services to people. They purchase vehicles from the customers in all over UK and give them money as good as the market value of their vehicle. You can visit their website at www.webuycarstoday.com and get updates on the latest offers they are providing. They are considered to be one of the most professional cars dealing company in UK.

Read Our Ratings Score and Reviews- At WeBuyCarsToday, They make sure that their clients become happy and satisfied with their services. Company also updates their views and reviews on official web page. You can visit company website and read customers views about WeBuyCarsToday, You can also check out rating and Score.

Check Your Area Coverage-When you will log on to the website, you will observe a section, which indicates the area coverage. There is a map present there, by entering your postal code in the box given there and you will be able to locate your area. We deal with anywhere and everywhere in UK.

We also Purchase Fleet Vehicles-They also deal in purchasing fleet vehicles released by government or police departments, auto car dealers, and rental car companies at WeBuyCarsToday.

Our Fast Services-At WeBuyCarsToday, they have worked with more than 40,000 customers so far. They are experienced and have smart and knowledgeable staff members, who are ready to answer your queries and to help you 24 hours a day seven days a week.You can give them a call on 02071832311 or visit the web page at www.webuycaarstoday.com.

In Negligence actions causing psychiatric damage, why are the courts so reluctant to impose a duty of care on defendants where the claimant is a “secondary victim”?

A tort is a social incorrect for which a cure, more often than not recompense, is

obtainable to the aggrieved individual in the civil legislation and courts. Under the Law of Torts,

obligations are allocated to people in diverse states of affairs, and accountability for neglectful

or unlawful deed is compulsory by legislation. For example, a duty of care for the users on road

is forced by legislation on all of the drivers. A resident of a home is obligated to have a duty of

care to the guests and visitors who come to his home or its premises. Unlike the contract law,

this is dissimilar from compulsions in an indenture where the parties associated with the duty

of care willingly are in an agreement to be bound. The property owner or the car driver in the

cases mentioned above cannot break away from their legal responsibilities for contravene of their

duties, although they may be ready to cover for the losses held in accidents through insurance.

Where people are insured against any accident or mishap, the insurance company as a rule steps

down into the shoes of the insured party and if there is any form of a legal action the insurance

company tries to settle any claims by the claimant.

The most significant function of the Law of Torts is to make accessible the remedies for the

claiming party (or parties) that have gone through destruction, thrashing, or an infraction of

constitutional rights and civil liberties (turner and Martin, 2010). The damage engrosses corporal

injuries to personnel or property, smashing up of persons’ reputations or financial interests, and

interference with persons’ use and enjoyment of their land. Nevertheless, just id a party suffer

from any loss this does not necessarily ensures that the legislation will make available a remedy;

a claimant here must prove that the individual committing the wrong doings owed him a duty

of care and that the tort is responsible for causing the losses. This law envelops a wide range of

dissimilar civil torts including inattention, intruding, annoyance, and denigration of a party. Each

tort engrosses its own rules and guidelines about legal accountability but most torts necessitate

a component of blameworthiness, which is meant by the fact that legal responsibility is only

forced on an individual who deliberately or inattentively takes actions or fails to take appropriate

actions in a particular circumstance.

The Tort of Negligence

Negligence is an inevitable variety of tort which includes an extensive range of circumstances

where individual or a party is harmed by others’ negligence. For a victim to ask for necessary

actions taken by court, he first of all has to prove following three rudiments:

1. The defendant is obligated a duty of care to the claimant.

2. The defendant has violated a duty of care.

3. Violation of the duty of care has caused realistic predictable damage to the claimant.

Duty of Care

Each citizen owes a duty of care for the fellow citizens. For example road users owe duty f care

for other road users; a property owner owes a duty of care for the visitors at his property and

his neighbours too. There are few moral reasons behind imposing the duty of care like sense of

care and responsibility for each other and doing no harm to each other and their properties are

the chief moral reasons. Imposing such duties will encourage people to take appropriate actions

in certain circumstances too. Due to expansion of population and duties of care, the legislation

became worried of the uncontrollable and unmanageable amount of tort of negligence. For this

view, there is a three-stage test to determine whether the duty of care exists or not.

Test for establishing whether a duty of care exists

Consecutively for a duty of care to subsist, the damage caused to the claimant by the defendant

must have been practically anticipated at the time the defendant was neglectful. Also, the

claimant must prove the proximity of defendant with him which means that he has to establish

any personal relationship, duration of events and the evidence of tampered goods (Horsey and

Rackley, 2010).

When to impose a duty of care?

Even if the damage is convincingly projected and there is propinquity between the claimant and

the defendant, the legislation may still discover that there is no duty of care if it is not reasonable,

just, or logical to impress a sense of duty on the defendant. This is by and large a subject of

civic guidelines, and is where the courts have to take hardnosed contemplations into account and

choose if it is in the community awareness to enforce a duty of care. This final factor covers a

range of issues such as if the obligation of a duty of care would avoid the accused from carrying

out his work properly, or if the victim or claimant is supporting in the expenses of an offense.

The courts are every now and then unwilling to enlarge the duty of care, where to do so might

give confidence to a variety of similar claims. This is identified as the floodgates disagreements

or disputes.

Psychiatric Injury or Nervous Shock

Psychiatric damage, which is every now and then referred to as nervous alarm, is a form of

personal grievances but it is more intricate to allege for that physical injury. There must be

confirmation that the plaintiff has endured solemn psychiatric infirmities such as post-traumatic

stress disorder. Common anguish, nervousness, or foreboding, devoid of any physical injury, is

insufficient as it does not result to a psychiatric disease. According to Cooke (2010), the courts

have at all times been vigilant in recognizing a duty of care in relation to psychiatric damage, for

large number of grounds. It is more complicated to make a diagnosis of psychiatric grievance

than physical damage and, consequently, it is easier for the claimant to make forged argues. It

may result into opening of the floodgates of lawsuits and legal actions with a sprint of claims

being made by claimant thereby making psychiatric injuries very difficult to enumerate in

expressions of recompense. We have primary and secondary victims in psychiatric injury:

1. Primary Victim: A primary victim is a person who has experienced the actual threat of

physical harm or rationally alleged himself to be hurt, as a consequence of the negligent

happening.

2. Secondary Victim: A secondary victim is that individual who is suffering from a

psychiatric infirmity as an outcome of on looking a mishap or its instantaneous aftermath.

Claims for psychiatric injury by primary and secondary victims

When we talk about secondary victims, they themselves are not in any direct danger but suffer

shock reacting to the after effects of any mishappening or just by watching a person’s injuries

who has met with an accident.

It is significant to guarantee that the duty of care, forced on defendants, for any type of mental

hurt caused to secondary victims is constrained inside rational limitations. There are authorized

boundaries on the declarations by secondary victims.

In the first case, the people were the primary victims as they died in the accident and a duty of

care was owed to the rescuer who suffered mental trauma as a consequence of helping out the

sufferers in that horrifying accident.

Conversely, in the second case of White v Chief Constable South Yorkshire (1999) the House of

Lords cleared that the rescuer could only be classed as a primary victim if he was in continuous

threat of bodily wounding but the saviors in White were not at hazardous conditions and were

unable to claim as primary victims.

The claimant (secondary victim himself or a person related in case secondary victim is unwell)

must prove all of the following crucial necessities:

• There is a close tie of love and friendliness with the primary victim involved in the

accident so that it is convincingly predictable that the claimant will bear psychiatric

illness. (In this case, love and care is presumed to exist between spouses, and parents and

children, but other claimants must prove that such a relationship exists between them.)

• The secondary victim must be either present at the sight of the accident, see the building

up of the accident, or its instantaneous consequences. The secondary victim must have

watched or attended to the misfortune or the undeviating consequence with his own

senses without any help. It will not be entertained if the claimant has heard about the

accident on radio or television or by any third person.

• A medically-recognized psychiatric illness is suffered by the claimant as a result of the

incident.

Therefore, it is sometimes easy but most of the time very difficult to prove the above

requirements for any claim by the secondary victim. Sometimes, even the psychiatric injuries are

very difficult to surface immediately after the accident and may take a considerable amount of

time to show which will be not entertained by the court then.

Reference List

• Cooke (2010) Law of Torts, 9th ed. Pearson, Part 2.

• Horsey and Rackley (2010) Tort Law, Oxford University Press, Part 2.

• Turner and Martin (2010), Unlocking Torts, 9th ed. Hodder Education, Chapters 3, 4, and

5.

Williams v Roffey Bros & Nicholls (Contractors) Ltd [1991] 1 QB 1]

Introductin:

“The approach of the Court of Appeal [in Williams v Roffey Bros & Nicholls (Contractors)

Ltd [1991] 1 QB 1] strongly suggests that the modern courts will be more willing to find the

presence of consideration in the renegotiation of a contract and leave it to duress to regulate

the fairness of the renegotiation. Indeed, one of the factors which relied upon in adopting a

more liberal approach to consideration was the fact that the court could always set aside the

renegotiated contract on the ground of duress where the ingredients were established.”

Modern courts’ willingness to look for “presence of consideration in the renegotiation of

a contract”, subject to “duress to regulate the fairness of the renegotiation” while adopting

a liberal approach. On the grounds of duress, the renegotiated contract can always be set

aside by the courts. Furthermore, the relationship between consideration of renegotiation

of contracts and the economic duress has somewhat evolved gradually in the context,

leading the courts to adopt a relaxed approach towards the strict application of the law on

consideration.

While we explore the above and also attempt to understand how satisfactory the current

legal approach to consideration and duress is; we shall start by first briefly understanding

and analysing the Court’s approach of the appeal [Williams v Roffey Bros (Contractors)

Ltd, 1991]. Thereafter, we will discuss “The Doctrine of Duress” and “The Doctrine of

Consideration”.

The Case: Williams v Roffey Bros (Contractors) Ltd



This is a very appreciated and leading English law contract case: Williams v Roffey Bros

& Nicolls (Contractors) Ltd [Williams v Roffey Bros (Contractors) Ltd, 1991]. It was

instrumental in deciding that in modifying a contract, the court will be required to discover

reconsideration; on condition of the evidence of ‘factual benefits’ given from one party to the

other.

Facts

A contract to refurnish around twenty-seven flats in the area of Twynholm Mansions (At

Lille Road, London) was awarded to Roffey Bros by Shepherds Bush Housing Association

Ltd. For an amount of £20,000 carpentry was subcontracted to Lester Williams by Roffey

Bros. The amount was to be payable in instalments. On completion of part of work, an

amount of £16,200 was paid. Owing to the ‘low price’ the Williams ran into a financial

difficulty. Under a liability for the ‘penalty clause’ for late completion according to the

contract, the contracting party promised an extra amount of £575 for each flat for the ‘in-
time’ completion. Consequently, after completing eight flats William ceased the work as he

had received an amount of £1,500 only. Later, the contracting party roped in new carpenters,

which resulted in William filing a court claim.

The Court held that Williams should receive an amount that will be as much as eight times of

the amount originally promised. The court further said that the contracting party had agreed

that the original amount that was fixed for the contract was too less than the standard rates.

And it also advised for raising the amount keeping in place the mutual interests of both the

sides.

Judgement



The court held that considerations provided by William were sufficiently good enough,

in spite of the fact that he was performing a pre-existing duty. It was further added that

the court’s idea of “promissory estoppels” was still not completely developed and argued

sufficiently in the correct manner. Therefore the concept of economic duress provides a

possible resolution.

A test for identifying the legitimacy of variation in contract was set. The test included two

parties where One (A) has contracted work to the other (Say, B). A condition may arise

which leads A (the contractor) to believe that, even before the work is completed, B would

not be able to deliver the finished goods or services in time. This drives A to promise a higher

remuneration to B with a purpose of encouraging him to complete the work in time. Here in

the case, herewith, no economic duress is identified.

Though an already existing duty has been performed, the obvious benefit of having the work

completed in-time or before-time, can be recognised as good enough consideration.

As the principle had not been processed for anymore refinement, the three identified

cases carried the complete dependency, and were unanimously applied after the legal

considerations were found out. The considerations were such that none of the post-
contractual changes or variations could have been upheld. Thus the above test was considered

to be just a refinement of “the Stilk v Myrick principle” while leaving it unharmed. It was

held as to not to be the accurate measure. It was stated that numerous practical benefits apart

from the ones that from the part of the original consideration may actually go on to form

greater to the required good consideration in lieu of the fulfilment of the contract.

Russell LJ’s interpretation in the favour of the claimer:



 “The courts nowadays should be more ready to find [consideration’s] existence so as to

reflect the intention of the parties to the contract where the bargaining powers are not

unequal.”

Notable was the fact that even Roffey Bros’ employees felt the existence of below par

designed remuneration, far less than reasonable. This led to an imminent requirement to

change the existing way of payment in to a better designed formal method that takes into

consideration the economic factors and then decided upon to the money per flat. Finally the

variation was supported by consideration which now appears to be a pragmatic approach

towards a more amicable and collaborative relationship between the parties.

Duress and Consideration: Relationship

Concept of Economic Duress

In the English contract laws, the fairly established doctrine of duress states that one party

from the contract is allowed to decide the terms of an agreement through providing proof of

an undue force or pressure that was put on them by the other party to the contract, that is,

against property or person, at the time of formulation of the initial agreement. Here, the party

that is subjected to undue duress or pressure states that it had no option other than accepting

the terms and enters the contract.

Presently, Economic duress is found to be a comparatively fresh development in the

context of contract law but is considered of increasing importance owing to the undeniable

and practically noted consequences for the parties that enter into any kind of contractual

commercial agreements.


In recent years the Courts have now come to accept that, apart from the threats that are posed

against a single person (part of a contract) or their property, the economic threat of could also

be of equal significant force in making a party to sign an agreement despite their reservations.

Economic duress is therefore this undue commercial pressure that lets an innocent party to

give into unfavourable choices.

Doctrine of Consideration

Before the recognition of the concept of economic duress, the position of such commercial

situation was kept safe by famous the doctrine of consideration. Here, consideration is

termed as the amount that is paid by one party the promise of another. While the law

states that consideration mandatorily has to suffice but there is no compulsion of it being

adequate. It was recognized that, the initial duty assigned was never a condition for sufficient

consideration for promising a higher remuneration. In a case where sailors were not able to

claim an extra share of wages for those who had left as no further consideration had been

given for the promise of the desired additional wages. Moreover, they were already contract-
bound by a pre-existing task of serving on the ship as much as possible. Logic behind the

mentioned statements says that someone who is entering a contract with somewhat a strong

bargaining position could actually stress on payment of extra wages or money for performing

a already assigned duty, while the second party may not be left with any choice but to agree

to the first party’s demands. Such possibility of extortion was seen in certain cases.

The Relationship: In light of Williams v Roffey Brothers

Enforcement of a promise of additional payment in context of a pre-assigned duty has not

always been held up. In the previously discussed case, on part of the contracting party an

amount extra to the initially agreed amount was paid to the other party A to perform an



existing duty as part of the terms of the contract. This was done when B was aware of the

knowledge regarding the inappropriateness of the amount that was initially contracted with

A and was in fact too low when compared to the standard rates. They were also aware that A

would be unable to meet deadlines of the assigned work and eventually prove damaging to

B, commercially. As is evident, the additional payment to be made to A by B had practical

benefits for B, and doing this would also serve as the consideration for the same. On A’s part

there was no suggestion of duress.

In cases where the previously discussed case was not applied, as the Courts have been

considering that where a debt is repaid by instalments as there would certainly exist some

kind of actual benefit to the contract giver or the credit giver. Henceforth, the practical

benefit alone, in any case, will not be treated as the sole consideration since the in debt party

shall owe the amount in any case. Also, it happens in the case when the credit giver would

actually get an some extra benefit that “Williams v Roffey” will be applied.

Conclusively the aftermath of the examples and court-cases is that, whenever there are

any products supplied in form of services provided or manufactured goods, and there is

a practical benefit derived, reasonable re-negotiations are possible with no duress. So the

Economic duress is indeed a parameter that let measure reasonability of the re-negotiations.

Relaxation on the strict application of law of consideration

Economic duress is nowadays needed to be differentiated from commercial pressures that are

legitimate. Threats that attempt to drift business and that tend to drop or remove discounts

and prohibit buying and selling from a competitor. These are categorised as legitimate

commercial pressures instead of any kind of duress.

LLB CONTRACT LAW 8

Recent cases have helped establish that the innocent party must not have voluntarily opted

for entering into the contract, for application of economic duress for the contract that a party

enters and the amount that is paid. Also, the pressure exercised on the innocent party in order

to make them agreeing to the contract and enter will be termed as illegitimate. Therefore,

any threats that is not proper and legitimate and that lead to compulsion on the part of that

party to enter into a contract shall be termed an economic duress [CTN Cash & Carry Ltd v

Gallagher, 1994]. It may simply be stated as the absence of choice for the party.

Conclusion

In conclusion, though economic duress in English Law is considered to be a fresh concept,

its implications were far more important than visible. Economic duress and similar problems,

in a way were faintly shielded by the classic “doctrine of consideration” which protected

innocent parties by not allowing any kind of further promises in absence of consideration

enforcements and thereby protects the contracted parties from possible kinds of contract-
originated extortion and commercially unethical pressure where bargaining powers were

unequal for the two parties.

As it was visibly dissatisfactory for the previously discussed case of “Williams v Roffey”

displayed that for extended promises, practical benefits are considered to be sufficient

consideration, providing a clear advantageous position for the other party. A very bleak

difference that distinguishes between what can be considered to be a straight and thoughtful

commercial negotiation, and a threatening economic duress; let a part in the contract create a

somewhat financially superior position in the contract. The innocent parties these days seem

better protected through recognition of the possible economic duress instead of arguments

over inadequate past consideration.



The law according to the courts needs to be therefore applied for the party that is actually

facing injustice arising from the varying of the initial contract. Keeping in consideration the

details that differentiate legitimate commercial modification to duress or economic duress,

the law of consideration has to be put to application in an albeit subtle manner. This needs

to be so as to recognise only the legitimate terms of the contract as proper and sufficient

considerations. The purpose of this is to avoid misjudgement on the part of courts and

injustice on the part of either of the parties.

Present volatility of the commercial market owing to the various external factors such as the

economic turbulence in the commercial space, the related ‘demand-supply’ variation for the

contracting party in the market, the availability of cheaper labour, the special terms laid down

in the contract and the ever increasing competition for both the parties, the contracted as well

as the contracting, makes the task of the court altogether a lot more complex that it was

previously. Still the numerous examples of the cases go to prove that either of the parties

could be at fault, knowingly or unknowingly. However, in light of the case that we are

discussing even though the fault lies with the contracting firm and the courts held in favour

of the contracted, innocent party, the mere acknowledgement on the part of the contracting

party of the fact that the promised amount was needed as the original amount that was fixed

in the initial contract was not reasonable. The intensions of the contracting party is therefore

seen as fair and the initial fixed amount was merely a result of successful commercial

negotiation on the part of contracting party and a miss of commercial opportunity on the part

of the contracted firm. Having said this, it is also upheld that even though the contracted

party missed to avail an opportunity and entered the contract even when the contracted

amount was low, there is absolutely no way that it’s right can be jeopardised considering that

the contracted party nevertheless remained innocent. The additional payment, therefore,



promised by the contracting party to the innocent party have two fold effects: first,

encouraging the contracting firm to complete the pre-existing duty that is bound to it

according to the original contract; secondly, it also outlines an attempt on the part of the

contracting party to avoid a possible damage that can occur to its financial settings because of

the task that would otherwise be left incomplete by the innocent party. Therefore it makes it a

sufficient consideration to be termed as a case of economic duress and amounts to an undue

pressure that led the contracted firm with less choice other than entering the contract. For

courts, the complexity increases when the contracting firm is equally innocent and trying to

keep decision making power to be equally distributed among the two parties but the external

economic factor play a major role disabling the two parties to keep to the terms of the

original contract, owing to the loss that each one of them may encounter.

Altogether the current legal approach to consideration and duress is a vital attempt to

maintain the rights of both parties in the contract and takes care of upholding the practical

benefit driven approach. The law in itself create a balance of ‘negotiation-power’ between

both the parties of the contracts without jeopardising the common interests. The law is

already playing an important role in making the courts view the contract-cases in a new light

and is set to further streamline itself with more judicial contribution so as to re-affirm it

importance and aid justice.

References:

Philip Newman,Barrister and NitinKhandhia, Solicitor, The law of Economic Duress, Vol. 01

pp. 2-15

Harris v Watson discussed in Smith, J. C. – Smith & Thomas A Casebook on Contract (11th

Edition) p.233 and p.235, Sweet & Maxwell, London

J.R. Carby-Hall, (1986) "Termination of Employment Other Than By Dismissal", Managerial

Law, Vol. 28 pp.1 - 17

M.H.Ogilvie, “Economic Duress, Inequality of Bargaining Power and Threatened Breach of

Contract”

Resource Book 2 W300: Law – Agreements Rights and Responsibilities (2003), Open

University, Milton Keynes

 Stilk v Myrick (1809), Smith, J. C. – Smith & Thomas: A Casebook on Contract (11th

Edition) p.234, Sweet & Maxwell, London

Treitel, The Law of Contract, 10th Edition, 1999, Sweet & Maxwell pp.88-92

Williams v Roffey Brothers & Nicholls (Contractors Ltd, Smith & Thomas: A Casebook on

Contract (11th Edition) p.236, Sweet & Maxwell, London

My recent Resarch On Fracking...!

What is FRACKING! 

Montgomery, Carl T. Smith, Michael B. (2010) emphasize that Hydraulic fracturing was introduced in 1949 by stanolind oil. In universal, just about 2.5 million fracture treatments have been accomplished. According to some opinion, nearly 60% of all drilled wells are fractured.   Fracture stimulation enhances the efficiency and it also helpful in the addition of reserves

In 1860, nitroglycerin in the form of liquid and later on solidified was to set up shallow and hard rock wells in some states of America (Kentucky, New York, Pennsylvania and West Virginia). Nitoglycerine was used illegally to some extent, but was thoroughly successful for oil well ”shooting”.  The main purpose of shooting a well to fragmentize the formation of oil bearing in order to raise the flow and recovery of oil.

In the beginning of 1930s, the test was being done by interjecting an acid (non explosive fluid) into the ground to set up a well. In order to create fracture a phenomenon called “pressure parting” was introduced in well-acidizing procedure that would not close thoroughly due to acid etching which will lead to a flow channel to well and strengthen productivity. Later on this phenomenon was practically applied in the field with acidizing wells, water injection and squeeze-cementing procedure.

This essay highlights that Shale gas could be most valuable sources of energy in coming few years. Shale gas like other energy sources has its benefits and drawbacks. By defining shale gas, during hydraulic fracturing shale gas are torn up and extracted from underground and basically it’s a natural gas normally found in the shale rock.

Hydraulic fracturing is a proven technological advancement which allows producers to safely recover natural gas and oil from deep shale formations. This technology has the potential to not only dramatically reduce our reliance on foreign fuel imports, but also to significantly reduce our national carbon dioxide (CO₂) emissions and accelerate our transition to a carbon-light environment. Simply put, deep shale gas and oil formation development is critical to America's energy needs and economic renewal.

Advantages:

If the word “shale” has not already given the game away, it’s the formation that Australian company Tamboran says holds up to 4.4 trillion cubic feet of natural gas – equivalent to 12 years of Irish daily consumption and enough to support 3,000 jobs for four or five decades. The rock pokes through the surface at Bundoran from where it stretches back inland.

Fracking has had a near revolutionary impact in the United States. Gas prices have fallen from about $14 a unit in 2008 to close to $2. Its impact there prompted US President Barack Obama to voice his support for the shale gas industry in last month’s state of the union address.

While reading about shale gas benefits by energy experts, the most meaningful point is that it emits low carbon emissions in comparison to coal as coal gives off double the emission of carbon.

Shale gas is also a rapidly available source of energy. Let’s say for instance if according to the latest survey, if these are right then North America has nearly 1,000 trillion cubic feet of recoverable shale gas and it fulfills the needs of natural gas of US for nearly 50 years. According to recent studies, it’s been highlighted that shale gas could provide half of America’s supply of gas by 2020.

The comparison in prices, it found that because of high amount of shale gas production would decrease the prices of natural gas. The production of shale gas will also help us in not on relying on other foreign expensive fuels and it can improve our energy security. For those countries which relying mostly on coal, which is not effective source,

According to the reports, because of the much more use of domestic production of shale oil and ethane the import of oil in US would fall below 1990s level on large basis. So in this sense, US would be more interested in export of natural gas according to Dudley about oil imports “are likely to be half of today’s level in2030”.

Thoroughly, the demand of global energy would increase in coming 20 years, which will be much more needed by china and India as according to the population growth and economical point of view. By 2030, economical point of view, from the sub-continent China and India would be third largest economies and energy consumers, both countries will reckoning about 35 % of overall population, Gross Domestic Products and energy demand.

In the coming two decades, the demand of energy would be likely to increase by 39%, or 1.6 annually, nearly in non –OECD (Organization for Economic Co-operation and Development).  In OECD countries the possibility of consumption is just 4% in total in coming period.

DISADVANTAGES: 

From environment point of view, there are some disadvantages of shale gas which in not acceptable. In spite of its being more valuable energy source with significant carbon emissions as compared to coal, shale gas has some drawbacks. Because of the leakage of methane gas from shale gas wells which is also environmental hazard. It can neutralize carbon dioxide reductions as well.

Fracking has its main effect on traffic before process of fracking starts bringing all the materials for each site and it will take about 30-40 days, 24 hours, 7 days a week. It also has some effects on water because 2.5 million of gallons of water is needed during mixture with 47,000 litres of chemicals which is a big risk of spoilage and leakage of water. It creates air pollution as well as because of escape of methane gas and vaporization of chemicals. and it is against the environmental hazards as it destructs the land, the soil, meadows and eventually it causes earthquakes in small ratio but not acceptable. From economical point of view, tourist won’t come to visit and there will be a loss in the food products. And in the end value of land, costs of land will gradually fall because of no cultivation and because of soil erosion.

The shale gas industry could make an impact on energy industry in terms of development as it could slow down the development, particularly if shale gas becomes much more cheap. As compared to shale gas and coal, renewable energy is not that competent. For renewable energy it would be a worst factor.

Regarding fracking, there are some more danger around the world. During fracking, there are chances of mixing toxic chemicals and methane with local water which can poison drinking water and it is harmful for human beings and animals, and also can poison agricultural land. At the beginning of this year in Lancashire, there was an earthquake likely caused by fracking as according to recent report from industry.  In USA, the places where fracking has been done, leakage of methane gas was that much that the people in their houses while using tap water can effortlessly put their tap water on fire.